ML053410267

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2005 Discharge Monitoring Report - Qualify Assurance (DMR-QA) Study 25 Corrective Action Report
ML053410267
Person / Time
Site: Sequoyah  
Issue date: 12/05/2005
From: Howard S
Tennessee Valley Authority
To: Mcadoo M
Office of Nuclear Reactor Regulation, State of TN, Dept of Environment & Conservation, Div of Water Pollution Control
References
Download: ML053410267 (2)


Text

Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 December 5, 2005 Mr. Mark McAdoo State of Tennessee Department of Environment and Conservation Division of Water Pollution Control Enforcement & Compliance Section 6th Floor, L&C Annex 401 Church Street Nashville, Tennessee 37243-1534 Mr. McAdoo:

2005 DISCHARGE MONITORING REPORT - QUALITY ASSURANCE (DMR-QA) STUDY 25 CORRECTIVE ACTION REPORT Please find enclosed the corrective action report on the 'not-acceptable" Total Residual Chlorine for the 2005 DMR-QA Study 25 Laboratory Performance Evaluation obtained by TVA Sequoyah Nuclear Plant (SQN) and supporting Laboratories as required by NPDES Permit TN0026450.

Please contact me at (423) 843-6700 if you have any questions or comments.

Sincerely, Stephanie A. Howard Principal Environmental Engineer Signatory Authority for J. Randy Douet Site Vice President Sequoyah Nuclear Plant Enclosure cc (Enclosure)

Mr. Wayne Turnbull EPA Region IV ESD/ASB/LE&QAS 980 College Station Road Athens, Georgia 30605-2720 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Chattanooga Environmental Assistance Center Division of Water Pollution Control State Office Building, Suite 550 540 McCallie Avenue Chattanooga, Tennessee 37402-2013 2 5 P-oted an ycBed pape

DMR-QA Study 25 Corrective Action Report Problem The graded Final Report 2005 Discharge Monitoring Report - Quality Assurance (DMR-QA) Study 25 for Total, Residual Chlorine (TRC) showed the performance evaluation as 'not acceptable."

Not Acceptable is when a reported value falls outside the acceptance limits. The acceptance limits for TRC were 0.653 - 1.10mg/L and SQN's reported value was 1.17mg/L.

Investigation SQN investigated and looked at the following possible errors made:

1) Bubble in the buret
2) Subtraction error
3) FAS titrant check
4) Manganese interference
5) Dilution error
6) Sample volume error
7) Sample preparation error Based on observations of technicians analyzing an additional sample, SQN ruled out all of these errors except for the possibility of the bubble in the buret and the subtraction error.

Corrective Actions

1) Disqualified analyst to perform total residual chlorine analysis.
2) Ordered and analyzed a remedial QC - Residual Chlorine, WasteWatR sample from Environmental Resource Associates (ERA).
3) Revised SQN Procedure 0-TI-CEM-260-011.9 to include the beginning and ending titrant volumes and also to verify there is no bubble in the tip of the buret.

Remedial QC sample results of analysis The acceptance limits for the remedial QC - Residual Chlorine, WasteWatR sample were 0.874 -

1.37mg/L and SQN's remedial value was 1.28mg/L. SQN's value of 1.28mg/L met the acceptance criteria for the remedial sample.

4t4ckQ Stephanie A. Howard Principal Environmental Engineer Signatory Authority for J. Randy Douet Site Vice President Sequoyah Nuclear Plant USEPA Lab Code: TN00999