RBG-31586, Responds to Violations Noted in Administrative Order VI-89-317 Re NPDES Permit LA0042731.Individual Involved Counseled to More Carefully Monitor Inventory of Flow Chart Recorder Paper

Responds to Violations Noted in Administrative Order VI-89-317 Re NPDES Permit LA0042731.Individual Involved Counseled to More Carefully Monitor Inventory of Flow Chart Recorder Paper

ML20248J235
Person / Time
Site:	River Bend
Issue date:	10/03/1989
From:	Booker J GULF STATES UTILITIES CO.
To:	Knudson M ENVIRONMENTAL PROTECTION AGENCY
References
RBG-31586, NUDOCS 8910130162
Download: ML20248J235 (3)

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3 GULF STATES UTELETIES C'OMPANY AlVER BEND $TATION PCM CutC6 EOX no ST $eANC;3dlLLE. LOJMANA 70175 AHEA CTE 'JA 0 % tG94 3J6 8651 October 3 ,1989 RBG- 31586 i File No. G1.11.7

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Mr. Myron Knudson, P.E. .

U. S.. Environmental Protection A .

Water Enforcement Branch-(6W-E) gency 1445 Ross twenue Dallas, TX 75202-2733 ATTN: fS. Vivian Hare'(6W-EA0)

Dear Mr. Knudson:

Administrative Order Docket No. VI-89-317 NPDES Permit No. LA0042731 River Bend Station - Unit 1

. Gulf States Utilities Company (GSU) considers the violations cited in the

' Administrative . Order to be all isolated incidents. GSU regrets the violations and is confident that the actions and plans discussed in this

- letter 'are sufficient to prevent recurrence. Corrective actions and preventive measures are discussed in respect to the three outfalls involved.

At Outfall .001, " cooling tower blowdown," GSU failed to monitor flow continuously in June, 1988, and failed to monitor temperature continuously in January, 1989. In the former case a chart recorder unexpectedly ran out of paper and the problem went unnoticed for almost 22 days. The basic cause for this oversight was personnel error due to inexperience and lack _of attention.

The specific individual ' involved and other environmental personnel were l counseled and instructed to more frequently and carefully monitor the inventory of flow chart recorder paper. This corrective / preventive measure appears to have been effective, and we believe further measures are unnecessary. The loss of temperature data for a cumulative period of almost 10 days occurred when a chart recorder drive motor was accidentally turned off on two occasions by an inexperienced worker. Design of the recorder is L - such that the chart drive motor power switch can easily be unconsciously depressed any time chart replacement or adjustment is performed. With-extraneous noise and the slow rate of chart movement, it is not readily apparent that the drive motor is off unless one observes the chart for several- consecutive minutes or notes the position of the switch.

Environmental personnel were reminded of sensitivity of the switch and I. ,

instructed to ensure that the chart drive is operating properly after every l equipment check / adjustment. More recently, a warning note was conspicuously I. posted on the chart recorder door. GSU believes that these measures are sufficient to prevent further inadvertent switching off of the chart drive.

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. Knudson Page 2 At Outfall 004, " treated sanitary waste from power station," a bypass occurred due to rainwater intrusion on June 28, 1989. The bulk of the bypass, 7,833 gallons, was partially treated in extended aeration package plants but did not traverse the tertiary sand filter. An estimated 1,000 gallons (worst case) of raw sanitary wastewater bypassed the system entirely.

The partially-treated effluent contained 312 mg/l of total suspended solids (TSS) in violation of the daily maximum limit of 45 mg/1. This excursion, of about 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> duration, also resulted in a calculated daily average TSS for June of 80 mg/l in violation of the limit of 30 mg/1. These two violations, related to a grab sample representing the same bypass incident, are the only TSS problems we have had at Outfall 004 (and its precursor under the previous l permit)sinceJanuary,1984. That is, out of at least 40 million gallons of wastewater released through 004 over a 5.7 year period, fewer than 8,000 gallons are known to have exceeded TSS limits. The stormwater that caused the June 28 bypass (and contributed much to the high TSS level in the form of j silt) gained access mainly by inundation of two orifices in sewer lines which had been disconnected from temporary station construction facilities. Both openings were temporarily plugged on the day of the bypass. A few weeks later the orifices were permanently plugged and an extensive search for other existing /possible sources of intrusion was completed. There now appear to be no pathways for intrusion of significant quantities of stormwater into.the

. treatment system at Outfall 004.

At Outfall 005, " treated sanitary waste from the Training Center to Grants Bayou," a bypass occurred on June 28, 1989, when an estimated 30,00D gallons of effluent overflowed from a 0.25-acre facultative/ anaerobic polishing pond.

This partially treated wastewater contained 111.2 mg/l TSS in violation of the daily maximum limit of 45 mg/1. The 5-hour excursion also resulted in a calculated daily average TSS for June of 82 mg/l in violation of the 30 mg/l limit. The bypass was caused by stormwater from an early morning deluge after several days of wet weather associated with Tropical Depression Allison. Runoff from the adjacent slope is normally shunted around the pond, but the diversion ditches were inadequate to handle such extreme storm events as that of June 28 especially with the soil saturated and receiving streams swollen from previous rains. Engineers have determined that very limited improvement in runoff diversion capacity is feasible. This and other problems with reliability of the performance of the treatment system have led to a decision to abandon Outfall 005 as soon as re-routing of the wastewater can be designed, permitted and installed. The present conceptual plan is to re-route sanitary waste from our Training Center and the nearby Employee Relations Building more than mile to the system which discharges through Outfall 004. Negotiations are underway for the design contract with a target for design work to be completed by the end of the year. Once sufficient design information has been developed, we will file applications for appropriate changes in the NPDES and Louisiana Water Discharge permits. GSU expects this schedule to result in ultimate closure of Outfall 005 sometime in mid- to late 1990. In the meantime, GSU plans to discharge through 0utfall 005 only intermittently in an effort to minimize possibilities of TSS problems due to pond algae and problems with state permit chlorine limits due to erratic flows.

.U

. : ,3 Knudson Page 3

'I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. . Based on my inquiry of the person or persons who manage the system, or those persons directly responsible. for gathering the information 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,

. f. Yb/

J. E. Booker Manager-River Bend Oversight River Bend Nuclear Group JEB/LAE/RJK/JWC/JVC/ch cc: Mr. Tom Killeen Enforcement Program Manager Louisiana Department of Environmental Quality P. O. Box 44091, Capitol Station Baton Rouge, LA 70804-4091 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555  :

U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 NRC Resident Inspector Post Office Box 1051 St. Francisville, LA 70775

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