ML070450139
| ML070450139 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/06/2007 |
| From: | Faggert P Dominion Resources Services |
| To: | Mack S Office of Nuclear Reactor Regulation, State of VA, Dept of Environmental Quality |
| References | |
| Download: ML070450139 (18) | |
Text
Pamela F. Faggert Vice President and Chief Environmental Officer Dominion Resources Services, Inc.
5000 Dominion Boulevard, Glen Allen, Virginia 23060 Phone: 804-273-3467 February 6, 2007 CERTIFIED MAIL RETURN RECEIPT REQUESTED Sharon Mack, Environmental Specialist, II Department of Environmental Quality Northern Virginia Regional Office 139001b Crown Court Woodbridge, VA 22193 RE: NORTH ANNA POWER PLANT: RESPONSE TO DECEMBER 2006 SEWAGE TREATMENT PLANT INSPECTION: PERMIT NO. VA0052451
Dear Ms. Mack,
This is in response to the January 4th and 8th, 2007, Department of Environmental Quality inspection reports for the subject site. In the January 4, 2007, inspection report, the agency recommended North Anna nuclear plant continue the Environmental System Services, LTD (ESS) study, which is designed to address the elevated ammonia concentrations detected in the sewage treatment plant effluent. North Anna nuclear plant will continue the on-going study.
Additionally, the plant will inform the Department of Environmental Quality of the conclusions of the study and actions the station initiates to address the sewage treatment plant effluent issue.
As requested, a copy of the December 15, 2006 ESS survey report is enclosed.
In the January 8, 2007, inspection report, the agency noted four deficiencies regarding calibration issues for the pH meter and equipment thermometer as well as issues regarding the oil and grease analysis. Although not requested to be reviewed, the information provided below was available during the December 5, 2006 agency inspection.
The responses are listed in the order presented in the January 8, 2007, inspection report.
- 1. No temperature correction factor on NQC thermometers in use:
Calibration checks are performed by the Metrology Laboratory on site against an NQC thermometer. If a test thermometer does not meet the acceptance criteria (+/- 0.5 degrees) it is taken out of service. As a result, no temperature correction factor is required.
- 2. No temperature correction factor for the pH meter:
The temperature probe on the pH meter is compared quarterly with an NQC thermometer. If the probe does not meet the acceptance criteria (as above) it is replaced. Therefore, no temperature correction factor is required.
c~co
- 3. The Oil and Grease procedure directs the use of 1 gram of sodium sulfate instead of 10 grams:
This is a typo in the procedure. Station personnel use ten grams in the analysis. The procedure is in the process of being corrected.
- 4. For the Oil and Grease analysis, a solvent blank is neither run with the samples nor factored in the calculation:
This finding is not accurate. The station does have a procedure that requires personnel to run a solvent blank when a new bottle of Freon is opened (Procedure attached - Only pages 7 and 8 of 13 address the blank analysis). Personnel track this activity on the Oil and Grease worksheet (Worksheet attached). As long as the blank results average less than 5.0 mg/L, no further adjustments are made to the sample calculation.
If you have any questions or need additional information, please do not hesitate to contact Annette Christian at 804-273-2988.
Sincerely, Pamela F. Faggert Enclosures ec: Sharon Mack e-mail: smmack@deq.virginia.gov
cc:
U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 RE: North Anna Units 1 and 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RE: North Anna Units 1 and 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 Mr. James T. Reece NRC Senior Resident Inspector North Anna Power Station
OIL AND GREASE PROCEDURE
)v IRGINIA POWER CtI-72,G 10 NORTH ANNA POWER STATION REVISION 7 PAGE 7 OF 13 6.0 INSTRUCTIONS 6.1 Preparing R Fluorocarbon-113 Reagent Blank for a New Lot 6 1.1 Run two solvent blanks to determine residue for each new bottle of fluorocarbon- 113 before use, if applicable.
- 6. 1.2 Tare a pre-dried boiling flask that was previously stored in desiccator. Record weight.
6 1i3 Pour 90 uiL of the new lot of fluorocarbon 113 into a boiliiig flask.
6.1 .4 1"o maximize solvent recovery, do the following
- a. Fit boiling flask with a distillation adapter equipped with a drip tube
- h. Collect solvent in an ice bath.
6.1.5 Distill solvent from flask in a water bath at 70 'C.
6.1.6 WHEN the flask appears dry, JJŽI do the following:
- a. Remove the distillation adapter.
- b. Insern a glass tube connected to vacuum source into the flask and Sweep out the flask for one minute.
- c. Remove flask .from water and wipe hc outside of tle flask to rerrove excess moisture and fingerprinns.
- d. Place flask in desiccator.
VIRGINIA POWER CH-72.GI O NORTH ANNA POWER STATION REVISION 7 PAGE 8 OF 13 6.1.7 )YUN at least 30 minutes has elapsed, THE do the following:
- a. Remove and weigh flask.
- b. Record the weight on QCC log.
- c. Return the flask to the desiccator 6.1.8 Repeat Step 6.1.7 until two successive weights are within 0.5 mrg.
6.1.9 Repeat Steps 6.1.2 through 6.1.8 for duplicate blanks.
6,1.10 Average fluorocarbon-I 13 blanks. The following applies;
- a. Results must be less than 5.0 mng/L.
- b. Negative numbers indicate unacceptable results.
- c. If unacceptable results ame obtained, THEN check with Chemistry supervision for the disposition of the unsuitable fluorocarbon-] 13 lot.
6.1.11 Log the acceptable fluorocarbon-i 13 blank value.
6.2 Collecting Samples 6.2.1 Ensure wide mouth glass bottle has been rinsed with solvent.
6 2.2 Collect about I liter representative grab sample in a clean wide mouth glass bottle, taking care not to overfill the sample container.
6.2.3 Mark sample bottle at water meniscus for later determination of sample volume.
OIL AND GREASE WORKSHEET
" i-*28-04 QC&6 6 6 OGB OIL AND GREASE BLANX WORKSHEET Method CH-72.Gl0 Average of duplicate blanks must be less than or equal 5 mg/l.
Oil and grease - mg/l = [(A-B)*I.OE6]/V Where A= final weight of boiling flasX(grams)
B= initial weight of boiling flask(grams)
V= volume of sample filtered (milliliters)
ENVIRONMENTAL SYSTEM SERVICES, Ltd STUDY ESS2 Vrnmenmaf9.5sem$ Semvc Ltd WASTEWATER CHARACTERISTICS SURVEY Dominion Generation North Anna Nuclear Power Station Louisa County, VA Prepared By:
Environmental System Services 218 N, Main St. Culpeper Va. 22701
Contact:
Donald F. Hearl Phone: (540)825-6660 E-mail: donh@ess-services.com Date: December 15, 2006 218 North Main Street
- P.O. Box 520* Culpeper, Virginia 22701-0520* Telephone 540-825-6660* Fax 540-825-4961
Page 2 of 4 Introduction Environmental System Services (ESS) was contracted to provide field sampling and analytical services to identify wastewater characteristics for several waste streams entering the onsite wastewater treatment facility. Grab Samples from five sources were collected on September 18, 2006. The primary objective of this survey was to provide insight to the source of high strength wastewater (primarily nitrogen and phosphorous),
entering the treatment system.
Background
Elevated nitrogen and phosphorous concentrations, above levels typically encountered in domestic wastewater, have been detected entering the wastewater treatment facility.
Dominion Generation is concerned that nitrogen and phosphorus concentrations in the range noted could require modifications or additions to the current wastewater treatment facility in order to comply with future water quality standards. A pro-active approach has been chosen to identify and address these contaminants of concern. The first step in the process of implementing treatment or process modifications requires a thorough understanding of the nature and source of contaminants entering the treatment collection system. During a meeting held between Dominion Generation and ESS it was concluded that a comprehensive wastewater characterization survey was the most appropriate course of action. ESS and Dominion Generation devised a plan of action to accomplish this objective.
Methodology Five point sources throughout the power station complex were identified as capable of providing representative sampling sites for the types and quantities of typical wastewater discharges to wastewater treatment plant. These were identified as the following:
" Plant Influent
" Cafeteria Power Station
" Process Discharge
- Building 58 Power Station
" SGRP Power station Based on past experience with typical constituents entering the wastewater treatment plant, the following sample parameters were selected:
- Biochemical Oxygen Demand (BOD)
" Nitrite and Nitrate (N02 and N03)
" Total Kjeldhal Nitrogen (TKN)
" Ammonia, as N (NH3)
" Total Phosphorous (Phos. T)
- Total Alkalinity (ALK T)
Discussion Pre-labeled sample containers and chain of custody forms were prepared by ESS for each sampling site. Samples were collected by an ESS field technician using a long handled dipper specially designed for the purpose. Samples requiring preservation were placed in containers with the appropriate preservative. Special attention was directed toward idefitifying unusual physical characteristics of the wastewater samples; specifically color, odor, and other indicators. Specific details regarding sampling locations, procedures, and noted characteristics are presented below.
Wastewater Treatment PlantInfluent A grab sample was collected from the flow control box used to regulate influent feed rate.
A distinct odor of hydrogen sulfide was noted. Color was noted as being darker than typical raw wastewater. Ammonia odor was also detected. Test data confirm that concentrations for TKN, nitrite/nitrate and ammonia all exceed typical raw wastewater concentration levels. In addition, the BOD concentration was double the expected level.
See Table.
Wastewater Treatment PlantProcessDischarge Water clarity appeared normal with no perceptible color or odor. The Nitrite (N02) and Nitrate (N03) were both well above normal plant discharge concentrations. This condition indicates that high concentrations of bio-degradable and nitrogenous compounds are entering the wastewater treatment plant. These compounds are being stabilized and converted to Nitrite and Nitrate (N02/NO3) by a very active nitrification process within the aeration basins. In addition to elevated nitrogen compound concentrations, the phosphorus concentration exceeds typical discharge levels two to three fold.
CafeteriaPump Station Odor and color were considered typical at this location; however the BOD concentration was approximately four and a half times a normal concentration of 300 mg/L. Ammonia and Phosphorous concentrations were within the normal range.
Building 58 Pump Station A strong septic odor was noted, and the wastewater appeared much darker than normal raw sewage. This condition is usually the result of extended retention time and lack of dissolved oxygen within collection system and in the pump station. Under these conditions organics are converted to ammonia and other nitrogen compounds.
Phosphorous was also noted as being elevated at this location.
Building SGRP Pump Station The sample exhibited a strong septic odor and dark color. Sample results confirmed higher concentrations of BOD, TKN, and Phosphorous. In addition the alkalinity concentration was noted as being unusually high. This could be attributed to potable water characteristics in this area of the facility. This condition could be influenced by potable water conditioning equipment, creating elevated alkalinity levels. The strong
Page 4 of 4 septic odor is most probably the result of extended retention time within the sewage pimp station.
Conclusion Based on field observations and sample data it can be concluded that a significant quantity of nitrogen and phosphorous compounds are entering the sewage collection.
Additionally several of the point sources sampled exhibited elevated concentrations of BOD which indicates of high levels of bio-degradable organics.
Recommendations The source of nitrogen and phosphorus compounds must be traced to more specific points of origin. The reactions occurring within the collection system, attributable to extended retention times, are clearly contributing to the elevated levels of ammonia nitrogen entering the wastewater treatment facility. ESS recommends additional sampling at pump station locations to confirm the continuing presence of septic conditions and elevated nitrogen and phosphorus concentrations.
In order to efficiently remove nitrogen and phosphorous from the wastewater treatment plant effluent a pilot study is recommended. This bench scale approach will provide valuable insight into the capabilities of the existing treatment system design.
Additionally, results from bench testing will assist Dominion Generation in the decision making process related to treatment system modifications and installation of additional equipment. ESS is prepared to proceed with additional sampling and bench testing following receipt of the authorization to proceed from Dominion Generation.
Dominion Generation North Anna Nuclear Power Plant Loiusa, Va.
Sampled By: Donald Hearl (All Parameters shown as Mg/L)
Sample Date: September, 18 2006 TKN Ammonia, as N Total Phosphorous Alkalinity Sample Point BOD Nitrite/Nitrate 79.8 60.4 12.2 261 Plant Influent 520 42.8 92.6 4.46 0.69 13.4 136 Process Discharge 10 0.04 22.3 3.77 6.22 <2 Cafeteria PS 1340 0.03 95.6 87.4 13.7 335 Building 58 PS 325
<0.02 168 0.1 16.9 641 SGRP PS 569
ENVIRONMENTAL SYSTEMS SERVICE, LTD.
APEd Page:
Work Order # 65210 Contract #: @0/48 Customer #: 1703 Customer PO #: 70002765 DOMINION GENERATION ATTN: MR. DON HUFFMAN Job Location: WWTP - NORTH ANNA P. 0. BOX 402 Collected by: DON HEARL MINERAL, VA 23117 Date Received: 09/18/2006
.A .. ...... s S
- TAG #: SAMPLE POINT: SAMPLE DATE:
62448 PLANT INFLUENT 09/18/2006 Description Result Unit Rpt. Limit Method Anlys Date Time Init Biochemical Oxygen Demand 520 mg/I 2 SM 5210 09/19/.06 16:50 TA Nitrite + Nitrate 42.8 mg/l 0.02 SM 4500N03E 09/22/06 16:57 MFS Total Kjeldahl Nitrogen 79.8 mg/I 0.10 SM 4500NB 09/20/06 09:15 PH Ammonia, as N 60.4 mg/I 0.10 Sh 4500UH3D 09/18/06 10:30 PH Total Phosphorus 12.2 mg/l 0.05 SM 4500PBE 09/22/06 11:00 JI Alkalinity, Total 261 mg/I 2 SM 2320B 09/21/06 11:00 JI TAG #: SAMPLE POINT: SAMPLE DATE:
62449 CAFETERIA-PS 09/18/2006 Description Result Unit Rpt. Limit Method Anlys Date Time Init Biochemical Oxygen Demand 1,340 mg/I 2 SM 5210 09/19/06 16:58 TA Nitrite + Nitrate 0.04 mg/I 0.02 SM 4500N03E 09/22/06 16:57 MFS Total Kjeldahl Nitrogen 22.3 mg/I 0.10 SM 4500NB 09/20/06 09:15 PH Ammonia, as N 3.77 mg/I 0.10 SM 4500NH3D 09/18/06 10:30 PH Total Phosphorus 6.22 mg/I 0.05 SM 4500PBE 09/22/06 11:00 J1 Alkalinity, Total <2 mg/l 2 SM 2320B 09/21/06 11:00 JI TAG #: SAMPLE POINT: SAMPLE DATE:
Reviewed by: )/
Es- LAB SERVICES Report Date: October 03, 2006 VA LAB ID# 00115 218:NORTH MAIN STREET
- PO BOX 520
- CULPEPER .VIRGINIA 22701 :* 540-825-6660
ENVIRONMENTAL SYSTEMS SERVICE, LTD.
Page: 2 Work Order #: 65210 Contract #: 00/48 Customer #: 1703 Customer PO #: 70002765 DOMINION GENERATION ATTN: MR. DON HUFFMAN Job Location: WWTP - NORTH ANNA P, 0. BOX 402 Collected by: DON HEARL MINERAL, VA 23117 Date Received: 09/18/2006
-- - -- - -- - -- - --- -- - - - - - - - - - - - - - - - - - - - - - ---- -II -------
Description Result Unit Rpt. Limit Method Anlys Date Time init 62450 PROCESS DISCHARGE 09/18/2006 Description Result Unit Rpt. Limit Method Anlys Date Time Init Biochemical Oxygen Demand 10 mg/l 2 SM 5210 09/19/06 16:54 TA Nitrite + Nitrate 92.6 mg/l 0.02 SM 4500ON03E 09/22/06 16:57 MFS Total Kjeldahl Nitrogen 4.46 mg/i 0.10 SM 4500NB 09/20/06 09:15 PH Ammonia, as N 0,69 mg/l 0.10 SM 4500NH3D 09/18/06 10:30 PH Total Phosphorus 13.4 mg/l 0.05 SM 4500PBE 09/29/06 13:00 JI Alkalinity, Total 136 mg/i 2 SM 2320B 09/21/06 11:00 JI TAG #: SAMPLE POINT: SAMPLE DATE:
62451 BUILDING 58-PS 09/18/2006 Description Result Unit Rpt. Limit Method Anlys Date Time Init Biochemical Oxygen Demand 325 mg/l SM 5210 09/19/06 17:00 TA Nitrite t Nitrate 0.03 mgl. 0.02 SM 4500N03E 09/22/06 16:57 MFS Total Kjeldahl Nitrogen 95.6 mg/i 0.10 SM 4500NB 09/20/06 09:15 PH Ammonia, as N 87.4 mg/l 0.10 SM 4500NH3D 09/18/06 10:30 PH Total Phosphorus 13.7 mg/l 0.05 SM 4500PBE 09/22/06 11:00 JI Alkalinity, Total 335 mg/l 2 SM 2320B 09/21/06 11:00 JI TAG #: SAMPLE POINT: SAMPLE DATE:
Reviewed by:_
ESS LAB SERVICES Report Date: October 03, 2006 VA LAB ID# 00115
.21,+8NORTI11,MAIN STREET* TOP BOX 520 *: .CULPEPER,. `VIRGINIA 22701 *; 5.4*.0-825-6660
ENVIRONMENTAL SYSTEMS SERVICE, LTD.
Q FflurCflgCfl(SflSMCU Page Work Order #: 65210 Contract #! 00/48 Customer #: 1703 Customer PO #t 70002765 DOMINION GENERATION ATTN: MR, DON HUFFMAN Job Location: WWTP - NORTH ANNA P. 0. BOX 402 Collected by: DON HEARL MINERAL, VA 23117 Date Received: 09/18/2006 Description Result Unit Rpt. Limit Method Anlys Date Time Init 62452 SGRP-PS 09/18/2006 Description Result Unit Rpt. Limit Method Anlys Date Time Init Biochemical Oxygen Demand 569 mg/i 2 SM 5210 09/19/06 17:07 TA Nitrite + Nitrate <0.02 mg/l 0.02 SM 4500N03E 09/22/06 16:57 MFS Total Kjeldahl Nitrogen 168 mg/i 0.10 SM 4500MB 09/20/06 09:15 PH Ammonia, as N 133 mg/i 0.10 SM 4500NH3D 09/18/06 10:30 PH Total Phosphorus 16.9 mg/l 0.05 SM 4500PBE 09/22/06 11:00 31 Alkalinity, Total 641 mg/i 2 SM 2320B 09/21/06 11:00 JI Reviewed by:
ESS LAB SERVICES Report Date: October 03, 2006 VA LAB ID# 00115
.218 NORTL.IMAIN STREET,: ,P BO5520 'CULPEPER,- VIRGINIA '-2270' 40,5 25-6'60O
SAMPLE CHAIN OJ CUSTODY RECORD ENVIRONMENTAL SYSTEMS SERVICE, LTD.
Company "_oV"* 218 North Main St. 500 Stone St 8321 Leishear Road 3917 Westpoint Blvd.
Contact Post Office Box 520 Post Office Box 736 Laurel, MD 20723 Suite E Address " Culpeper, VA 22701 Bedford, VA 24523 Winston-Salem, NC 27103 Address )6'1\9*Ab ) B00-541-21 16 540-586-5413 301-617-9582 910-659-3378
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Yo 540-825-6660 Fax 540-586-5530 Project NamelSite A- a,-'0 4TP I n dc P.O.#
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R Date Time Received by: Relinquished by: Date Time Received by:
Relinquished by: Date Time Recived by: Relinquished by: Date Time Received for Laboratory by:
Method of Delivery Remarks: f n TAT "UPS C1 FedE Hand Delivery e dI Normal, Rush W.O.# _*ý.3a \0 Amt Paid $
Need Results by 0 UPS Overnight E0 Post Office E] Under 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Extra charges will apply for Rush TAT. W.O.# Check #
Revised 11/04/04
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