ML093310182
| ML093310182 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/23/2009 |
| From: | Cleary T Tennessee Valley Authority |
| To: | Parker P Office of Nuclear Reactor Regulation, State of TN, Div of Water Pollution Control |
| References | |
| TN0026450 | |
| Download: ML093310182 (2) | |
Text
Tennessee Valley Authority Post Office Box 2000 Soddy Daisy, Tennessee 37384-2000 Timothy P. Cleary Site Vice President Sequoyah Nuclear Plant November 23, 2009 Patrick Parker Manager, Enforcement & Compliance Department of Environment & Conservation Division of Water Pollution Control 6th Floor, L & C Annex 401 Church Street Nashville, Tennessee 37243-1534
Dear Mr. Parker:
SEQUOYAH NUCLEAR PLANT (SQN) - BIOCIDE/CORROSION TREATMENT PLAN (B/CTP) -
NPDES PERMIT NO. TN0026450 On October 25, 2009, during treatment with Spectrus CT1 300 from the period of 0830 to 1800, Sequoyah did not collect an effluent sample as specified in the SQN Biocide/Corrosion Treatment Plan (B/CTP). Evaluation of the treatment concluded that during the entire treatment period the concentration of the quaternary ammonium compounds in the discharge did not exceed 0.05 mg/L by mass balance calculations. In addition, no harm to fish or other aquatic species was observed. Sequoyah has initiated documentation of the incident, the follow up investigation, and corrective actions in accordance with the site's Corrective Action Program. Enclosed for your review is a summary of the incident. If you have any questions or need additional information, please contact Stephanie Howard at (423) 843-6700 or Ann Hurt at (423) 843-6714 of Sequoyah's Environmental staff.
I certify under penalty of law that this document and all 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 inquiry of the person or persons who manage the system,-.
or those persons directly responsible for gathering the information, 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, Timothy
.Cleary Site Vice President Sequoyah Nuclear Plant Enclosures cc (Enclosures):
Chattanooga Environmental Assistance Center
'U.S. Nuclear Regulatory Commission Division of Water Pollution Control.
ATTN: Document Control Desk State Office Building, Suite 550 Washington, D.C. 20555 540 McCallie Avenue" Chattanooga, Tennessee 37402-2013 printed on recycled paper
ENCLOSURE SEQUOYAH NUCLEAR PLANT SPECTRUS CT1 300 EFFLUENT SAMPLE Backaround According to the Biocide/Corrosion Treatment Plan (B/CTP) approval dated April 27, 2005, for the use of Spectrus CT1 300, "when treatment is underway, routine sampling of the effluents shall be undertaken once each four hours during daylight hours and once during nighttime hours, (or composite sampler may be used)." SQN uses an ISCO composite sampler to meet the sampling requirement. Samples are analyzed using a low-level detection method; sampling-is required in conjunction with a mass balance calculation in order to demonstrate protection of the receiving stream.
Incident Description Spectrus CT1 300 treatment was scheduled for 10/22/2009 through 10/24/2009. The composite sampler was scheduled to collect samples from the morning of 10/22/09 to the morning of 10/25/09. Treatment was initiated as scheduled on 10/22/2009; however the treatment was actually terminated on 10/25/2009. Due to the schedule change for the treatment, no sampling occurred on 10/25/2009 from 0830 to 1800. Table 1 summarizes daily plant conditions and quantity of chemical used. Table 2 summarizes the treatment schedule, mass balance calculation, and composite sampler schedule and analytical results.
Table 1 Date 10/22/2009 10/23/2009 10/24/2009 10/25/2009 Diffuser Discharge Flow 2500 cfs 2500 cfs 2500 cfs 2500 cfs ERCW A Train Total Flow 22000 gpm 20700 gpm 22300 gpm 22300 gpm Injection Rate 5.5 gph 5.5 gph 5.5 gph 5.5 gph Injection Start Time 1300 0000 1800 0000 Injection Stop Time 2400 2150 2400 1800 Total Hours Injected 11.00 21.83 6.00 18.00 Calculated System Quat 1.93 mg/L 2.06 mg/L 1.91 mg/L 1.91 mg/L Pounds Per Day Quat 234.77 lbs.
465.90 lbs.
128.05 lbs.
384.16 lbs.
Calculated Diffuser Discharge Quat 0.040 mg/L 0.040 mg/L 0.040 mg/L 0.040 mg/L Table 2 ERCW A Train Mass Balance Composite Sampler Composite Sampler Calculation Results Start Date / Time Start Date / Time.
End Date Time End Date / Time 10/22/2009 / 1300 0.040 mg/L 10/22/09 / 1000
<0.025 mg/L 10/22/2009 / 2400 10/23/09 / 0900 10/23/2009 / 0000 0.040 mg/L 10/23/09 / 1000
<0.025 mg/L 10/23/2009 / 2150 10/24/09 / 0900 10/24/2009 / 1800 0.040 mg/L 10/24/09 /0930
<0.025 mg/L 10/24/2009 / 2400 10/25/09 / 0830 10/25/2009 / 0000 0.040 mg/L no sample collected no sample collected 10/25/2009 / 1800 from 0830 - 1800 from 0830 - 1800 The B/CTP specifies that the concentration of the quaternary ammonium compounds (Quat) at Outfall 101 shall-not exceed 0.05 mg/L. All mass balance calculations performed during the treatment were 0.040 mg/L. All composite samples collected during the treatment were <0.025 mg/L using the methylene chloride extraction. Historical composite sample analytical results have been <0.05mg/L or lower at Outfall 101 for similar plant conditions.