U-602988, Annual Environmental Operating Rept for Period Covering Jan-Dec 1997
| ML20217P817 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/31/1997 |
| From: | Sipek J ILLINOIS POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| U-602988, NUDOCS 9805070099 | |
| Download: ML20217P817 (8) | |
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liknois Power Company Clinton Power Station P.O. Box 678 Clinton, IL 61727
. Tel 217 935-8881 Joseph V. Sipek g Director . Licensing An mmova Company U-602988 1 A.120 April 30, 1998 l
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Docket No. 50-461 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Clinton Power Station Annual Environmental Operating Report
Dear Sir:
In accordance with Appendix B to the Clinton Power Station (CPS) Technical Specifications, Clinton Power Station's Environmental Protection Plan (EPP), Illinois Power (IP)is submitting the Annual Environmental Operating Report. This report covers the period of January 1,1997, through December 31,1997.
Sincerely yours, P
J se h V. S e Director - Licensing GBS/mlh >
Attachments )
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cc: NRC Clinton Licensing Project Manager )
NRC Resident Office, V-690 j Regional Administrator, Region III, USNRC g {
i 9905070099'971231 DR l ADOCK 05000461
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Attachment I to U-602988 Page 1 of 4 Annual Environmental Operaties Report The Environmental Protection Plan (EPP) for Clinton Power Station (CPS) require:, that the Annual Environmental Operating Report include:
(A) A list ofEPP non-compliances and the ccrrective actions taken to remedy them.
(B) A list of all changes in station design or operation, tests, and experiments made in accordance with subsection 3.1 of the EPP which involved a potentially significant unreviewed environmentalissue.
(C) A list of non-routine reports submitted in accordance with subsection 5.4.2 of the EPP.
- (D) Any results and/or assessments for the environmental monitoring programs s described in subsection 2.0 of the EPP which were submitted to the respective regulatory agencies during the annual reporting period.
The following provides Illinois Power's response to each listed item.
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A. A list of EPP non-compliances and the corrective actions taken to remedy them:
- 1. On Thursday, January 2,1997, the vendor representative assigned to service the Raw Water Treatment system conducted routine drawdown tests on the Sodium Bisulfite (dechlorination) pumps located in the Shutdown Service Water (SX) System Egress building (Outfall 007).
Following the drawdown test on the Division III Bisulfite Pump, the vendor representative neglected to reopen the supply valve to the pump.
Starting at 1445 on Friday, January 3,1997, a Division III Diesel Generator Heat Exchanger flush was per formed for approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. This established chlorinated water flow in the Division III SX piping to the Ultimate Heat Sink (when the DG H/X is not being flushed no flow exists in the Div III piping). Since the Division III Bisulfite Pump was valved out, the water discharging to the lake was not dechlorinated. This was a non-compliance with the CPS National Pollutant Discharge Elimination System (NPDES) permit.
Corrective r. :.
Tite vene m ,..csentative was counseled on the use of self-checking tee..dc ; This is considered to be an isolated event, consequently no furthe .nions are necessary.
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Attachment I to U-602988 Page 2 of 4
- 2. On March 4,1997, samples collected from both Sewage Treatment Plants (Outfall 002a) contained a flow weighted average Total Suspended Solids (TSS) cons atration of 113 mg/l (NPDES permit limit 60 mg/l). This l i
result was attributed to instability of the Contact Stabilization Sewage Plant due to a recent startup of the plant, which was necessitated by heavy rainfalllate in February. The Extended Aeration Sewage Treatment Plant is normally the only treatment plant required to process plant sewage. The result may also have been affected by improper placement of the suction strainer of the Extended Aeration Sewage Treatment Plant sample compositor too close to the bottom of the Discharge Chamber, resulting in a non-representative sample being collected due the uptake of material deposited on the floor of the chamber.
Corrective Action:
Personnel have been briefed on the necessity of verifying that the suction strainer is not placed too close to the bottom of the Discharge Chamber. ]
- 3. On March 8,1997, a sample collected from the Wastewater Treatment ;
Facility (Outfall 003) contained a TSS concentration of 115 mg/l (NPDES permit limit 30 mg/l). This resulted in the TSS 30-Day Average clso being exceeded (29 mg/1, NPDES permit limit 15 mg/l). This analysis value is '
believed to be due to recent maintenance performed at the Wastewater Treatment Facility which involved the replacement of a length of piping.
Debris from the pipe repair apparently found its way into the effluent of the treatment process.
Corrective Action:
In the future, whenever maintenance of this nature is performed, the piping will be flushed thoroughly to prevent a similar occurrence.
1 Attachment 1 )
4 to U-602988 Page 3 of 4
- 4. CPS experienced problems with Total Residual Chlorine (TRC) analyses during October 1997. In June 1997, the Chemistry group starting using a handheld instrument based on the spectrophoto-metric DPD method, called l a "DCR Photometer", for NPDES TRC analyses. Prior to October, the l Chemistry group had not experienced any difficulties with the DCR Photometer.
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- 1) On October 8,1997, high TRC results (0.92 to 0.95 mg/l) were obtained while sampling all three Shutdown Service Water (SX) divisions at Outfall 007(NPDES permit limit 0.05 mg/1). These results were believed to be due to high turbidity present in the lake water supply to the SX system, possibly from lake turnover, causing " false positive" data to be obtained. All three SX divisions were resampled a short time later with analysis results below the Method Detection Limit. Since the high results were believed to be an isolated occurrence, the matter was not pursued at that time.
- 2) The next weekly samples were performed on October 14,1997, with results ranging from <0.05 mg/l to 0.17 mg/1. Using information received from the manufacturer, the analysis procedure was revised and the three SX divisions were resampled later that i same week, with results below the Method Detection Limit. It was l subsequently determined that the revised procedure was not in accordance with Standard Methods for the Examination of Water and Wastewater,19th Edition, method 4500-Cl G, DPD Colorimetric Method. High TRC results, ranging from 0.79 mg/l to 0.85 mg/1, were obtained the next week (en October 20,1997) at Outfall 007. However, this time the SX divisions were resampled using an amperometric titrator, with results below the Method Detection Limit.
Corrective Action:
As corrective action, the DCR Photometer is no longer being used to analyze NPDES samples.
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Attachment I to U-602988 Page 4 of 4 l
- 5. On November 30,1997, analysis of a sample cellected fro'n the Transformer Area I Oil Water Separator (Outfall 004) indicated an Oil & Great e (O&G) concentration of 29 mg/l (NPDES permit limit 20 mg/l).
l Corrective Action: l The reason for the high O&G result could not be determined. The Oil Water Separator was subsequently inspected and no evidence of oil (sheen) was found in the outlet chamber. Small quantities of oil, considered to be within normal parameters, had been found in the inlet and middle (settling) chambers during the previous monthly inspection. This is considered to be an isolated incident, consequently no further action is necessary.
The following item was not categorized as a NPDES permit non-compliance, but was reported in a routine discharge monitoring report.
In October 1997, CPS discovered and reported to the Illinois Environmental Protection Agency a potential unmonitored discharge of chlorine from screenhouse Outfall 006. The October Discharge Monitoring Report stated details would be provided in a separate letter. Details were provided to the Illinois Environmental Protection Agency on December 18,1997 in letter 0-601581. (see attachment 2) l B. A list of all changes in station design or operation, tests, and experiments made in i accordance with subsection 3.1 of the EPP which involved a potentially significant !
unreviewed environmentalissue- ;
1 There were no changes in station design or operation, tests, and experiments made ;
in accordance with subsection 3.1' of the EPP which involved a potentially significant unreviewed environmental issue.
I C. A list of non-routine reports to be submitted in accordance with subsection 5.4.2 of the EPP:
There were no non routine reports submitted in accordance with subsection 5.4.2 of the EPP.
D. Any results and/or assessments for the environmental monitoring programs described in subsection 2.0 of the EPP which were submitted to the respective regulatory agencies during the annual reporting period:
There were no results and/or assessments submitted to regulatory agencies with respect to environmental monitoring programs described in subsection 2.0.
Ilhnois Power Company P O Box 511 Decatur, IL 62525-0511 1 P@WER Attachment 2 u no. c.m.a, to U-602988 Page 1 of 3 0-601851 December 18,1997 {
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l Mr. Thomas G. McSwiggin, P.E. 1 i
Manager, Permit Section l
Division of Water Pollution Control Illinois Environmental Protection Agency 1021 North Grand Avenue East Springfield, Illinois 02794-9276 ,
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Dear Mr. McSwiggin:
Illino:s Power Company - Clinton Power Station NPDES Permit No. IL0036919 - Outfall 006 In the Clinton Power Station (CPS) October,1997 DMR, Illinois Power stated in the comment section that there is a potential unmonitored discharge of chlorine from screenhouse Outfall 006. Travsing screen backwash water is the major contributory wastestream for Outfall 006. After numerous raw water treatment system modifications have occurred over the course of the last 10 years at Clinton Power Station, it was recently discovered that the traveling screen backwash water is now continuously chlorinated with sodium hypochlorite.
There are six traveling screens in the circulating water screen house. During normal operating conditions, each of the six traveling screens backwashes a minimum of 40 minutes every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with water from the service water system. Backwash water and traveling screen debris then flow inrough a trough into a trash collection basket. The overflow from this basket then discharges to Clinton Lake from Outfall 006.
Traveling screen backwash water is supplied ftom the service water system at CPS.
Service water for CPS is pulled directly from Clinton Lake by the service water pumps.
Service water was intermittently chlorinated with sodium hypochlorite from August,1988 to October,1991. From October,1991 through May,1996 the traveling screen backwash water was not chlorinated. Since May,1996, as a result of the latest raw water treatment system modification, the service water system (and hence, the traveling screen backwash water) has been continuously chlorinated with sodium hypochlorite.
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Page 2 of 3 the period that CPS was intermittently chlorinating service water, the probability that the 40- -
minute backwashing cycles of the traveling screens coincided with the approximate two hours y )
' i that sentice water chlorination occurred is minimal. It is important to note that the only time that a chlorinated water discharge could have occurred from Outfall G06 was during the !
traveling screen backwashings.
The Station has now confirmed that chlorinated water discharges have occurred from i Outfall 006 since May,1996 when the continuous chlorination of the service water system !
began. However, for various reasons, the service water system has not been chlorinated for j approximately 7 months of the 19-month period that the continuous chlorination system has i been in operation.
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During normal operating conditions with the circulating water pumps running, most of l the water discharged from Outfall 006 is expected to be returned to the suction bay in the !
screen house (intake) because the Outfall 006 discharge pipe is only about 50 feet from the screen house. At normal station operating conditions, the average inlet flow varies between 648 million gallons per day and 864 million gallons per day with eitSer two or three circulating water pumps and two service water pumps in operation. The discharge to Outfall 006 from screen washing is approximately 70,000 gallons per day. For most of the period between August,1988 and October,1996 circulating water pumps have op'erated and water in the immediate vicinity of the screenhouse would be drawn into the circulating water pumps. ;
During the interval of intermittent chlorination to the service water system, the Total Residual Chlorine in the screen wash water, during normal operations, is estimated to be 1.75 ppm. Since continuous chlorination of the service water system began in May,1996, Total j Residual Chlorine has ranged from 0.7 to 2.0 ppm during normal operating conditions.
Upon discovery of the chlorinated water discharge to the lake, chlorination to the service water system was promptly terminated until CPS could ensure that backwashing of the traveling screens would utilize non-chlorinated service water. Sincethechlorinated water i discharge was terminated immediately, the concentration of chlorine in Clinton Lake is not known. However, Illinois Powerwould not expect the concentration to be significant because s of the chlorine demand of the lake water in the immediate vicinity of the intake area.
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CPS has identified three potential resolutions to prevent chlorinated water from entering the laks through Outfall 006. The most economical and feasible solution (and the .
plan of choice at this time) is to dechlorinate the traveling screen backwash water with sodium bisulfite before the water is discharged to Outfall 006. The final resoluticn will be determined l upon detailed evaluation of all potential options. The Agency will be notified of the final '
resolution by either an application for construction and operating pen nit if a treatment system
'is chosen or by letter if another option is chosen.
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Attachment 2 to U-602988 )
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Should have any questions regarding this information previously provided, feel free to contact me at 217/424-6833.
Sincerely, ILLINOIS POWER COMPANY Brett J. Marshall .
Group Leader, Water bc: J. S. Sipek, V-9 M. A. Reandea G. B. Statton, V-920)
R. C. Maurer, T-31C J. M. Niswander/S. G. Massie, T-31C R. L. Jones, V-928 I T. L Davis / CPS NPDES Corr., A-17 N. 6. Locke, T-33 l
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