ML12157A246
| ML12157A246 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/23/2012 |
| From: | Entergy Operations |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GNRO-2012/00039, CR-GGN-2006-02714 | |
| Download: ML12157A246 (10) | |
Text
Attachment 22 to GNRO-2012/00039 Attachment 22 to GNRO-2012/00039 ER Reference - Entergy 2010e (NPDES CRs)
Entergy Operations, Inc. Condition Report Detail Page 15 of 126 May 30, 2010 3:09 PM Reportability: KNOT REPORTABLE
.CR-GGN-2006-02714 Significance: D Operability: NOT REQUIRED CR Status: Closed on July 11, 2006 Classification: ACTIONS TAKEN Date Discovered: 07/10/2006 Condition Summary:
On July 6, 2006 at 09:00 pH for Outfall 016 measured 9.23. This exceeded the NPDES permit limitation of 9.00. This reading was taken by the GGNS contract laboratory [Argus Analytical] field technician and the number was reported to the permittee on July 10, 2006. A subsequent pH measurement taken July 10, 2006 at 09:49 revealed a pH of 8.89. An investigation of the cause of this event was performed on July 10, 2006. No change to processes or programs that influence this outfall were identified. The contract manager was contacted regarding management of the HVAC unit that discharges to this outfall. No changes to the HVAC chemical treatment or chemical usage was identified. Based upon this investigation and subsequent pH measurement, no apparent cause was identified for this pH exceedance. A courtesy notification was made to the Mississippi Department of Environmental Quality [MDEQ] on July 10, 2006. A non-compliance report will be included with the Discharge Monitoring Reports [DMRs] submitted to MDEQ July 28, 2006. GGNS licensing department was notified of this event and determined no NRC reportability is required.
Responsible Dept: Tech Chemistry Mgmt Originated: 07/10/2006 by Shaw,Rusty, Tech Chemistry Support Staff Affected Systems: Affected Equipment:
Remarks:
Contact:
Closing
Description:
Assignment Version: 1 Performed: 07/11/2006 by Swords,Gary D Significance Code: D
Description:
Assigned To: Tech Chemistry Mgmt Classification Code: ACTIONS TAKEN Reportability Version: 1 Report Number: Reportability Code: NOT REPORTABLE Reportability
Description:
Performed: 07/10/2006 by Abraham,William B Not reportable - This event does not meet the screening criteria of PAP 01-S-06-5, Aft Ill.
Discussed this issue with the originator of CR. He advised GGNS licensing department was notified of this event and determined no NRC reportability is required. Reviewed Operability Statement.
Operability Version: 1 Operability Code: NOT REQUIRED Immediate Reportability Code: NOT REPORTABLE Operability
Description:
Performed: 07/10/2006 by LiddelIRicky M This CR documents an NPDES issue. A courtesy notification was made to the Mississippi Department of Environmental Quality [MDEQ] on July 10, 2006. A non-compliance report wil be included with the Discharge Monitoring Reports [DMRs] submitted to MDEQ July 28, 2006. This condition does not impact any TS/TRM or safety related equipment or requirements and is not immediately reportable per 01-S-06-5.
Operability Approved: 07/10/2006 by Mathes,Ernest W Approval Descriptior
Page 20 of 126 Entergy Operations,Inc. Condition Report Detail May 30, 2010 3:09 PM Reportability: :NOT REPORTABLE
- CR-GGN-2006-03875 Significance: D Operability: NOT REQUIRED CR Status: Closed on October 09, 2006 Classification: ACTIONS TAKEN Date Discovered: 10/05/2006 Condition Summary:
At 09:00 the pH measured at outfall 014 [outlet of sedimentation basin B / south basin] was 9.17. This exceeds the NPDES Permit MS 0029521 page 17 of 33 limitation of 6.5 - 9.0. Cau.w is believed due to heavy algae growth [C02 removal], natural process. See attachment for more information.
Responsible Dept: Tech Chemistry Mgmt Originated: 10/05/2006 by Lassetter Jr,John M, Tech Chemistry Mgmt Affected Systems: Affected Equipment:
Remarks:
Reference Type I Description Reference.Type I Description Reference Type I Description SCREEN NOT SAFETY EQ : closed CA&A
Contact:
Closing
Description:
Assignment Version: 1 Performed: 10/09/2006 by Swords,Gary D Significance Code: D
==
Description:==
Assigned To: Tech Chemistry Mgmt Classification Code: ACTIONS TAKEN Reportability Version: 1 Report Number: Reportability Code: NOT REPORTABLE Reportability
Description:
Performed: 10/05/2006 by Jackson,Rita R Not reportable - This event does not meet the screening criteria of PAP 01-S-06-5, Att Ill.
Per NUREG 1022, Licensees generally do not have to report media and government interactions unless they are related to the radiological health and safety of the public or onsite personnel, or protection of the environment. For example, the NRC does not generally need to be informed under this criterion of:
? minor deviations from sewage or chlorine effluent limits
? minor non-radioactive, onsite chemical spills
? minor oil spills
? problems with plant stack or water tower aviation lighting
? peaceful demonstrations
? routine reports of effluent releases to other agencies
? releases of water from dams associated with the plant This was a minor deviation from effluent and does not appear to meet reporting criteria See section 3.2.12 News Release or Notification of Other Government Agency for details.
Operability Version: 1 Operability Code: NOT REQUIRED Immediate Reportability Code: NOT REPORTABLE
Page 22 of 126 Entergy Operations,Inc. Condition Report Detail May 30, 2010 3:09 PM Reportability: NOT REPORTABLE CR-GGN-2006-03931 Significance: C Operability: NOT REQUIRED CR Status: Closed on March 23, 2007 Classification: NON-SIGNIFICANT Date Discovered: 10/10/2006 Condition Summary:
14:00 Oct. 10, 2006: During routine data review, determined that on Oct. 6, 2006 at 13:44, during the PSW sodium hypochlorite injection, an NPDES permit requirement to sample Outfa 001 [Discharge to River] at an interval not to exceed 30 minutes was not met. The sample was collected at a 45 minute interval. No detectable chlorine concentrations were measured at Outfall 001during the injection.
This requirement is implemented in procedure 08-S-04-499 Step 6.2.28 a.
Initial investigation:
During task performance, the plant computer [PDS] is used to monitor 1P44N035, PSW Chlorine Monitor for residual chlorine concentration in plant piping to verify that target chlorine concentration is met.
The computer point stopped updating during the injection and the analyst went into the power block to collect and analyze a grab sample to determine residual concentrations. When analyst returned to the Outfall 001 sample point, the 30 minute sample interval had been exceeded.
Reportability:
Per NPDES permit Part II A. 3 a. this noncompliance should be reported verbally to the Ms Dept. of Env. Quality within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the time the permittee becomes aware of the circumstances [due < 1400 10/11/06]. A follow-up written report is required within 5 days [ due 14:00 10/15/2006].
Based on review of NUREG 1022 Section 3.2.12 and discussion with plant staff licensing, this non-compliance does not require additional notifications.
Responsible Dept: Tech Chemistry Mgmt Originated: 10/10/2006 by Lassetter Jr,John M, Tech Chemistry Mgmt Affected Systems: Affected Equipment:
Remarks:
Contact:
Closing
Description:
Assignment Version: 1 Performed: 10/11/2006 by Hickman,James E Significance Code: C
==
Description:==
Assigned To: Tech Chemistry Mgmt Classification Code: NON-SIGNIFICANT H IvI 2 Reportability Version: 1 Report Number: Reportability Code: NOT REPORTABLE Reportability
Description:
Performed: 10/1112006 by Larson, Michael J
Page 31 31 of of 126 Entergy Operations,Inc. Condition Report Detail May PM May 30, 2010 3:09 PM Reportability: NOT REPORTABLE CR-GGN-2007-00851 Significance: C Operability: NOT REQUIRED CR Status: Closed on March 26, 2007 Classification: NON-SIGNIFICANT Date Discovered: 03/01/2007 Condition Summary:
Reference CR GGN 2007-0835. On 2/28/2007 approx. 2500 gallons of a water/oil/ AFFF mixture was recovered from oil water separator / piping in from of the Vehicle Maintenance shor Heavy rains on the morning of 3/1/07 flushed residual AFFF [Cat ID 81064024, 81064023] from the oil water separator and piping into the site storm drain system and into a creek on the North side of the plant property. This creek drains under the north access road into the North sedimentation basin to NPDES Outfall 013 and eventually to Gin Lake. The turbulence in thi storm drain system resulted in persistent foaming in greater that trace amounts. This constitutes a NPDES permit exceedance. At 12:07 3/1/2007 Ms Dept of Env Quality Personnel were notified via a voice mail. The voice mail fulfills the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> NPDES requirements NPDES Permit Part IIA.3.a). The material is 100% water soluble so mitigation options are limited. The primary concern for the material is the potential to deplete oxygen in the receiving waters which could impact aquatic life in a negative fashion.
Responsible Dept: Tech Chemistry Mgmt Originated:
Affected Systems: Affected Equipment:
Remarks:
Contact:
Closing
Description:
Assignment Version: 1 Performed: 03/05/2007 by Courtney,Richard A Significance Code: C
==
Description:==
Assigned To: Tech Chemistry Mgmt Classification Code: NON-SIGNIFICANT Reportability Version: 1 Report Number: Reportability Code: NOT REPORTABLE Reportability
Description:
Performed: 03/01/2007 by Larson,Michael J
Page 49 of 126 Entergy Operations,Inc. Condition Report Detail May 30, 2010 3:09 PM CR-GGN-2008-00233 Significance: C Reportability: NOT REPORTABLE Operability: CR Status: Closed on February 05, 2008 Classification: CORRECT/ADDRESS Date Discovered: 01/15/2008 Condition Summary:
NPDES permit exceedance: Outfall 010 [sewage plant effluent] pH measured at 6.34 at 08:35 on 1/15/2008 by Contract personnel. NPDES permit limitation is 6.5 - 9.0.
09:00 - 09:30 Plant staff Chemistry performed additional measurements at various locations in the sewage plant effluent mixing trough and determined that the suppressed pH resulted from a bi-product associated with addition of the dechlorination chemical [sodium bisulfite]. Depending on the time and location of the Outfall 010 sample relative to the sodium bisulfite addition point, the pH may be suppressed.
Responsible Dept: Tech Chemistry Mgmt Originated: 01/15/2008 by Lassetter Jr,John M, Tech Chemistry Mgmt Affected Systems: Affected Equipment:
Remarks:
Reference Type Description Reference Type I Description Reference Type I Description OPS BYPASS OVERSIGHT CA&A
Contact:
Closing
Description:
Assignment Version: 1 Performed: 01/17/2008 by Swords,Gary D Significance Code: C
Description:
Assigned To: Tech Chemistry Mgmt Classification Code: CORRECT/ADDRESS operability discussed with OPS Reportability Version: 1 Report Number: Reportability Code: NOT REPORTABLE Reportability
Description:
Performed: 01/16/2008 by Owens Jr,James E Not reportable - This event does not meet the screening criteria of PAP 01-S-06-5, Att Ill. Refer to the immediate actions.
Trend rCndh I Tr~nIrlp Tlenp Trandl rndp I Trand rntip Tynp CYMG : AD P : HEPFACTOR 1 : REPORT WEIGHT KW-EFFLUENT : KEYWORDS NOT APPLICABLE : INPO BINNING Corrective Actions
Page 58 of 126 Entergy Operations,Inc. Condition Report Detail May 30, 2010 3:09 PM Reportability:
CR-GGN-2008-02187 Significance: C NOT REPORTABLE Operability: CR Status: Closed on May 14, 2008 Classification: CORRECT/ADDRESS Date Discovered: 05/05/2008 Condition Summary:
March 2008 Discharge Monitoring Reports [DMRs] were not postmarked by Apr 28 as required by NPDES permit page 21 of 33, Part I.D.2.a. The reports were routed for signature on April 19 but individual did not follow through to ensure package was signed / mailed.
Responsible Dept: Tech Chemistry Mgmt Originated: 05/05/2008 by Lassetter Jr,John M, Tech Chemistry Mgmt Affected Systems: Affected Equipment:
Remarks:
Reference Type j Description Reference Type I Description Reference Type I Description MISC : ADMIN issue - no MF CA&A
Contact:
Closing
Description:
Assignment Version: 1 Performed: 05/08/2008 by Jones,Milton L Significance Code: C
Description:
Assigned To: Tech Chemistry Mgmt Classification Code: CORRECT/ADDRESS Reportability Version: 1 Report Number: Reportability Code: NOT REPORTABLE Reportability
Description:
Performed: 05/05/2008 by Larson,Michael J Not reportable - This event does not meet the screening criteria of PAP 01-S-06-5, Att Ill.
Trnnrl Cn.ndr I Trend CnrId Tynp Trnrl rnrl'n I Trpnrl (rnrig Tunp CYMG : WW H : HEP FACTOR CYMG : HU U-LAPSE 1 : REPORT WEIGHT KW-ENVIRONMENTAL MONITORING : KEYWORDS CY1 : INPO BINNING Corrective Actions Corrective Action # I Type: DISP - CA
- The CRG has classified this CR Category C (Corrective Action) and assigned to the responsible department to correct the identified condition per EN LI-102 Category C - Corrective
.Action. Perform disposition review and ensure actions are assigned as applicable to correct the problem. If disposition review determines the problem is broader or more severe than initially assigned, present the information to the CRG for review and potential re-categorization. A Root Cause, Apparent Cause Evaluation / Equipment Failure Evaluation is not
Page 63 of 126 Entergy Operations,Inc. Condition Report Detail May 30, 2010 3:09 PM Reportability: NOT REPORTABLE CR-GGN-2008-03929 Significance: C Operability: CR Status: Closed on September 30, 2008 Classification: CORRECT/ADDRESS Date Discovered: 08/07/2008 Condition Summary:
A sample analysis for July 24, 2008 has been received from Argus Laboratory indicating a 1.39 mg/I Zinc concentration in Outfall 002; at this point it is considered a potential exceedencE of the daily maximum requirement of 1.0 mg/I. There are two sample requirements per month for this parameter at Outfall 002. The first sample for July 10, 2008 was analyzed and carr back 0.539 mg/I and below the permit requirement. If the July 24th sample is confirmed as indicated the monthly average for this parameter will still be within compliance with the NPDE; permit requirements. The possible reason for this is the flush of the natural draft cooling tower on July 22, 2008; resulting in additional zinc in the effluent.
Responsible Dept: Chemistry Mgmt GGN Originated: 08/07/2008 by Shepphard,Charles, Chemistry Staff GGN Affected Systems: Affected Equipment:
Remarks:
Reference Type I Description Reference Type I Description Reference Type I Description MISC : Chemistry issue - mc CA&A
Contact:
Closing
Description:
Assignment Version: 1 Performed: 08/11/2008 by Lee,George H Significance Code: C
==
Description:==
Assigned To: Chemistry Mgmt GGN Classification Code: CORRECT/ADDRESS Reportability Version: 1 Report Number: Reportability Code: NOT REPORTABLE Reportability
Description:
Performed: 08/11/2008 by Larson,Michael J NOT REPORTABLE - This event does not meet the screening criteria of PAP 01-S-06-5, Aft Ill.
Based on discussions with Chemistry personnel, the condition noted is a MINOR deviation similar to the example given such as exceeding sewage or chlorine effluent limits.
As stated in NUREG 1022, Licensees generally do not have to report media and government interactions unless they are related to the radiological health and safety of the public or onsite personnel, or protection of the environment. The purpose of this criterion is to ensure the NRC is made aware of issues that will cause heightened public or government concern related to the radiological health and safety of the public or on-site personnel or protection of the environment. The NUREG further states: clarifications are intended to set a reporting threshold that ensures necessary reporting, while minimizing unnecessary reporting.
Zinc levels are such that impact on the Environment is minimal and of a minor nature - no press releases are planned or anticipated for this release - therefore not reportable.
REFERENCES:
NUREG 1022 - PAGE 72, 01-S-06-5, REAP.
Trpnd rnrip I Trpnd rndp Tynp ~Tr~ndrI Tr~~d(~eI0 Tr~nrIC~nd~ ndi I Trpnd rnrip Tuna~
Page 72 of 126 Entergy Operations,Inc. Condition Report Detail May 30, 2010 3:09 PM CR-GGN-2008-04197 Significance: C Reportability: NOT REPORTABLE Operability: NOT REQUIRED CR Status: Closed on August 28, 2008 Classification: CORRECT/ADDRESS Date Discovered: 08/21/2008 Condition Summary:
At 0910 8/21/08, Contract lab personnel notified GG plant staff that free residual chlorine [FRC] measured at NPDES Outfall 010 [Sewage Plant Effluent] was 1.18 mg/L. This exceeds th daily maximum limitation of 0.5 mg/L listed in the NPDES permit page 13.
NOTE: Chlorine is added to the sewage plant effluent to control bacteria. A de-chlorinating chemical [sodium bisulfite] is added to neutralize any residual chlorine prior to the sewage plant effluent discharge to sedimentation basin A [north basin].
GG Plant staff immediately requested lab personnel to resample and dispatched the sewage plant operator to verify sodium bisulfite [de-chlorination chemical] feed. Sewage plant operator found a fouled sensor which affected [reduced] the rate of de-chlorination chemical addition.
Sewage plant operator cleaned the probe. This action immediately increased the de-chlorination chemical addition rate; Resample of Outfall 010, at 0950 8/21/08, indicated FRC was non-detectable, within specification at < 0.1 mg/L.
No negative effects on biota in Basin A were noted.
Cause of the upset:
Sewage Plant operations on 8/20/08 included cleaning the clarifier portion of the plant. This activity is associated with an infrequent maintenance activity on a sludge return line. ClarifiE cleaning increases the amount of solids present in the contact chamber. Increased solids can gradually create a film on the de-chlorination sensor. The film can reduce probe sensitivity and reduce the de-chlorination chemical addition rate.
Based on the magnitude and duration of the non-compliance this is considered a minor deviation in chlorine concentration that does not represent a threat to public health or the environment. It does represent a non-compliance with the NPDES permit and has been reported to the Ms Dept of Env Quality in accordance with permit conditions. No additional reportability is required. EN-OM-128 Att.. 9.1 requires Duty Manger notification for not Responsible Dept: Chemistry Mgmt GGN Originated: 08/21/2008 by Lassetter Jr,John M, Chemistry Mgmt GGN Affected Systems: Affected Equipment:
Remarks:
Reference Type I Description Reference Type I Description Reference Type I Description MISC Conditions do not we CA&A
Contact:
Closing
Description:
Assignment Version: 1 Performed: 08/25/2008 by Lee,George H Significance Code: C
==
Description:==
Assigned To: Chemistry Mgmt GGN Classification Code: CORRECT/ADDRESS
Page 115 of 126 Entergy Operations,Inc. Condition Report Detail May 30, 2010 3:09 PM Reportability: NOT REPORTABLE CR-GGN-2010-00497 Significance: C Operability: CR Status: Open Classification: CORRECT/ADDRESS Date Discovered: 01/25/2010 Condition Summary:
GGNS National Pollutant Discharge Elimination System (NPDES) permit requires Outfall 016 be sampled twice per quarter. Outfall 016 receives ESC HVAC samples are obtained by ar outside vendor. Chemistry manages the vendor contract. On 1/25/2009 at 1449 it was determined that the vendor only completed one of two samples required during each of the third and fourth quarters on 2009. All other samples obtain during 2009 period were within compliance for this outfall as well as for the site pertaining to the NPDES permit.
Responsible Dept: Chemistry Mgmt GGN Originated: 01/25/2010 by Shepphard Sr,Charles K., Chemistry Staff GGN Affected Systems: Affected Equipment:
Remarks:
Reference Type I Description Reference Type I Description Reference Type I Description MISC : This CR does not wa CA&A
Contact:
Closing
Description:
Assignment Version: 1 Performed: 01/28/2010 by Jones,Michael D Significance Code: C
==
Description:==
Assigned To: Chemistry Mgmt GGN Classification Code: CORRECT/ADDRESS HPER Level 2 Reportability Version: 1 Report Number: Reportability Code: NOT REPORTABLE Reportability
Description:
Performed: 02/01/2010 by Jackson,Rita R Not reportable - Discussed with environmental personnel and reviewed NUREG-1022.
10CFRSO.72(b)(2)(xi) says, "Any event or situation, related to the health and safety of the public or on-site personnel, or protection of the environment, for which a news release is planned or notification to other government agencies has been or will be made. Such an event may include an on-site fatality or inadvertent release of radioactively contaminated materials." Per NUREG 1022, section 3.2.12, News Release or Notification of Other Government Agency, discusses that the purpose of the reporting requirement of 50.72(b)(2)(xi) is to "ensure the NRC is made aware of issues that will cause heightened public or government concern related to the radiological health and safety of the public or on-site personnel or protection of the environment." This event involved missed samples and NOT an unusual or abnormal release of radioactive effluents. Licensees generally do not have to report media and government interactions unless they are related to the radiological health and safety of the public or onsite personnel, or protection of the environment. Per NUREG 1022, if the event is routine and has little significance, an ENS notification is not needed.
The routine requirements for the missed NPDES samples for Outfall 016 were flow, ph and chlorine, all non-radiological parameters . Based on the fact that GGNS collected six of 8 required samples and noted that all other samples obtain during 2009 period were complete and within compliance for this outfall, as well as for the site pertaining to the NPDES permit.
Other than communication with the Department of Environmental Quality to let them know about the missed samples, no other reports are planned or required. Chemistry will state the reason for missing the two results of the two quarters and any measures taken in the comment space at the bottom of the DMR Form. This event is routine in nature and has little significance.