ML19353B053

Discusses NPDES Polychlorinated Biphenyls (Pcb) Cleanup Plan.Status of Reclamation Efforts for Low Vol Waste Treatment Pond Provided.Pcb Sampling Grid Analytical Results Encl

ML19353B053
Person / Time
Site:	Sequoyah
Issue date:	11/20/1989
From:	Schmierbach M TENNESSEE VALLEY AUTHORITY
To:	Stryker R ENVIRONMENTAL PROTECTION AGENCY
References
NUDOCS 8912110119
Download: ML19353B053 (6)

Text

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TENNESSEE VALLEY AUTHORITY SPB 25 201P

• Knoxville, Tennessee 37902 q

IWV 2 01989 l

t Mr. Robert Stryker United States Environme ital ,

Protection Agency Region IV loxics Section ,

345 Courtland Strer c

. Atlanta, Georgia 30365 ,;

Dear Mr. Stryker:

1ENNESSEE VALLEY AU1HORilY (lVA) - SEQUOYAH NUCLEAR PLANT (SQN) -

. NATIONAL POLLUTAN1 OlSCllARGE ELIMINA110N SYSlEM (NPDES) PERMil NO. TN0026450 -POLYCHLORINATED BIPHENYLS (PCB) CLEANUP PLAN J The; purpose of this letter is to provide the status of TVA's reclamation  !

efforts for the SQN low volume waste treatment pond (LVWlP). Also, this letter will. serve to document the results of a November 2 telephone conversation between Abraham H. Loudermilk, Jr., Jim G. Mantooth (both with TVA), and you concerning TVA's technical proposal for cleanup of the. ]

LVWTP.

In an August 11 meeting, documented by an August 24 letter to you, EPA and TVA agreed upon a statistical sampling plan for quantifying PCB concentrations'in the LVWlP sediments. A PCB cleanup criteria.of 25 milligrams per liter (mg/1) or less for the pond sediments was also agreed upon. Enclosure 1 is a topographic drawing of the pond with an overlay which illustrates the physical location of the individual sample E

points. A September 12 letter f rom Richard D. Stonebraker, EPA, l

recommended that rather than composite the top two inches of a core from L- each of the sampling points into three area samples as originally. agreed upon, the 2-inch increments should be analyzed individually. Enclosure 2 i is a table of the analytical results for the top two inches of sediment from each sample point. As shown in the table, only one sample point, PCB-10, exhibited a PCB concentration greater than the 25 mg/l cleanup

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criteria.

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' DR ADOCK0500g7 I \

An Equal Oppm tunity Employer I

Mr. Robert Stryker NOV 201989 The remaining eight inches of the 10-inch core sample taken at PCB-10 was '

then divided into f our, 2-inch increments and analyzed for PCB concen-trations. Enclosure 3 is a table of the analytical results. As shown, the PCB concentrations below the top two inches of the PCB-10 core sample were less than the 25 mg/l cleanup criteria. Migration of PCB through the soil column was restricted, at least in part, by the clay content of the pond's bottom. Soil samples from the randomly selected points of PCB-3,7,10 and 17 show that the pond's bottom consists of an inorganic clay with medium-to-high plasticity and a clay content ranging from 38%

to 71% (average of 50%). Therefore, it is reasonable to assume that the migration of PCB through the soil column at the other sample locations within the pond 1s similarly limited.

To further define the potential cleanup area, additional samples consisting of the top two inches of sediment were collected around the imediate area of PCB-10 and analyzed for PCB concentrations. Enclosure 4 is a table of the analytical results while the overlay of Enclosure 1 shows the area of the pond's bottom which must be removed to comply with the 25 mg/l cleanup triteria. The resulting volume of soil to be removed '

for disposal is approximately 108 cubic yards.

In summary, EPA and TVA agreed in the November 2 telephone conference ,

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that TVA will remove the top two inches of soil within the approximate boundaries shown by the dashed line on the overlay of Enclosure 1. This soil will-be transported to Chemical Waste Management, Inc., hazardous waste landfill located at Emelle, Alabama, for disposal. TVA will continue to dewater the LVWIP under the stipulations of the agreement L reached between the lennessee Division of Water Pollution Control (lDWPC) and TVA as identified in the December 2, 1988 meeting at the 1DWPC l'

Chattanooga field office, the January 4, 1989 confirmation letter to Philip L. Stewart, and the May 1, 1989 project status report to Ann McGregor. In addition, it was agreed that any water which could not be i

l l pumped from the pond due to the potential for exceeding the total ,

l suspended solids limitation of the NPDES permit (approximately 100,000 l

gallons) could be solidified and mixed with the soil of the pond's bottom l

af ter cleanup. A pond liner will be installed prior to returning the LVW1P to service to reduce the potential for leaching of any remaining ,

l 1- PCB into the pond's contents after it is returned to service. Design I plans and specifications for the liner will be submitted to the 1DWPC for review and approval prior to installation. TVA is presently pursuing a L " turn-key" type contract to complete reclamation of the SQN LVWTP.

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1. l10V 201989 Mr. Robert Stryker

' If you have-any questions or require any additional in information, Knoxville, please call Abraham 11. Loudermilk, Jr. , at (615) 632-6656 Tennessee.  :

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Sincerely, Jo o tkf d M. Paul $chmierbach, Manager Environmental Quality Enclosures cc (Enclosures):'

Ms. Nancy Redgate United States Environmental Protection Agency .

Region IV Toxics Section 345 Courtland Street Atlanta, Georgia 30365 Mr. Philip L. Stewart, Manager Chattanooga Field Office Division of Water Pollution Control Tennessee Department of Ilealth and Environment 2501 Milne Street Chattanooga, Tennessee 37406-3399

'U.S._ Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

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j ENCLOSURE 2 PCB SAMPLING GRID l ANALY11 CAL RESUL1S LOW VOLUME WAS1E 1REA1 MENT POND SEQUOYAll NUCLEAR PLAN 1 Sample Point PCB Conc.. ppm ,

PCB-18 1.2 PCB-2 0.39 PCB-3 3.98 PCB-4 A 1.74 PCB-5 7.43 PCB-6 No Sample PCB-7 2.26 i 0.18  :

PCB-B PCB-9 <0.1 PCB-10 69.97 PCB-11 9.0 PCB-12 15.1 PCB 10.27 PCB-14 1.34 PCB-15 12.38 PCB-16 9.43 '

PCB-17 2.66 PCB-18 0.58 PCB-19 No Sample Note: 1. PCB sample points 1 and 4 orginally fell on top of the pond's dike and were relocated.to within the pond's interior.

Consequently these points were renumbered as 18 and 4A.

2. Sample point 1B fell so close to sample point 6 that PCB-6 was not sampled.

3. Sample point 19 fell on top of the pond's dike and was not relocated. Theref ore, PCB-19 was not sampled.

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ENCLOSURE 3-I SEQUOYAll NUCLEAR PLAN 1 LOW VOLUME WAS1E 1REA1 MEN 1 POND

.PCB CONCENTRATIONS FOR PCB-10 CORE SAMPLE j

IN TWO-INCH INCREMEN1S PCB Sample j Increment Conc. ppm PCB-10, 2-inch depth 69.97 l l

<0.10 j.

PCB-10, 4-inch depth i PCB-10, 6-inch depth 1.30 l

PCB-10, 8-inch depth <0.10 -

PCB-10,10-inch depth <0.10 i

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- ENCLOSURE 4 j, .

SEQUOYAll NUCLEAR PLAN 1 LOW VOLUME WAS1E 1REAlMEN1 POND PCB CONCENTRA110NS IN 1WO-INCll SEDIMENT SAMPLES IMMEDIA1LLY SURROUNDING PCB-10 Sample Point PCB Conc., ppLn 15 A 20 33 A 91 81 A 39 15 8 52 33 8.-

110 81 B 9.8 .

'15 C 16 5

33 C 81 C 120 15 0 2.5 33 D 4.5 4

15 E 37 33 E 100 81 E 24 15 F 74 .

33 F 4*I  !

81 F 0.91 1

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