ML13084A324

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

ML13084A324
Person / Time
Site:	Sequoyah
Issue date:	03/20/2013
From:	John Carlin Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation, State of TN, Dept of Environment & Conservation, Div of Water Pollution Control
References
Download: ML13084A324 (4)

Text

Tennessee Valley Authority, Post Office Box 2000, Soddy Daisy. Tennessee 37384-2000 March 20, 2013 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 Number 3, 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 11, 2013. The storm water analytical monitoring results were received on February 25, 2013. The analytical monitoring results for Storm Water Outfall Number 3 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 qualifying event resulted from a four hour rainfall on the morning of January 11, 2013. The analytical results can be seen tabulated below.

Table 1. Storm Water Annual Iron Exceedance Values Storm Water Sample Backup Analytical Averaged Benchmark Outfall Sample Analysis Sample Results Results Monitoring Number Date Received Analysis (mg/L) (mgRL) Requirement Date Received (mg/L) 3 1/11/2013 2/25/2013 03/05/2013 8.4; 6.7 8 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.

Likely Cause of the Exceedance The likely cause of the exceedance of the benchmark monitoring requirement for total recoverable iron is elevated iron concentration in the native soil around the storm water outfall and the presence of exposed steel which had been temporarily staged in the area.

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 Number 3. A brief summary of the proposed modifications, including a timetable for implementation follows.

Storm Water Number 3 Per the SQN SWPPP, ground cover consists of crushed stone, gravel, and grass. Drainage ditches are equipped with rip rap and filter socks as best management practices.

The exposed steel and temporary material storage near storm water oufall number 3 will be removed by 3/30/2013.

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 underpenalty of law that this document and all attachments were prepared under my direction or supervision in accordancewith 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 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.

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in it 1111L e 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.AB S-C-i-E.N.C 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 25,2013 TVA-Sequoyah Nuclear Plant P.O.Box 2000 Soddy-Daisy, TN 37384 ESC Sample # : L621136-03 Date Received 02/20/13 09:00 Description Annual Storm Water NPDES Samples Site ID Sample ID SW 3 Project #

Collected By ZH/PB Collection Date 01/11/13 09:30 Parameter Result Det. Limit Units Method Prep PID Analyzed AID Iron 8.4 0.10 mg/l 200.7 02/21/13 1731 388 02/22/13 2301 ST 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, NMD - 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: 02/25/13 08:31 Printed: 02/25/13 08:31 Page 4 of 7

12065 Lebanon Rd.

• OESC Mt. Juliet, TN 37122 (615) 758-5858 1-800-767-5859 Fax (615) 758-5859 L*A-B S C-I-E N'C'E-S Tax I.D. 62-0814289 Est. 1970 REPORT OF ANALYSIS Brad Love March 05,2013 TVA-Sequoyah Nuclear Plant P.O.Box 2000 Soddy-Daisy, TN 37384 ESC Sample # : L622673-01 Date Received 03/01/13 09:00 Description Annual Storm Water NPDES Samples Site ID Sample ID SW 3 BACK UP Project #

Collected By zH/PB Collection Date 01/11/13 09:30 Parameter Result Det. Limit Units Method Prep PID Analyzed AID Iron 6.7 0.10 mg/l 200.7 03/04/13 1850 580 03./05/13 1230 ALT 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: 03/05/13 16:08 Printed: 03/05/13 16:26 Page 2 of 3