ML032200040
| ML032200040 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 07/25/2003 |
| From: | Crawford R Tennessee Valley Authority |
| To: | Hannah C Office of Nuclear Reactor Regulation, State of TN, Dept of Environment & Conservation |
| References | |
| Download: ML032200040 (5) | |
Text
Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 July 25, 2003 Mr. Chip Hannah Tennessee Department of Environment & Conservation Division of Water Pollution Control Enforcement & Compliance Section Sixth Floor, L & C Annex 401 Church Street Nashville, Tennessee 37243-0455 Dear Sir.
WAITS BAR NUCLEAR PLANT (WBN) - NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT NO. TN0020168 - RESPONSE TO NOTICE OF VIOLATION This letter is in response to a Notice of Violation letter dated July 3, 2003, see attached letter. The period of Noncompliance on Outfall 112 for the chronic toxicity to larval fathead minnows (Pimephales promelas) was April 13-May 2. A retest was performed the week of April 27th. The retest ended the Noncompliance on May 2 which resulted in an ICz value of
> 100 percent. The cause of the Noncompliance was due to naturally occurring pathogens as found in the study performed at WBN in 2001. WBN is now in compliance with our NPDES permit. WBN understands the requirements of our NPDES permit and that we are subject to enforcement action until compliance is achieved with our NPDES permit. A copy of the Notice of Noncompliance Is also enclosed for your reference.
If you should have any questions or need additional information, please contact me at (423) 365-8005 at Watts Bar.
I certify under penalty of law that this document and al attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the Information submitted. Based on my lnquiy of the person or persons who manage the system, or those persons directly responsible for gathering the formation, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false Information, including the possibility of fine and imprisonment for knowing violations.
Sincerely, Robert J. Crawford Environmental Supervisor FddAid C eywPOW
Mr. Chip Hannah Page 2 July 25, 2003 Enclosures cc (Enclosures):
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Mr. Mike Kelley Tennessee Department of Environment & Conservation Division of Water Pollution Control Environmental Assistance Center 540 McCallie Avenue, Suite 550 Chattanooga, Tennessee 37402
STATE OF TENNESSEE DIVISION OF WATER POLLUTION CONTROL 401 CHURCH STREET L & C ANNEX 6TH FLOOR NASHVILLE TN 37243-1534 July 3, 2003 CERTIFIED MAIL Mr. Robert Crawford, Environmental Supervisor TVA Watts Bar Nuclear Plant P.O. Box 2000, Mob It Spring City, TN 37381-2000
Subject:
Notice of Violation NPDES Permit#TN0020168 TVA Watts Bar Nuclear Plant Rhea County, Tennessee
Dear Mr. Crawford:
This letter serves as a Notice of Violation. The Division of Water Pollution Control has reviewed the Discharge Monitoring Reports (DMRs) for TVA Watts Bar Nuclear Plant and found the violation(s) of permit terms, shown on the attached report.
- The Division of Water Pollution Control requires a written explanation of the violation(s) summarized on the attached report within 30 days, if you did not submit an explanation with the DMR. The explanation must include the reason for the violation(s) and the corrective action taken to avoid future violation(s). The explanation should be sent to the attention of Mr. Chip Hannah at the address shown in the letterhead.
Your facility is subject to enforcement action due to non-compliance with permit terms.
However, your explanation will be considered prior to further action from this Division. Please be advised that pursuant to T.C.A. 69-3-1 15, civil penalties may be assessed for each day a violation occurs or continues. If you have questions or concerns regarding this correspondence, contact Mr. Hannah at 615-532-0683.
Sincerely, Christopher S. Moran, Manager Enforcement and Compliance Section cc: EAC-Chattanooga Compliance File
NPDES Permit #TN0020168 July 02,2003 TVA - Watts Bar Nuclear Plant Facility Type: Major Industrial Rhea County, Tennessee WPC Staff: Mr. Chip Hannah
SUMMARY
OF VIOLATIONS Discharge Monitoring Reports (DMRs) for 4/1/2003 through 4130/2003.
Explanation Reported Permit Received Value Umit Unit Code Stathi,tical Base Violation Type with DMR -
Outfall Parameter 1112 1C25 Statre 7day Chr pimephales l 1E1 D i 100l I Percent l Min!mum 'INumedc Violation
. A.
2 .
l
NOTICE OF NONCOMPLIANCE WITH EFFLUENT LIMITATION NPDES PERMIT TN0020168 WAITS BAR NUCLEAR PLANT April 18, 2003 Outfall Serial Number (OSN) 112: Runoff Holding Pond Description of the Noncompliance:
Semi-annual toxicity testing of OSN 112 demonstrated chronic toxicity for larval fathead minnows (Pimephales promelas). Sampling was conducted from April 13-18, 2003. The IC25 value resulted in 82.5%, which did not meet the permit limit of 2100%. There were no toxic effects seen in Daphnids (Ceriodaphnia dubia).
Cause and Period of the Noncompliance:
The noncompliance is known to have begun April 13, 2003, when the initial test sampling began. Preliminary results from repeat sampling conducted from April 28-May 2 indicates the period of noncompliance likely ended May 2. Final reviews and Engineering confirmation of the repeat test will be completed in late May. The cause of the Noncompliance was due to naturally occurring pathogens.
Steps Taken To Reduce. Eliminate, and Prevent Recurrence of the Noncompliance:
Corrective actions include the retest. UV pretreatment controls tested in parallel for this outfall indicated no chronic toxicity for larval fathead minnows. This is similar to the Notice of Noncompliance that was submitted for the same outfall on April 21, 2001. A study was performed in 2001 at WBN and indicated that the failure of Whole Effluent Toxicity testing for fathead minnows was due to naturally occurring pathogens in this outfall. The same pattern of failure is seen here. A copy of this study has been provided to TDEC. Additional copies are available upon request. No further actions are believed necessary at this time.