ML20076K813

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Forwards Three Recent non-compliance Repts Re Fort St Vrain National Pollutant Discharge Elimination Sys Permit
ML20076K813
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 10/19/1994
From: Warembourg D
PUBLIC SERVICE CO. OF COLORADO
To: Joseph Austin
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
P-94090, NUDOCS 9411020125
Download: ML20076K813 (11)


Text

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P.O. Box 840 16806 WCR 191/2; Platteville, Colorado 80651 cenv, co 8020i-o840 October 19, 1994 Fort St. Vrain P-94090 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Attention:

Mr. John H. Austin, Chief Decommissioning and Regulatory i

Issues Branch Docket No. 50-267 i

SUBJECT:

NPDES Permit Non-Compliance Reports

Dear. Mr. Austin:

Attached for your information are three recent non-compliance reports related to the Fort l

St. Vrain (FSV) National Pollutant Discharge Elimination System (NPDES) Permit. This information is provided in accordance with the FSV Non-Radiological Technical t

Specifications, Section 3.2.a of Appendix B to Facility Operating License No. DPR-34.

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If you have any questions regarding this information, please contact Mr. M. H. Holmes at (303) 620-1701.

Sincerely, 0 /Y /) % Q I

Don W. Warembourg Decommissioning Program Director DWW/SWC Attachment ec:

Regional Administrator, Region IV Mr. Robert M. Quillin, Director Radiation Control Division Colorado Department of Health i

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October 7,1994 l

I Ms. Kathleen L. Kalamen l

Industrial Enforcement Engineer i

Permits and Enforcement Section I

Water Quality Control Division j

Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, Colorado 80222-1530 RE:

Public Service Company of Colorado (PSC) Fort St. Vrain Station CDPS l

Permit No. CO-0001121 l

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Dear Kathy:

j Attached please find a non compliance report for the PSC Fort St. Vrain Station.

The non-compliance report details the maximum pH exceedance reported to you on j

October 5,1994.

If you have any questions regarding this report, please feel free to contact me at 294-2814.

Sinc ly, h Lf &

Louise C. Meyerkord Unit Manager Environmental Programs Attachments cc:

U.S. EPA, Region Vill Steve Miller Don Warembourg Dave Fetterolf Ted Borst Terry Staley Jesse Brungardt Glen Reigel l

NPDES DISCHARGE PERMIT NONCOMPLIANCE REPORTING FORM Date: 10/07/94 Applicable Permit No.: CO-0001121 Discharge No.: 001 A Company: Public Service Comoany of Colorado Mailing Address: P.O. Box 840 Denver. CO 80201 I

Plant Name: Fort St. Vrain Station Plant Location: Near Platteville. Colorado County: Weld II. NONCOMPLIANCE REPORT A.

Description and Cause of Noncompliance: A sample collected at discharge point 001A at l

2:00 pm on 10/4/94 exhibited a pH of 9.40 s.u. The cause of this elevated pH is biological

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(photoplankton) activity in the farm pond. Water discharged into the pond from the Goosequill Ditch has a pH less than 9.0 s.u.

B. Noncompliance Period:

Started:

A. M.

2:00 P. M.

10/4/94 Date Ended:

A.M.

P. M.

Date C. Action Taken to Reduce, Eliminate, Prevent: A year-long study was implemented on May 1993 to determine the causes of high pH in the 001 A outfall from the farm pond. This study was completed on 9/30/94 and submitted to the CWQCD. The conclusion of the study was that elevation of pH across the farm pond was related to biological (photoplankton) activity. A I

permit amendment will be d.afted for public notice in November 1994, which will delete the pH limitations for outfall 001 A. (See attached 9/30/94 letter from Don Holmer, CWQCD)

D. Person Initiatiq.R6 port: Lemse Meyerkord,

e Signature: ' A /4tlJJ - l h11 h*' M f/1 L

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E. Water Quality Control Division Noti cation Requirements:

Telephone (24 hrs.):

10/5/94 Date Ms. Kathleen Kalamen Notified 1:07 om

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Written (5 days):

10/7/94 Date Notified l

SUBMIT REPORT TO:

%It. Pat Nchon Regional Adminhtratae Colorado Department of flesiah U.S. EPA Water Quaht, Control Divhion One Denver Place. Suite 500

\\1onianrine & Enforrevocat Seetina 999 INth Strew MWM-C 4300 Cherry Crwk Drive South Denver. CO N0202 2405 lienver. LO wil2221530 Atta.: En(necennent. Permit Penerse la the event of naa. compliance for the FSV Station. a verhal report must he made to the Nuclear Nresiseery Comesse by the F5V shift supervisor 6201n90) withia four hours after verhally notifying the Water Quahey Controi Divisies.

C..ntade.a the FsV.nitt supemsor ishaters.it 109 p m..m to.5/94 5

STri O? CO_OW30 Roy Romes, Covemor Patrma A. Nolan. MO, MPH Exectmve Direcer Dedtated ao prosecxar's and unproveng she heskh and enwonrnant of the peop6e of Colorano 4300 Cherry Cred Dr. 5.

taborasory Build a6

- Denver Colorado a02221530 a210 E.11th Avenue Phone (303)692 2000 Denver. Colorado 80220 3716 (3031691.a700 g p_hasidi_ _ _ _ - _ _

ofPublic September 30, 1994 andEnvueamam Louise Meyerkord, Unit Manager, Environmental Programs, Public Service Company of Colorado P.O.

Box 840 (1225 17th Street, Suite 2000)

Denver, CO 80201

Subject:

Public Service Company of Colorado (PSC) Fort St. Vrain Station, Discharge Permit Co-0001121, Wald County, Colorado.

Dear Louise i

This letter is a verification of our telephone conversation yesterday (September 29, 1994) with respect to the Division's deterisination regarding future PE limitations for outfall 001A from the Farm Pond outlet to the South Platte River, which is part of the PSC Fort St. Vrain Station Discharge Permit CO-0001121. The Division has determined at this time that a permit amendment will be drafted for the next public notice (November 1994) which will be deleting the pH limitations for outfall 001A. This decision is based upon the one year study by PSC of the conditions in the Farm Pond, outfall 001A, and outfall 0018.

This report has shown that the elevated pH levels from the Fara Pond (001A) are due to algae and to the presence of nutrients in the pond throughout the year; however, there has been compliance within the range of the pH limits for outfall 0018 which is prior to the inlet of the Farm Pond.

The Division's decision is also based upon a consideration of the previously specified limits for outfall 001A (which has included total residual chlorine limits, temperature limits, and flow reporting) in the last three renewal permits, which did not include pH limitations at 001A.

Thus, at this time, the Division will use enforcement discretion for any violations of the pH limitation range of 6.5 to 9.0 s.u. for outfall 001A, since these limits will be deleted. Although these particular pH limits were specified as applicable beginning on October 1,1994 on page Ic(1) of the permit, these limits are also subject to the ** footnote, which states: "These pH limitations will be further reevaluated and modified, based upon the analytical results of the one-year study and other possible considerations." Thus, this letter and the next amendment address the decision that there will be no pH limits for the 001A discharge point.

For the time being, Public Service Company should continue monitoring for pH at outfall 001A.

Requirements for future pH monitoring at outfall 001A will be discussed in the upcoming permit amendment.

HOCeived Enwenrnont Services p

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.Louico May0rkord, Unit Mantgar, Environmental Program 3, j

"Public Servico comp:ny of Coloredo - Ft. St.-Vrain Station September 30, 1994 Page 2 If you have any concerns or questions regarding this letter, please contact me at (303)+692-3601.

Sincerely, l

1 Don A. Holmer Industrial Permits Engineer i

Permits and Enforcement Section WATER QUALITY CONTROL DIVISION cc Kathleen Kalamen, Industrial Permits and Enforcement Unit, WQCD Victor Sains, Field Support Section, WQCD Wald County Health Department Permits Section, Environmental Protection Agency l

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  • th P.O Box 840 i

Denver. CO 80201 0840 October 10,1994 Ms. Kathleen L. Kalamen Industrial Enforcement Engineer Permits and Enforcement Section Water Quality Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver. Colorado 80222-1530 RE:

Public Service Company of Colorado (PSC) Fort St. Vrain Station CDPS Permit No. CO-0001121

Dear Kathy:

Attached please find a non-compliance report for the PSC Fort St. Vrain Station. The non-compliance report details the boron exceedance reported to you on October 10, 1994.

If you have any questions regarding this report please feel free to contact me at 294-2814.

Sin rely, IAuise C. Meyerkord Unit Manager Environmental Programs Attachment ec:

U.S. EPA Region Vill Steve Miller Don Warembourg Terry Staley Dave Fetterolf i

Jesse Brungardt Mike Holmes Ted Borst Glen Reigel

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NPDES DISCHARGE PERMIT NONCOMPLIANCE REPORTING FORM Date: 10/10/94 Applicable Permit No.: CO-0001121 Discharge No.: 001B I.

GENERAL Company: Public Service Comoany of Colorado Mailing Address: P.O. Box 840 Denver. CO 80201 Plant Name: Fort St. Vrain Station Plant Location: Near Platteville. Colorado County: Weld II. NONCOMPLIANCE REPORT A.

Description and Cause of Noncompliance: A sample collected at discharge point 001B at 8:45 am on 10/9/94 exhibited a boron concentration of 0.813 mg/1, which slightly exceeds the 0.75 mg/l boron limitation established in my 8/26/94 letter to Don Holmer. (Copy is attached.)

The boron concentration at 9:00 am on 10/8/94 (the first day of this PCRV shield water release) was 0.449 mg/1, thus allowing for higher discharge rates. Apparently, the higher discharge rate caused exceedance of the limit. The rele.ase was complete by the time the 0.813 mg/l boron analytical result was received.

B. Noncompliance Period:

Started:

8:45 A.M.

P. M. 10/9/94 Date Ended:

10:20 A.M.

P. M.

10/9/94 Date C. Action Taken to Reduce, Eliminate, Prevent: The discharge was complete prior to receipt of the 10/9/94 boron analytical result. More conservative margins will be utilized in future PCRV shield water releases.

D. Person Initiating prt: Louise Afeverkord Signature:

VI E. Water Quality Control Division NotificMion Requirements:

Telephone (24 hrs.):

10/10/94 Date Ms. Kathleen Kalamen Noti 6ed 8:30 am Written (5 days):

10/10/94 Date Noti 6ed SUll%IIT REIHRT 10:

Sis. Kathiern Kalainen Regional Administrator t'ulorado Department of 11ealth U.S. EPA Water Quality Control Divisism One Denver Place, Suite 500

%1onitoring & Enrurrement Sertum 499 INth Street NWAl C 000 Cherry Creek Drive Nmth Denver, CO N0202-2405 Denser. CO x02221530 Attn.: Enforcement Permit Program In the esent of non<ompliance for the FSV Station, a verhal report must he made to the Nuclear Regulatory Commission by the FSV shift supervisor to20-1090) within four hours after terhally notifying the Water Quality Control Division.

c ntacted the FsV shid supervnnr at 8:33 a.m. nn 10/10/94.

h Public Service-

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= a su uo Lenver CO 802010840 August 26,1994-Mr. Don Holmer industrial Permits Engineer Permits and Enforcement Section Water Quality Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, Colorado 80222-1530 RE:

Public Service Company of Colorado - Fort St. Vrain Station Permit #CO-0001121

Dear Don:

As we discussed, the Public Service Company of Colorado (PSC) Fort St. Vrain Station (FSV) will be discharging the first 38,000 gallons of shield water from the prestressed concrete reactor vessel (PCRV) through a filtering /demineralizer system and subsequently to the South Platte River via the Goosequill Ditch during the week of August 29,1994. This discharge will be made in accordance with conditions of the FSV wastewater discharge permit and the Tritium Discharge Understanding between Public Service Company of Colorado and the Colorado Water Quality Control Division (" Tritium Understanding"), as developed in August and September 1992.

Due to the tact inat tritium ievels in the PCRV shield water have been much lower than preaicted, very little PCRV shield water has been released to date.

Accordingly, there has been an accumulation of sodium nitrite, sodium nitrate (due to the conversion of most of the nitrite in the PCRV shield water to nitrate), and sodium tetraborate; the source of these parameterr is from the approved use of Calgon products as coagulant aids in the PCRV shield water. Such materials would have been released over the last year if a " feed and bleed" program had been necessary due to higher tritium concentrations being encountered.

Therefore, as we agreed, to comply with water cuelity standards for Segment 1 of the Middle Soutn Platte River, FSV will utilize purposeful control of release rates of the PCRV shield water to the Gooseouill Ditch. along with waters reautred to comply witn 10 CFR 20 limits for radioactive releases. FSV will ensure that the waters discnarged from ine Gooseouill Diten to the Soutn Platte River comply with all existing wastewater aiscnarge limiations, as well as tne following limitations:

1) 0.68 mg/l nitnte (as agreed in tne " Tritium Unaerstanaing");

2) 10 mg/l nitrate twater cuality stancaro for tne receiving seament): and 3) 175 mgn ooron twater cuantv stanaara for tne receiving segment and agricultural stanaaral

i The potential for increaseo levels of nitrates entering tne farm pond from the Gooseouill Ditch is not exoected to nave a significant effect on tne OH at the farm cono due to the snort duration of the PCRV snield water releases.

The PCRV shield water will be crained from the PCRV througn demineralizers to a bladder in the Reactor Building sumo, then drained from tne cladder to the sum pump, wnich will disenarge it Oy mixing it with the 10 CFR 20 reouired blov.down flow.

Analysis of the bladder contents for radioactivity levels, as well as nitrite, nitrate, and boron concentrations will be performed prior to release from the bladder.

Release rates to the Goosequill Ditch will be calculated to ensure compliance with the wastewater discharge permit conditions and the aforementioned nitrite, nitrate, boron, and radioactivity limits.

FSV will further ensure that such limitations are met by conducting daily sampling for these parameters at the Goosequill Ditch (outfall 0018) during the days when a release is made. Due to consistency of the water quality of this water, it is believed that this frequency will accurately reflect the concentrations of these parameters in the released water, Results of the monitoring of the nitrite, nitrate, and boron will be submitted to the CWQCD upon receipt.

It is anticipated that each 38,000 gallon release will take place in approximate a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period with at least one week between releases. Three 38,000 gallon releases and one 21,000 gallon release will be conducted in the upcoming six weeks.

The next major drain of 175,000 gallons is expected to be made in February to April 1995.

Draining of the remaining 40,000 gallons of PCRV shield water will be conducted as necessary to support the decommissioning program.

Thank you for your cooperation in this matter. If you have any questions or concerns regarding this information, please call me at 294-2814 Sincerely, i

W Louise C. Meyerkord Unit Manager Environmental Programs cc:

A. C. Crawforo D. Waremoourg D. Fetterolf G. Vanesn J. Brungardt T. Staley M. Niehoff G. Reigei T. Borst B. Woooard

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P 0. Box 840

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Denver. CO 80201 0840 i

October 12, 1994 Ms. Kathy Kdamen Industrial Enforcement Engineer -

Permits and Enforcement Section Water Quality Control Division Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South Denver, Colorado 80222-1530 RE:

Public Service Company of Colorado'- Fort St. Vrain Station CDPS Permit No.

CO-0001121 1

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Dear Kathy:

Enclosed please find a non-compliance report for the Public Service Company of Colorado Fort St. Vrain (FSV) Station. The non-compliance report details the pH exceedances reported to you on October 12, 1994, If you have any questions regarding this report, please feel free to contact me at 294-2814.

Sincerely, Louise C. Meyerkord I

Unit Manager Environmental Programs

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l Attachment cc:

U.S. EPA, Region VIII Steve Miller Don Holmer Glen Reigel Don Warembourg Mike Holmes Dave Fetterolf Terry Staley Ted Borst Jesse Brungardt

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NP' DES DISCHARGE PERMIT NONCOMPLIANCE REPORTING FORM Date: 10/12/94 Applicable Permit No.: CO-0001121 Discharge No.: 001 A I.

GENERAL i

Company: Public Service Comoany of Colorado Mailing Address: 'P.O. Box 840 Denver. CO 80201 Plant Name: Fort St. Vrain Station Plant Location: Fear Platteville. Colorado County: Weld II. NONCOMPLIANCE REPORT A. Description and Cause of Noncompliance: A sample collected at discharge point 001A at 1:00 pm on 10/12/94 exhibited a pH of 9.34 s.u. The cause of this elevated pH is biological (photoplankton) activity in the farm pond. Water discharged into the pond from the Goosequill Ditch has a pH less than 9.0 s.u.

B. Noncompliance Period:

Started:

A.M.

1:00 P. M.

IN12/94 Date f

Ended:

A.M.

P. M.

Date C. Action Taken to Reduce, Eliminate, Prevent: A year-long study was implemented on May 1993 to determine the causes of high pH in the 001 A outfall from the farm pond. This study was completed on 9/30/94 and submitted to the CWQCD. The conclusion of the study was that elevation of pH across the farm pond was related to biological (photoplankton) activity. A permit amendment will be drafted for public notice in November 1994, which will delete the pH limitations for outfall 001 A.

j D. Person Initiatig;dfeport: LouiscEeverkord Signature: /,A AfOaj ',ll4/4 '1AND $..,

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E. Water Quality Control-Division Notification Requirements:

Telephone (24 hrs.):

10/12/94 Date Ms. Kathleen Kalamen Notified 2:30 om Written (5 days):

10/12/94 Date Notified

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SUllMIT REl' ORT TO:

Ms. Kathlwn Kalamen Regional Adminhtrator Colorado Department of Public liralth and Environment l' N. EPA Water Quality Control Dishion e Denser Place. Suite 500 Monitoring & Enforcement Swtion 999 IXth Strert N WM-C 4.100 Cherry Crwk Drise Nmth Denser. CO x0202 2405 Denver, CO hu2221530 Attn.: Enforcement Permit Program in the event of non<ompliance for the FSV Station, a scrhal report must he made to the Nurtrar Regulatory Commission

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