View source for RBG-30244, Responds to Administrative Order Issued on 890131 Re Violation of Min Ph Limitations in Outfall 001 on 880917 Due to Rainwater from Acid Storage Tank Containment Being Transferred Rapidly Into Cooling Sys Flume

{{Adams
| number = ML20235Y518
| issue date = 03/03/1989
| title = Responds to Administrative Order Issued on 890131 Re Violation of Min Ph Limitations in Outfall 001 on 880917 Due to Rainwater from Acid Storage Tank Containment Being Transferred Rapidly Into Cooling Sys Flume
| author name = Deddens J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = Knudson M
| addressee affiliation = ENVIRONMENTAL PROTECTION AGENCY
| docket = 05000458
| license number = 
| contact person = 
| document report number = RBG-30244, NUDOCS 8903140264
| document type = CORRESPONDENCE-LETTERS, EXTERNAL CORRESPONDENCE, EXTERNAL LETTERS ROUTED TO NRC
| page count = 2
}}

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GUL1 '' STATES                   UTILITIES COMPANY ne www.         rem m u .e            , ucm um 7w,                                       I ARE A CC E. $ A    #35494 J     348 MS1 March 3,1989 RBG- 30244 File No. G1.11.7 Mr. Myron 0. Knudson Water Management Division (6W)
U. S. Environmental Protection Agency, Region VI 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733

==Dear Mr. Knudson:==

Administrative Order Docket No. VI-89-067 NPDES Pernit No. LA0042731                                                     l River Bend Station - Unit 1 This letter is in response to the Administrative Order issued on January 31, 1989, and received on February 2, 1989, relating to the violation of minimum                                ;
pH limitations in Outfall 001 (cooling tower blowdown) at River Bend Station on September 17, 1968. The violation resulted when rainwater from an acid
:,torage tank containinent was transferred too rapidly into a cooling systern flume. Leaks from equipment in the acid tank system hcd contaminated the rainwater, which in turn exceeded the buffering capacity of the cooling water in the flume. Contrary to the description in the Administrative Order, 350,000 gallc.ns of acid-contaminated rainwater were not discharged directly to tsie Mississippi River. About 25,000 gallons of acidified rainwater were transferred to the flume, froin which blowdown was being discharged at 1,900-2,000 gallons per minute. Records indicated that the flume pH may have                                .
been below 6.0 standard units (SV) fer 2-3 hours until blowdown was stopped.                                1 Hence, the conservative estimata of 350,000 gallons                         on     noncomplying discharge. The pH of 3.1 SU, measured in the outfall proper, repre.sented the lower extreme for the period in question.
As noted in the noncompliance letter submitted on September 22, 1988, the ininediate corrective actions taken were to stop the discharge within a few minutes of recognizing the problem and to repair the acid leaks to the spill containment a few days later. Inustigations and discu:sfons of the incident i
(e.g., at group safety meetings) produced a heightaed awareness of the l           indirect consequences of transferring any fluids to systems which discharge l           to the environment. Measures to prevent recurrence of thic typa of problem
!           were fully instituted within about a week after the incident, as follows:
: 1. Warning     signs    were placed at appropriate facilities, instructing personnel that secondary containments may only be emptied with proper authorization.
: 2. The    formal written instructions governing removal of fluids                        from secondary containments by maintenar.ce persnnnel were ravised to require appr9priate       evcluation,             planning,      coordination,    and    signature        3 authorization by chemistry or environmental personnel on a case-by-case                    4)'7 i basis.       g,gg        ,4 g9gggg                                                            (
PDR    ADOCK 05000458 9                          PDC

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O'Neill                                                                      Page 2       j The incident of September 17, 1988, was due piimarily to inadequate coordination and control of a relatively infrequent activity.' Although the               l rainwater was known to be contaminated, the concentration of leaked acid was             l not fuliy appreciated and the need for ca reful , gradual               transfer was     j overlooked.          The procedural changes noted in item 2 above effectively force personitel to perform such transfers in a coordinated and controlled manner.,
On tha few occasions since September,1988, that transfers of fluids from                 !
spill containments to tne flume have been performed, the revised procedure has worked well. We are confihnt that strict adherence t3 the procedure                  3 will prevent any future adverse effects of such maintenance activities en the quality of effluents to the Mississippi River.
I certify under penalty of law that this document and all          attachments were pr epared under my direction or supervistan in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.            Based on my inquiry cf the person or persons who manage the system, or those persons directly responsible for gathering the infonnation submitted,          the  information submitted is, to the best of my knowledge and belief, true, accurate and complete.          I am aware that there are significant          penalties for submitting false information,       including the possibility of fine and imprisonment for knowing violations.
Sincerely,
[&            P J. C. Deddens                               '
Senior Vice President JCD/ E8/           RJK/   /JVC/ch cc: Mr. Frank Dautriel, Enforcement Coordinator Office of Water Resources Department of Environmental Quality Post Office Box 44091, Capitol Station Baton Rouge, LA 70804-4091 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555
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