ML20071E390
| ML20071E390 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/03/1983 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 3F-0383-09, 3F-383-9, NUDOCS 8303100200 | |
| Download: ML20071E390 (11) | |
Text
'
e f%.
e NW h k&@f$Q k
%L.* te_
t'
- {f?k??
e
%dfec M
Power C O R P O m a v e c es March 3,1983 3F-0353-09 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Environmental Reports
Dear Mr. Denton:
Pursuant to Crystal River Unit 3 Technical Specifications, Appendix B - Part II, Section 3.2, attached is a copy of the Florida Power Corporation (FPC) response to a show cause order from the Environmental Protection Agency (EPA). The show cause order is a result of FPC notifying EPA of violations of NPDES Permit FL0000159 following recent ordered changes to the permit by EPA.
Should you have any further questions concerning this matter, please contact this office.
Sincerely, k
W G. R. Westafer Manager Nuclear Licensing and Fuel Management DVH:mm cc:
Mr. 3. P. O'Reilly, Regional Administrator Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Stree: N.W., Suite 2900 Atlanta, GA 30303 fo $-
o R303100200 830303 PDR ADOCK 05000302 S
PDR General Office 32o1 TNrty founn street souin. P O Box 14042, St Petersburg. Florda 33733 e 813-866-5151
bees N. B. Sp:ka J. A. Hancock G. C. Moora H. A. Evertz G. R. Westafer 3,,3 copy,gr<
D. A. Shantz G. A. Becker g
B. J. Hickle R. E. Parnelle e
g{
CERTFIED/ RETURN RECEIPT REQUESTED C On P0 m at ic a February 28, 1983 1
Mr. Gilbert W. Wallace, Chief Industrial Operations Section Facilities Performance Branch Water Management Division U. S. Environmental Protection Agency 345 Courtland Street Atlanta, Georgia 30365
Subject:
Crystal River Units 1, 2, & 3 NPDEG Permit No. FL0000159 Administrative Order No. 83-17 (wCAB)
Dear Mr. Wallace:
In response to your letter of February 4, 1983, we submit the following information for your consideration at the meeting scheduled for March 8, 1983, in Atlanta.
On January 21, 1983, we reported to EPA that on January 10, 1983, the discharge from outfall 007, Regeneration Waste neutralization Tank (SDT-1), exceeded the 20 mg/l daily limit for oil and grease. In the report we indicated that a thorough assessment of this incident had taken place to determine the cause and to develop means to avoid simi-lar future discharges and that it was concluded that no equipment mal-function or operational action could be identified that contributed to the high oil and grease discharge. We indicated that we suspected either a contaminated sample or analytical error.
Subsequent review has not uncovered any new information, i.e., we still believe that a measurement error occurred instead of in actual discharge of oil and grease above the prescribed limit. as was discussed with representa-tives of EPA during their inspection of the Crystal River 1, 2, and 3 facilities on February 8,1983, the laboratory procedure associated j
with the determination of oil and grease is easily subject to gross 4
error.
It was further explained that sampling and laboratory proce-dures have been changed to require splitting of the sample in case a backup analysis is necessary to confirm a suspected value.
Another possible explanation is that a spurious source of emulsified 7
J oil was present in the discharge. The oil / water separator system is designed to remove oil based upon the fact that oil floats on water, i
Emulsified oil does not behave in that manner and would consequently I
pass through the oil / water separator system. We do experience emulsi-fled oil and grease in other waste streams but we do not believe they are present in any quantity in this stream.
General Office 3201 Thefty fourtn Street South e P O Box 14042. St Petersburg. Fiorda 33733 e 813-866-5151
q S
Mr. Gilbert W. Wallace i
~ February 28, 1983 i
Page 2 4
Our letter indicated we had experienced several non-compliances.via outfall 007 due to oil and grease since the installation of the oil / water separator system in lace 1981. We have' implemented specific corrective actions'to reduce'the potential for non-compliance and are studying both short term and long tera solutions. '1hese are described in Attachment A.. Some of these were discussed with the EPA inspection i
team during their visit. We will be prepared to discuss these in more i
detail at the March 8, 1983, meeting.
j i
On January 21, 1983, we'also reported five instances on four specific j
days where the pH of discharge from outfall 007 exceeded the u.aximum i
value of 9.0 allowed by the subject order. The values of these exceed-ances ranged from 9.07 to 9.1.
[
We were concerned with pH requirements placed on both outfall 003 and 007 when we received the administrative order on January 3, 1983. The reason for this reaction is the fact that Florida Power has been work-ing with EPA since May,1980, on an program to mititgate the discharge of oil and grease and total suspended solids (TSS) from these dis-
{
charges. At no time during conversations did EPA express concern with i
pH from these two outfalls. To the contrary, we were assured that pH was not of concern from 003 and 007 since these streams were diluted by j.
more than 10,000 gallons / minute of seawater prior to release to the environment at outfall 006. Review of our records and correspondence confira this EPA position. For example, attached is a letter dated i
October 12, 1982. You will note that discussion in this correspondence pertains to oil and grease and TSS, not pH.
We do not believe that pH should be regulated from either outfall 003 or outfall 007 in as much as these small waste streams are greatly di-i I
luted by the 10,000 gallon / minute flow of the nuclear service and decay heat seawater system prior to release to the waters of the United States at outfall 006. This, coupled with the fact that measured values for the pH of seawater range from 8.6 to 9.3, leads us to the conclu-j sion that there is no impact whatsoever on the environment.
Not withstanding this conclusion, there are actions that Florida Power
}
could take to bring the pH within the range of 6.0 to 9.0 specified in i
the administrative order. Attachment B describes actions that have l
l been implemented to mitigate these non-compliance as well as a poten-tial near term solution. EPA representatives on the inspection team were shown how we are are attempting to comply. Basically, the method i
i now being used is to sample the contents of SDT-1 and manually add through a manho'- in the top of the tank the quantity of acid esicu-lated to bring the tank contents to the proper pH range. Admittedly, l
this process is somewhat crude. Our engineering staff has invectigated more precise, sophisticated methods which we will be prepared to dis-cuss with you on March 8, 1983. These involve pumps, tanks, control systems, etc., all of which are expensive and time consuming to engi-neer, procure, and install. We do not believe the expenditures of these efforts and funds are warranted.
Mr. Gilbert W. Wallace February 28, 1983 Page 3 Florida Power Corporation has acted responsibly by identifying these waste streams, bringing them to EPA's attention, and implementing actions necessary to bring them into compliance. We are no less anxious than EPA to bring these efforts to a successful conclusion.
Sincerely, bXtLLs0%
William S. O' Brien 5
Director Environmental & Licensing Affairs WSO/gr 4
Attachments cc:
V. J. Tschinkel, FDER w/ attachment 4
i i
}
j 4!
1 i
i I
i
I Attachment A Page1 i
Oil and Grease Control February 28,1983 OIL AND GREASE CONTROL REGENERATION WASTE NEUTRALIZATION TANK (SDT-1)
PHASE I IMMEDIATE ACTIONS COMPLETED The following actions have already been initiated and combined they will significantly reduce the probability of future EPA violations associated with dumping low level waste into the CR-3 discharge canal.
1.
Auxiliary steam transfer:ed from CR 1&2 is a major source of waste water during startup an:t shutdown modes. Operational procedure changes have been made to minimize the use of auxiliary steam.
2.
Automatic actuation of the turbine building sump pumps has resulted in bypassing the Oily Water Separator. These pumps are now administratively limited to manual control.
3.
An engineering project team has been created to develop and implement near term plans to preclude future violations.
4.
Stone and Webster, an Architectural Engineering firm, has been contracted to develop an Engineering Study for a " final" solution to the problem.
l
...-,-__.-.,._.m
Attachmer,t A Page 2 Oil and Grease Control February 28,1983 i
OIL AND GREASE CONTROL
(
REGENERATION WASTE NEUTRALIZATION TANK (SDT-1)
(continued)
PHASE II NEAR TERM ACTIONS
)
The following represents near term action which will provide j
additional protection against future violations.
COMPLETION ITEM DATE i
1.
Storage of low level waste water is Mid July 1983 j
currently at a premium and contributes to the situation where waste water must be discharged. A large reserve capacity sta age system is planned utilizing an existing fuel storage tank at CR 1&2.
PHASE III LONG TERM MODIFICATIONS i
j The Phase III action item will result in a final problem solution. It will assure complete compliance with existing EPA regulations in
,j the long term.
j COMPLETION 4
ITEM DATE 1.
In order to completely understand all February,1984 i
the factors associated with low level waste handling, an Engineering Study is required. Stone and Webster will i
perform this study. Their recommendations i
as agreed upon by FPC Nuclear Engineering j
will be implemented by design modifications.
l i
t y...
r- - -... -. - --
Attachment B Page1 Oil and Grease Control February 28,1983 PH CONTROL SDT-1 AND LSST PHASE I IMMEDIATE ACTIONS COMPLETED The potential for a violation of pH limits associated with p(rocessing waste water through SDT-1 and the Laundry Shower Sump Tank LSST) has been significantly reduced. The following action items describe relevant facts and recent developments which support this conclusion.
1.
At this time there are no means available to control pH in SDT-1.
However, plant procedures have recently been modified to include manual adjustment of pH prior to discharge from SDT-1, 2.
A gross cost estimate was made by Nuclear Engineering regarding automatic pH control of SDT-1 and LSST at approximately $500,000.
PHASE II NEAR TERM ACTIONS COMPLETION I"2 M DATE 1.
In emergency situations excessive low Mid July 1983 activity level waste water will be sent to a reserve capacity storage system utilizing a fuel oil storage tank at CR 1&2. pH restrictions are not applicable during this mode.
2.
Representatives from Environmental Licensing March 3,1983 and Affairs will meet the. EPA on March 8, 1983. Florida Power will present a case that the relatively small quantities of discharge low level waste water will be effectively neutralized (pH) when added to the circulating discharge water.
PHASE III LONG TERM MODIFICATIONS COMPLETION ITEM DATE 1.
No long term modifications or studies have been planned pending the March 8,1933 meeting with the EPA.
1 i
l CERTIFIED !%IL r ;=. : -,3 tt..u-VG:::.. k' CS ee r si es a t so se October 12, 1981 Mr. ItNard D. Zeller Acting Assistant Regional Administrator U.S. Envircnmental Protection Agency i
345 Courtland Street f4E Atlanta, GA 30365
Dear Mr. Zeller:
i
Subject:
Crystal River Unit 3 NPDES Permit FL0000159 Serial fio. 006 In response to your September 18, 1981, request for information regarding Florida Power Corporation's progress in mitigating certain discharges into the t!uclear Services and Decay Heat System (Serial flo. 006), enciesed is Mr. R. C. !!iddell's memo to me dated October 6,1981, which outlines the latest status on this project. After Florida Power has veceived and revics;ed the TTI Engineering information regarding mitigction of oil and grease in the Laundry and Shower Sump Tank (LSST), we will updata you. A meeting may be in order at that time.
Sincerely, William S. O'Brien Director Environmental and Licensing Affairs WSO/kd Ms. V. J. Tschinkel, FDER W/ Attachments cc I.
l General Office 320i Tn.ny-sounn street souin. P O Bom 14o42 St Petersburg. Florida 33733 e 8t3-866-5151 j
@M INTEROFFICE CORRESPONDENCE Power Nuclear Engineerino H-1 com ;
w.u coe.)
Crystal River Unit #3 Plant Discharges to MSSW System-NPDES-000159 susJECT:
Outfall Serial 006 File: MAR 80-05-03 W. S. O'Brien October 6, 1981 yo.
cars:
Nuclear Engineering has reviewed the EPA Request for Information dated September 18, 1981, concerning NPDES Permit FL000159 Discharges Through Outfall Serial 006 and offers the following:
1.
The evaporato: condensate storage tank (ECST) - The effluent from the ECST's is distilled domineralized water. This liquid is recirculated in the tanks, sampled for activity and discharged to the NSSW system through a radiation monitor. Florida Power Corporation analyzed each batch released from these tanks from January through May 1980, approximately 50 batches, for oil, grease, and total suspended solids and pH. The only discrepancies found involved pH. This discharge was reviewed with the EPA on May 16, 1980.
The EPA agreed that FPC could discontinue monitoring this source since the only problem was pH and dilution in the NSSW system was adequate to eliminate any concern.
FPC plans no further action on this item.
2.
The laundry and shower sump tank (LSST) - This tank collects the i
waste from the contaminated laundry and hot shower. This waste is collected, recirculated, sampled for activity and discharged to the NSSW system through radiation monitors. Monitoring of this source was begun in January 1980 for oil, grease, and total suspended solids and pH. Following the May 16, 1980 meeting with the EPA f
monitoring for pH was discontinued. Monitoring for oil, grease, and total suspended solids still continues. ' A modification to the system was completed in January 1981 which added filters in the ficw path from the sump tank. After several months of evaluation it was determined that the total suspended solids problem had been corrected and further action was required for the oil and grease contamination. Florida Power Corporation contracted with TTI Engineering, a waste engineering consultant, to help resolve the
[
problem. TTI was at the Crystal River plant on September 23, 24, I
and 25, 1981. During this visit, TTI reviewed the system hardware, operation, sampling procedures and techniques, ir.vestigated for l
possible sources of contamination and talked with the operators and I
technicians. The information collected will be used to provide a total assessment of the problem and to develop options for
[
corrective action. This information is due to Florida Power l
Corporation by October 15, 1981. FPC will review the options, choose the best balanced approach which will achieve resolution and i
. oms,
^
i, W. S. O'Brien October 6, 1981 Page Two plan and initiate implementation. A description of the chosen action and implementation schedule will be submitted by i
November 13, 1981. Florida Power Corporation is continuing administrative efforts to minimize the oil and grease contaminments in the LSST discharges.
3.
The Regeneration Waste Neutralization Tank (SDT-1) - The effluent from this tank originates in the Turbine Building sump and is routed to this tank prior to discharge through rtdiation monitors.
Florida Power Corporation is continuing to monitor this discharge for oil, grease, and total suspended solids and is continuing the administrative effort to minimize the oil and grease contamination of this discharge. By letter dated December 2,1980 l
(O'Brien/Zeller) FPC outlined the plan to install a cleanup system between the turbine building sump and SDT-1 which would remove the oil, grease, and solids to within 40 CFR423 limits. Operation was scheduled for November 1981. Florida Power Corporation has maintained this schedule and presently is making every effort to have the new equipment installed by November 1,1981. A FACET 400 gpm oil / water separator system has been purchased on FPC Purchase Order F1110). Shipment is scheduled from Tulsa Oklahoma on October 15, 1981, receipt at Crystal River 3 should be by October 19, 1981. All miscellaneous pipe, valves, hangers, electrical and control equipment has been purchased and received.
The engineering design packege to install the systsem was issued on August 17, 1981. Prefabrication and installation of piping is presently in progress. Attached for your information are the following documents related to the turbine building sump modification:
a.
Florida Power Corporation Specification SP-5059 dated January 19, 1981 b.
FACET Proposal No. 81-11-SE dated February 24, 1981.
Florida Power Corporation Purchase Order F11109 with three (3) c.
amendments.
d.
FACET drawing No. 677311 Sheet 1 and 2.
e.
Engineering Design package MAR 80-05-03 without attachments.
\\
m y
.-c m.,
,w.
w r--.,
y y
-..y
.-.w-,,,,.,,,,,.
,._,.,y
-f.,,y me--,,
-,y.-
,,g
,-y
i W. S. O'Brien l
October 6,1981 Page 6 If any additional information is required, please contact me at extension 4738. Thank you.
l R. C. Wide 11 Nuclear Mechanical Engineer Widell(T05)D1-1 cc:
G. A. Becker (w/o attach)
P. Y. Baynard (w/o attach)
File Readers i
_ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _