ML12068A115

Tennessee Storm Water Multi-Sector General Permit for Industrial Activities Permit No. TNR050015 Sector O Exceedance of the Benchmark Monitoring Requirement

ML12068A115
Person / Time
Site:	Sequoyah
Issue date:	03/06/2012
From:	John Carlin Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation, State of TN, Div of Water Pollution Control
References
Download: ML12068A115 (4)

Text

Tennessee Valley Authority, Post Office Box 2000, Soddy Daisy, Tennessee 37384-2000 March 6, 2012 Chattanooga Environmental Field Office Division of Water Pollution Control State Office Building, Suite 550 540 McCallie Avenue Chattanooga, Tennessee 37402 TENNESSEE VALLEY AUTHORITY - SEQUOYAH NUCLEAR PLANT - TENNESSEE STORM WATER MULTI-SECTOR GENERAL PERMIT FOR INDUSTRIAL ACTIVITIES PERMIT NO.

TNR050015 SECTOR 0 EXCEEDANCE OF THE BENCHMARK MONITORING REQUIREMENT.

Please find enclosed the thirty day notification, the lab analysis for the exceedance of the benchmark monitoring requirement for total recoverable iron for Storm Water Outfall Numbers 2 and 15, the sixty day notification of the review of Sequoyah Nuclear Plant's Storm Water Pollution Prevention Plan (SWPPP), and a summary of Best Management Practices (BMPs) modifications and additions to mitigate future exceedance of total recoverable iron.

Description of Event Tennessee Storm Water Multi-Sector General Permit for Industrial Activities Sector 0 requires annual monitoring of total recoverable iron. Sequoyah Nuclear Plant sampled for total recoverable iron on January 17, 2012. The storm water analytical monitoring results were received on February 10, 2012 and February 13, 2012. The analytical monitoring results for Storm Water Outfalls Nos. 2 and 15 exceeded the benchmark monitoring requirement for total recoverable iron as stated in Table 0-2, Benchmark Monitoring Requirements for Steam Electric Power Generating Facilities. The storm water event was triggered by a steady rainfall that continued throughout the day. The analytical results can be seen tabulated below.

Table 1. Storm Water Annual Iron Exceedance Values Benchmark Storm Water Sample Date Sample Analysis Analytical Monitoring Outfall Number Received Date Results (mg/L) Requirement (mg/L) 2 1/17/2012 2/10/2012 9 5 15 1/17/2012 2/13/2012 25 5 The Tennessee Storm Water Multi-Sector General Permit for Industrial Activities requires informing the division's local Environmental Field Office (EFO) within 30 days from the time storm water monitoring results were received describing the likely cause of the exceedance.

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Likely Cause of the Exceedance The likely cause of the exceedance of the benchmark monitoring requirement for total recoverable iron is elevated background iron concentration in the soil around the storm water outfalls (based on historical sampling) and the need for more effective best management practices (BMPs).

SWPPP Review and Modification Timeline Sequoyah Nuclear Plant's SWPPP has been reviewed to determine the modifications and additions to the plan which would assist in reducing the iron effluent concentration at Storm Water Outfall Nos.

2 and 15. A brief summary of the proposed modifications, including a timetable for implementation follows.

Storm Water Number 2 Per the SQN SWPPP, there are no paved surfaces in this drainage area. Ground cover consists of crushed stone, gravel, and grass. Drainage ditches are equipped with check dams as BMPs.

Iron absorbing booms / socks will be added to this drainage area as a BMP to reduce total recoverable iron in the storm water effluent. The placement of this additional BMP will be completed by 06/08/2012.

Storm Water Number 15 Per the SQN SWPPP, there are no paved surfaces in this drainage area. Ground cover consists of crushed stone and grassy vegetation.

Iron absorbing booms / socks will be added to this drainage area as a BMP to reduce total recoverable iron in the storm water effluent. The placement of this additional BMP will be completed by 06/08/2012.

If you have any questions or need additional information please contact Brad Love of Sequoyah's Environmental staff by phone at (423) 843-6714 or by e-mail bmlove@tva.gov.

I certify under penalty of law that this document and all attachments were preparedunder my direction or supervision in accordance with a system designed to assure that qualified personnel properly gatherand evaluate the information submitted. Based on my inquiryof the person or persons who manage the system, or those persons directly responsible for gatheringthe information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significantpenalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

ln President Sequoyah Nuclear Plant Enclosures cc (Enclosures):

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

12065 Lebanon Rd.

Mt. Juliet, TN 37122

• ESC L-A'B 5"C-I.E.NC.E.S (615) 758-5858 1-800-767-5859 Fax (615) 758-5859 Tax I.D. 62-0814289 Est. 1970 REPORT OF ANALYSIS Brad Love February 10,2012 TVA-Sequoyah Nuclear Plant P.O.Box 2000 Soddy-Daisy, TN 37384 ESC Sample # : L559697-02 Date Received 02/09/12 09:00 Description Anual Storm Water NPDES Samples Site ID Sample ID SW 2 Project #

Collected By Chris Randolph Collection Date 01/17/12 11:40

,Parameter Result Det. Limit Units Method Prep PID Analyzed AID Iron 9.0 0.10 mg/l 200.7 02/09/12 1823 528 02/b9/12 2325 WC BDL - Below Detection Limit Det. Limit - Practical Quantitation Limit(PQL)

Laboratory Certification Numbers:

AIHA - 09227, AL - 40660, CA - 1-2327, CT- PH-0197, FL - E87487, GA - 923, IN - C-TN-01 KY - 90010, NC - ENV375,DW21704, ND - R-140, SC - 84004, TN - 2006, VA - 00109, WV - 233 AZ -0612, MN - 047-999-395, NY - 11742, NJ - TNO02, WI - 998093910 Notes:

The reported analytical results relate only to the sample submitted This report shall not be reproduced, except in full, without the written approval from ESC.

Reported: 02/10/12 14:56 Printed: 02/10/12 14:57 Page 3 of 10

12065 Lebanon Rd.

OESC Mt. Juliet, TN 37122 (615) 758-5858 1-800-767-5859 Fax (615) 758-5859 LA.B S.C-I*E-N-CE-S Tax I.D. 62-0814289 Est. 1970 REPORT OF ANALYSIS Lynne Koby February 13,2012 TVA-Sequoyah Nuclear Plant P.O.Bpx 2000 Soddy-Daisy, TN 37384 ESC Sample # : L559819-10 Date Received

• 02/09/12 09:00 Description  : Annual Storm Water NPDES Samples Site ID Sample ID  : SW 15 Project #

Collected By  : Chris Randolph Collection Date : 01/17/12 12:37 Parameter Result Det. Limit Units Method Prep PID Analyzed AID Iron 25. 0.10 mg/l 200.7 02/10/12 1415 542 02/11/12 1835 WC BDL - Below Detection Limit Det. Limit - Practical Quantitation Limit(PQL)

Laboratory Certification Numbers:

AIHA - 09227, AL - 40660, CA 2327, CT- PH-0197, FL - E87487, GA - 923, IN - C-TN-01 KY - 90010, NC - ENV375,DW21704, ND - R-140, SC - 84004, TN - 2006, VA - 00109, WV - 233 AZ -0612, MN - 047-999-395, NY - 11742, NJ - TNO02, WI - 998093910 Notes:

The reported analytical results relate only to the sample submitted This report shall not be reproduced, except in full, without the written approval from ESC.

Reported: 02/13/12 15:34 Printed: 02/13/12 15:45 Page 11 of 11