ML18059A528

Forwards non-radiological NPDES Permit Violation Rept for May-Oct 1993

ML18059A528
Person / Time
Site:	Palisades
Issue date:	11/17/1993
From:	Rogers D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9312020514
Download: ML18059A528 (7)

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consumers Power POWERINli M.ICHliiAN'S PIUlliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 November 17, 1993 Nuclear Regulatory Commission.

. Document Control Desk Washington, DC 20555 David W. Rogers Plant Safety and Licensing Director DOCKET 50-255 - LICENSE DPR PALISADES PLANT - NON-RADIOLOGICAL NPDES PERMIT VIOLATION REPORT - MAY THROUGH OCTOBER 1993 Section 3.2 of the Palisades Environmental Protection Plan (Non-Radiological) entitled, "Reporting Related to NPDES Permits and State Certifications,"

states that copies of reports to the State of Michigan indicating violations of NPDES permits sha 11 be sent to the NRC. - Our April 17, 1985 letter to the NRC states that we will comply with Sections 3.2 and 5.4.2 of Appendix B of the Palisades Technical Specifications, by submitting all NPDES permit violations and reports of Oil, Salt or Polluting Material loss, on a semi-annual ba.sis within 30 days from April 30 and Oct~ber 31.

During the period from May through October 1993, two NPDES State notifications were required and one report of Oil, Salt or Polluting Material loss was made.

The attachment to this letter contains a summary of the recent NPDES Permit activity and copies of the notifications sent to the State of Michigan.

David W. Rogers Plant Safety and Licensing Director Cc Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment 9312020514 931117 PDR ADOCK 05000255 p

PDR 260073 A CMS' ENERGY COMPANY I

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Attachment Consumers Power Company Palisades Plant Docket _50-255 NON-RADIOLOGICAL NPDES PERMIT VIOLATION REPORT MAY 1993 THROUGH OCTOBER 1993 November 16, 1993 5 Pages

Non Radiological NPDES Permit Violation Report May 1, 1993 to October 31, 1993 NPDES NOTIFICATIONS During this period (May 1, 1993 to October 31, 1993) there were two NPDES notifications reported to the Michigan Department of Natural Resources (MDNR).

The.reported incid~nts are destribed as follows:

1.

On August 12, 1993 at 0020 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> during continuous chlorination of the service water system, the plant exceeded the Total Residual Oxidant (TRO) concentration to Outfall 001. There were no unusual observations at Outfall 001 as a result of this NPDES violation.

2.

On August 31, 1993 and September 1, 1993 during initial start-up of Palisades groundwater remediation system, the plant exceeded the NPDES purgeable halocarbon limit for Trichloroethane {TCE} and Tetrachlorethane (PCE}.

The Palisades groundwater remediation system is a temporary installation designed to remov~ halocarbons.from a groundwater plume near the north end of the plant ~ite. The following values were obta~ned:

August 31, 1993 September 1, 1993 20.9 ppb PCE 8.2 ppb 19.1 ppb The PCE results exceeded the NPDES limit of 3 ppb for both.days.

The TCE NPDES limit of 10 ppb was exceeded on September 1, 1993 (only}.

The NPDES limits were exceeded due to the initial start-up of the grciuhdwater remediation system.

The specific causes of exceeding the limits are:

a.

High back pressure from the Soil Vapor Extraction (SVE) Unit restricted air flow from the air stripper tower, resulting in lower operating efficiency of the air stripper tower.

At this lower

_efficiency less halocarbon is removed from the process stream.

b; No ~ater level had been maintained in the air stripper tower sump-which allowed air to escape through the air stripper tower water discharge.. This again resulted in a lower efficiency of the air stripper tower.

The two problems were corrected on September 1, 1993.

• The high back pressure was resolved by restricting the air flow from the SVE unit. A water level was maintained in the air stripper tower sump by partially restricting the water discharge from the sump.

The NPDES notification reports to MDNR. for both NPDES violations are attached.

OIL, SALT; or POLLUTING MATERIAL LOSS During the same time period, there was one report of oil, salt or polluting material loss. There was a loss of approximately 100 gallons of sewage to the ground on October 2s; 1993. A copy of the notification to MDNR is attached.

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OTHER ACTIVITIES Other activities which may be of interest pertaining to water quality are summarized below:

I. Pali sades submitted a Permit Renewal Application for NPDES Permit MI0001457 to MDNR on April 2, 1993. This NPDES permit was to expire on October 1, 1993 but remains in effect until a new NPDES permit is issued.

2.

Palisades received permission from MDNR on June 7, 1993 to use Betz Pal-02, an anti-sealant, in th~ circulating water system.

At the average dosage rate of 0.12 ppm and maximum dosage of 0.35 ppm this product should.

not have any adverse effects on the receiving waters.

3.

Palisades received permission to discharge component cooling water

• containing sodium nitrites to the *receiving water via Outfall 001 during periodic maint~n~nce of the component cooling water heat exchangers. This approval was granted to the plant on June 7, 1993.

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FILE NO:

Pl0.2.1 INCIDENT NO: PAL-93-08-NC136 UFI NO: 950*72*40*05/3 Yrs

. NPDES NOTIFICATION Apparent Difference From Daily Maximum Limitation Plant:

Palisades,.

Pennit No:

Ml 0001457 Outfall

Description:

Mixing Basin Discharge Outfall No:

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Parameter: Total Residual Oxidant CTROl P~rameter Code No: 50060-P

1. Date of Incident:

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2.

Identification of Specific. Effluent Limitation or Monitoring Requirement 1

Affected:

Daily maximum limit of 36 ug/1 total *residual oxidant (TRO) applicable to continuous discharge (greater than 120 min/day).

3. Description of Incident:

During a routine continuous chlorination of the Palisades service water system on 8/12/93 at 0020 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, a TRO concentration of 80 ug/l was

• measured.

4. Apparent Cause:

Apparent internal miscommunication. Apparently the continuous chlorination of the service water system was initiated without starting the feed of dehalogenation chemical, sodium bisulfite.

5.

If not immediately corrected, the anticipated time the condition is

• expected to continue:

Continuous chlorination was initiated at 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br /> on 8/11/93.

The sodium bisulfite feed was started at 0018 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> on 8/12/93. This was a one-time event not expected to be repeated.

G; Corrective Action - The following corrective, action was taken or will be taken to reduce, eliminate and prevent recurrence:

As discussed under item No. 5 above, the sodium bisulfite feed was started immediately upon the discovery-that continuous chlorination had been initiated (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 18 minutes elapsed time). A TRO measurement of Outfall 001 *at 0020 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> on 8/12/93 measured 80 ppb; by 0115 hours0.00133 days <br />0.0319 hours <br />1.901455e-4 weeks <br />4.37575e-5 months <br /> the same day, the TRO level had.dropped below the level of detection at <20 ppb.

Secondly, this matter will be thoroughly reviewed with the Plant's Chemistry Technicians and appropriate Plant operations personnel.

7.

Additional Comments:

11 Visual observations of the plant's mlxrng b,asin and Outfall 001 discharge to Lake Michigan showed no adverse effect on aquatic ~*

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FILE NO:

PlO.Z.l INCIDENT NO:. PAL RAP-93-08/09-NCOl UFI NO:

950*72*40*05/3* Yrs NPDES NOTIFICATION Apparent Differe~ce From Daily Maximum Limitation Plant: Paljsades - Fuel Depot Groundwater Permit No:

Ml 0049131 Remediation Project Outfall

Description:

Storm Drain Dischargeo Outfall -No:.:,;00=1=--------

Parameter:.Trichloroethene CTCEl Parameter Code No:

Tetrachloroethene CPCEl

• 1. Date of Incident: August 31. 1993 and September 1. 1993

. 2.

Identification of* Specific Effluent Limitation-* or-Monitoring Requirement Affected:

Daily maximum limit of 10 pg/l Tr.ichloroethene (TCE)- and 3 pg/l Tetra-chloroethene (PCE)

3. Description of Incident:

• During initial start-up and testing of the Palisade~ groundwater remediation system for the fuel depot site, a* ICE concentration of 20.9

µg/l was measured on 9/01/93, and PCEconcentration~ or 8.2 µg/l and 19.1

µg/1 were measured on 8/31/93 and 9/01/93*,. respectively.

4. Apparent Cause:

High air flow.and discharge pressure from the soil vapor extraction (SVE) vacuum pump restricted external air flow* from* the air stripper tower blower.

In addition, some of the SVE air* was. escaping through the tower sump discharge line due to insufficient water-level in* the sump.

Both conditions combined to reduce the tower's. efficiency in removing the ICE and PCE from the groundwater.

5. If not iR111ediately corrected, the anticipated time-the condition is expected to continue:

The SVE unit was inmediately turned off and temporary equipment

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• adjustments were made to increase the external air* flow through the tower

• by partially closing the discharge valves from* the SVE vacuum pump and the.

tower sump. After the system was restarted on 9/02/93, the concentration of TCE and PCE in the discharge was measured at 1.1 pg/l and 0.5 µg/l, respectively. This verified that the temporary adjustments were appro-priate.

00993-02.DAO/MLP

State. of* Mt chi gan Department of Natural Resources REPORT OF OIL. SALT OR POLLUTING MATERIAL LOSSES SPCC/PIPP

• Appendix F Revision 7 Page 1 of 1 Pursuant to the provis.ions of Act 245 of the.Public Acts of Michigan 1929 as amended, regulations have been issued which require that all Owners, Managers or Operators of* vessels, oil storage. or on land/facilities shall notify the Water Resources Carmission or his authorized representative of oil, salk and polluting material losses. This notification shall be made pranptly by telephone* or* telegraph; giving briefly the particulars, and by mail, giving a detailed account of* events and conditions.

Date Company.Name 10 - 2.5 _, 'i3 Consumers Power Company Location of Loss (Be Specific)

Ct:<..>f-of' reed wa_kr p(,{J'I* '7 B Id 9 Palisades Nuclear Plant Material Lost Amount Name' of Surface Water. Involved

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'"V 100 9 a II c:l"n.S n Dl/l 'e..I Date Loss was Discovered Time of Discovery cJ c /-v I:> -u-ZS/ J99..3 I 2-0 c)

Name of Department of Natural Resources Representative Contacted.

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Telephoned or Telegraphed by Whom Ttme A,...Jta..o~ A Ca/ /o t.JU.. '7 1330 Cause of Loss (include Type if Equipment and Other* Details)

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Nature of Loss (include Canplete Description of Damage)

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Canpany Name Consumers Power Company Return this form to: Enviro1111ental Department Parnall Road CC; KMHaas JHager Jackson, Michigan DCC: 950/72*40*11 x72*40*12/5D By Signature*

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24 Hours Emergency Notification Nllli>er:

(800) 292-4706 I

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