ML18153A117
| ML18153A117 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 03/19/1997 |
| From: | Hadder A VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Steward R VIRGINIA, COMMONWEALTH OF |
| References | |
| NUDOCS 9703250234 | |
| Download: ML18153A117 (15) | |
Text
CERTIFIED MAIL RETURN RECEIPTREOUESTED.
March 19, 1997 Mr. Roger Steward Virginia Department of Environmental Quality OWRM-WQAP P. 0. Box 10009 629 E. Main Street Richmond, VA 23240-0009 RE:
DMR-QA RESULTS FOR VIRGINIA POWER FACILITIES
Dear Mr. Steward:
Post Office Box 26666 Richmond, Virginia 23261 60 *-~So /!JB/
. 56- ~c¥8/33Cj v,RGIN/A POWER We have carefully evaluated the data contained in the Discharge Monitoring Report-Quality Assurance (DMR-QA) report dated January 6, 1997, where results were judged to be unacceptable.
A.check was made at each facility for potential sources of error and we have determined the following:
Bath County Power Station (Permit No. V A0053317)
After review of the laboratory procedures and Quality Control program for Non-Filterable Residue, no obvious problems were indicated. The laboratory will perform additional blind samples to ensure data quality and integrity.
Fathead Minnow acute toxicity testing was performed by Coastal Bioanalysts, Inc. (CBI).
Corrective action for this test is detailed in the attached four letters from Dr. Peter F. DeLisle, of CBI, and the EPA.
Bremo Power Station (Permit No. V A00533 l 7)
A review was performed for the Non-Filterable Residue testing. The suspected problems were in the preparation of the blind sample. The analyst noted that the material did not disperse evenly and floated on 1:1:!e top. No surfactant was added to the sample as suggested in the preparation sheet. The laboratory will check into use of a surfactant for future standards.
Fathead Minnow acute toxicity testing was performed by Coastal Bioanalysts, Inc. (CBI).
Corrective action for this test is detailed in the attached four letters from Dr. Peter F. DeLisle, of CBI, and the EPA.
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Mr. Roger Steward
., March 18, 1997
'Page2 Chesapeake Energy Center (Permit No. YA0004081)
Total Phosphorus was performed by the Virginia Power System Laboratory. The typical range for samples analyzed at our lab is below 0.50 mg/L. The calibration curve is prepared from 0.01-to 0.50 mg/L.
The EPA blind sample had to be diluted within our operating range. A series of dilutions was analyzed with results ranging from 3.05 mg/L to 4.0 mg/L. The 3.50 dilution was within our working range and thought to best match our sample range. APG blind performance
- standards for WV certification were also analyzed at this time. These standards also required dilution but final results fell within acceptance limits.
Acceptance Reported Ref. Value Mean Std. Dev.
Range APGConc.1 1.45 1.279 1.235 0.221 0.664-1.807 APGConc. 2 18.75 16.91 16.856 1.551 12.855-20.859 The problem with the Total Phosphorous test was with the choice of dilution. In future analyses additional dilutions will be used for out of range samples and blinds.
Chesterfield Power Station (Permit No. V A0004146)
The QA TRC sample was prepared and analyzed according to the EPA's enclosed instruction. The sample was analyzed with two different analyzers. Each analyzer gave a reported value of.53 ppm TRC.
The expiration date on the Hach powder pillows is 5/99.
The lab performs and documents pH checks on the chlorine test at each outfall on an annual basis. This check has shown that the Hach powder pillow is sufficient to ensure proper pH limits in any chlorine tested sample.
In 1997 Chesterfield plans on enrolling laboratory personnel in Virginia's DEQ laboratory workshops on Total Residual Chlorine.
The analyst did everything according to all instructions.
Chesterfield lab personnel will continue to self assess all procedures, and sample handling.
Mr. Roger Steward
, March 18, 1997
'Page 3 See comments under Chesapeake Energy Center for information regarding the Total Phosphorous results.
Fathead Minnow acute toxicity testing was performed by Coastal Bioanalysts, Inc. (CBI).
Corrective action for this test is detailed in the attached four letters from Dr: Peter F. DeLisle, of CBI, and the EPA.
Clover Power Station (Permit No. V A0083097)
Fathead Minnow acute toxicity testing was performed by Coastal Bioanalysts, Inc. (CBI).
Corrective action for this test is detailed in the attached four letters from Dr. Peter F. DeLisle, of CBI, and the EPA.
North Anna Power Station (Permit No. VA0052451)
Fathead Minnow acute toxicity testing was performed by Coastal Bioanalysts, Inc. (CBI);
Corrective action for this test is detailed in the attached four letters from Dr. Peter F. DeLisle, of CBI, and the EPA.
Possum Point Power Station (Permit No. VA0002071)
Fathead Minnow acute toxicity testing was performed by Coastal Bioanalysts, Inc. (CBI).
Corrective action for this test is detailed in the attached four letters from Dr. Peter F. DeLisle, of CBI, and the EPA.
Surry Power Station (Permit No. V A0004090)
Following receipt of the DMR-QA sample results, the station laboratory analyzed another TSS blind sample which was procured by the Virginia Power System Laboratory from Environmental Resources Associates. The first sample was a 500 ml sample yielding 73.6 ppm. The analyst also ran a duplicate using 200 ml, which yielded 69.6 ppm. The true value stated by Environmental Resource Associates was 73.3 ppm with an acceptance range of62.3-84.3. Both of the station laboratory's results were well within the acceptance range.
The problem with the 1996 EPA analysis may be related to a problem experienced in the 1995 TSS analysis. Due to the heavy concentration of the sample in 1995 some plating out of solids occurred on the TSS funnel. The analyst folded the filter and wiped the inside edge of the funnel after filtration, per procedure. The analyst did not feel comfortable with this due to the possibility of losing solids during the transfer. The 1996 sample also seemed to be heavy with solids. To alleviate the problem, the analyst decided to run only 500 ml of sample, instead of 1000 ml. The analyst believes there was some difficulty with getting
Mr. RogerSteward
- Marcl1 18, 1997
'Page4 e
the solids in solution and transferring the sample from the volumetric flask to the graduated cylinder. The analyst anticipated a possible problem with the solids staying in solution, and was careful to mix the sample well before pouring off. The analyst thought the solids would sink quickly, so he sought to remedy this by pouring it very rapidly into the cylinder. If this was erroneous~ it would seem to make the results too high instead of too low. Unless the solids tended to float, which would decrease the results, the analyst knows of no other explanation for the low result.
The same analyst has performed the annual DMR-QA analyses for Surry Power Station since** * **
1990; all previous results have been within the acceptable range.
See comments under Chesapeake Energy Center for information regarding the Total Phosphorous results.
Yorktown Power Station (Permit No. V A0004 l 03)
See comments under Chesapeake Energy Center for information regarding the Total Phosphorous results.
Fathead Minnow acute toxicity testing was performed by Coastal Bioanalysts, Inc. (CBI).
Corrective action for this test is detailed in the attached four letters from Dr. Peter F. DeLisle, of CBI, and the EPA.
All Virginia Power laboratories take pride in their ability to perform accurate analyses contributing to the success of our VPDES program. An internal quality assurance program utilizing check samples three times per year is in place and we believe that this program assures that all of our laboratories are p~rforming with a high degree of precision and accuracy.
If you have additional suggestions of how to improve our programs, or if you have any questions regarding the information provided, please feel free to contact Mr. David Y aworsky of my staff at (804) 717-5901.
~/l!Lv A. W. Hadder
~
Manager Environmental Policy & Compliance Attachment
Mr.. Roger Steward
, March 18, 1997
- Page 5 cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW Suite 2900 Atlanta, GA 30323.
RE:
North Anna Units 1 and 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW Suite 2900 Atlanta, GA 30323 RE:
Surry Units 1 and 2 Docket Nos. 50-280/50-281 License Nos. DPR-32/DPR-37 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 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 RE:
Surry Units 1 and 2 Docket Nos. 50-280/50-281 License Nos. DPR-32/DPR-37 Mr. Russell Gibbs NRC Resident Inspector North Anna Power Station Mr.M. W.Branch NRC Senior Resident Inspector Surry Power Station
March 7, 1997 Mr. Ken Roller Virginia *Power Innsbrook 3 SW 5000 Dominion-Blvd Glen Allen, VA 23060
Dear Ken,
e Coastal Bioanalysts Inc.*
P.O. BOX 626 GLOUCESTER PT., VA. 23062
- PH. (804) 642 - 0168 In response to the "not acceptable 11 results reported by our lab for ~ethod code 11 (acute Pimepha/es prome/as, moderately hard synthetic freshwater, 20°c) in EPA DMR-QA Study 16, we have re-analyzed the original bench sheets and performed additional testing and research. I believe the following points will clarify the matter and confirm the ability of our laboratory to perform these tests.
- 1. The "true" value and acceptance limits are based on a bi-weighted mean and 95%
probability intervals, respectively, calculated from the reported data for all labs (Jim Lazorchak, EPA, personal communication). Therefore, there is always a 5% probability that a competent laboratory will report a value outside the limits, but the value would likely be close to the acceptance limit (see attached letter from Paul Britton, February 5, 1997). Because a) our value of 87.6% was very close to the upper acceptance limit of 85.6%, b) the lower 95% confidence limit (69.2%) of our LC50 value falls well within the EPA acceptance limits, and c) the reported fathead chronic data are very close or equal to the "true" values, this would seem to apply in our case.
- 2. In our DMR-QA test we used fish which were 9 days old; the EPA protocol allows the use offish from 1 to 14 days old(+/- 12 hr). Because we noted that fish in 100% and 50% concentrations were moribund at the end of the test, we wondered if the LC50 would have been significantly different if the animals had been even slightly*more sensitive (e.g. if younger fish were used). Also, because many laboratories do not maintain in-house cultures offish but instead rely on commercial suppliers which charge more (typically 15-25%) for older fish, we suspected the data set might be biased towards tests conducted with younger (i.e. less expensive) fish.
We discussed this matter with Jim Lazorchak of EPA-Cincinnati (1/30/97 phone conversation) who runs the technical aspect of the program. In that conversation he indicated that on the basis of phone calls he had received from other laboratories there did seem to be a relationship between fish age and test results and that it was his desire to perform a study to examine the effects of age, grow-out density, fish source, etc. on the
e EPADMR.-QAResponseMarch 7, 1997 Page2 of3 e
=,,_@coastal Bioanalysts Inc..
toxicity of Study 16 toxicant. He was not aware at that time that laboratories submitted to EPA information on test organism age (page 5 form EPA-421 (Cin) Rev 3-96) with the toxicity results and could not offer any quantitative information on this issue. An unusually high percentage (16%) of the labs fell out oflimits for method code 11 (see attached summary report PE-010) and because the lower acceptance-limit was the detection limit (6.25%, the lowest tested concentration) all labsi"alling out oflimits would have LC50s greater than the upper acceptance limit of85.6%. We have requested age and LC50 data for method code 11 to examine if the age of the fish selected by the laboratory was a determining factor in test performance. However, EPA will not be able to provide the data for several months (see attached letter of February 20, 1997 to Paul Britton and March 3, 1997 reply from Jim Lazorchak).
- 3.
Because of concern over whether the use of fish of differen~ ages might affect test acceptability, even though they are within the EPA-specified age range, we ran a series of tests with newly-obtained Study 16 toxicant in our lab. To rule out effects of organism source (i.e. our in-house cultures) we used fish from three sources: in-house cultures (CBI), Chesapeake Cultures, Inc. (CC, Hayes, VA) and Aquatic Bio-Systems, Inc. (ABS, Fort Collins, CO). Three age classes were tested: 1 or 2 days old, 7 days old, and 14 days old. Tests with CBI fish were run simultaneously with tests using fish from commercial suppliers. For each set oftests, solutions were prepared in a s4igle flask for all ages/sources to eliminate variability in test concentrations between groups. Dry weights of control fish were determined at the end of the test to determine whet_her any effects were related to organism weight which in tum can be presumed to relate somewhat to culture and/or grow-out conditions. The results of these tests appear in Table I.
(attached).
The 48-h LC50 is clearly related to the age of the fish. LC50s for 1-or 2-day-old fish and 7-day-old fish are significantly different (p=0.014, Student's t-Test). Because LC50s could not be calculated for 5 out of 6 of the tests with 14-day-old fish they*cannot be statistically compared to the other age classes but are obviously different. The LC50s for all of the tests with 1-or 2-day-old fish and 5 out of 6 of the tests with 7-day-old fish were within EPA acceptance limits. It was also noted in this study, like the test for DMR-QA study 16, that in tests with older fish (i.e. 7 and 14 days old) many fish were moribund across several concentrations at test end and response was more variable:
- Source of fish and fish weight did not have any consistent effect.
In summary, based on the data generated in our laboratory and the limited data available from EPA, the reason for the "unacceptable" results was that we were unlucky in choosing older fish to run the test. Had fish less than 7 days old been used the results would have been acceptable. In spite of this, because our value is so close to the upper
EPA DMR-QAResponse March 7, 1997 Page 3 of3 e
. = Coastal Bioanalysts Inc.
acceptance limit it would not be considered to be indicative of a laboratory problem based on EP A's interpretation of data from these studies.
If you have any questions or concerns please do *not hesitate to call.
-~ //y PeterF. De~h.D.
President Attachments
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY NATIONAL EXPOSURE RESEARCH LABORATORY CINCINNATI, OH 45268 February S, 1997 Reporting Toxicity Laboratories
Dear Toxicity Laboratory:
OFFICE OF RESEARCH AND DEVELOPMENT Thank you for sending a copy of your DMR.-QA Study 16 whole-effluenttoxicity results to the USEP A at the same time you sent it to your permittees. Your data were used in conjunction with data from other reporting laboratories to establish the study acceptance limits for the toxicity endpoints. Enclosed is a complementary copy of the Performance Evaluation Report on your data and a summary report which allows you to compare your performance to results for the entire study. Reported data were "usable,, whenever they were NOT less-than or greater-than values.
Acceptance limits for NOEC results were set at the median reported value plus and minus one dilution. Acceptance limits for all other endpoints were set statistically as 95% prediction intervals using robust statistical techniques, i.e., such intervals should contain 95% of the data reported by laboratories producing typical data. Since more than 92% of the reported data were within the acceptance limits, most laboratories would seem to be doing a good job. The 5% of data from competent laboratories that happened to fall outside the acceptance limits would tend to be close. Those interested in limits for endpoints they did not report can get them by calling Mantech at {919)406-2164.
Enclosures (2): As Stated.
Sincerely yours, Paul W. Britton, Statistician National Water Quality Assurance Programs Branch Ecological Exposure Research Division cc: Region and State DMR-QA Coordinators John Helm, USEPA, OECA, Mail Code 2225A, 401 M Street, S.W., Washington, DC 20460 James Lazorchak, USEP A, Room 642, 26 M.L.King Drive, Cincinnati, OH 45268 Ryan Boera, ManTech Env. Tech., P.O.Box 12313, 2 Triangle Drive, RTP, NC 27709 Paulette Yongue, ManTech Env. Tech., P.O.Box 12313, 2 Triangle Drive, RTP, NC 27709 Racycled/Recyclabl* *Printed with Vegetable OU Based Inks on 100'% Recycled Paper (40% Poslconsumer)
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Summary Report for All Participants DMR-QA Toxicity Study Number 016 Report: PE-010 Page:
1 Date:
22JAN97 Total
Participants:
278 True Value Results Reported Usable Accept.
Not Accept.
FATHEAD MINNOW ACUTE DATA AS % OF SAMPLE:
752-LC50 - MHSF,*20 DEG.
41.9 139 139 117 22 754-LC50 - MHSF, 25 DEG.
43.7 116 116 112 4
755-LC50 -
DMWi 25 DEG.
32.9 39 39 33 6
FATHEAD MINNOW CHRONIC DATA AS % OF SAMPLE:
756-SURVIVAL, NOEC - MHSF 25 160 160 160 0
757-GROWTHt IC25 -
MHSF 31.3 153 152 108 44 758-GROWTH, NOEC -
MHSF 25 160 155 149 6
759-SURVIVAL, NOEC -
DMW 25 35 35 34 1
760-GROWTH, IC25 -
DMW 50.3 29 28 27 1
761-GROWTH, NOEC -
DMW 25 35 34 33 1
CERIODAPHNIA ACUTE DATA AS % OF SAMPLE:
762-LC50 - MHSF, 20 DEG.
38.2 57 57 56 1
763-LC50 -
DMW, 20 DEG.
28.6 16 16 16 0
764-LC50 - MHSF, 25 DEG.
30.8 106 106 101 5
765-LC50 -
DMW, 25 DEG.
-25.2 50 50 46 4
CERIODAPHNIA CHRONIC DATA AS % OF SAMPLE:
766-SURVIVAL, NOEC -
MHSF 25 145
- 145 143 2
767-REPROD., IC25 -
MHSF
.
- 28. 2 141 141 120 21 768-REPROD., NOEC -
MHSF 25 145 141 133 8
769-SURVIVAL, NOEC -
DMW 12.5 58 57 57 0
770-REPROD., IC25 -
DMW 14.8 53 52 40 12 771-REPROD., NOEC -
DMW 12.5 58 55 54 l
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Coastal Bioanalysts Inc.
P.O. BOX 626 GLOUCESTER PT.. VA. 23062 PH. (804) 642 - 0168 February 20, 1997 Mr. Paul W. Britton Nat. Water Quality Assurance Programs Branch Ecological Exposure Research Division Cincinnati, OH 45268 Re: FOIA request
Dear Mr Britton:
The purpose of this letter is to make a FOIA request for some information relating to the DMR-QA Study 16 Toxicity tests. One set of our results was not acceptable and we need to respond to the state coordinator by March 14 with an explanation of the unacceptable results.
Based on some preliminary tests in our lab we believe there may be a significant relationship between fish age and LCSO for method code 11. Consequently, we would appreciate any information you could give us regarding several aspects of these tests. First, we request a breakdown of the method code 11 (MHSF 20°c Fathead acute) LC50s. We also request a breakdown of the fish ages used in this test as provided to EPA on page 5 of Form EPA-421 (Cin) Rev 3-96. If a data set is available with both the age and the LC50s (i.e. paired data)
. this would be particularly useful in interpreting why our value was out of bounds. We are not requesting laboratory identifications or results for other tests at this time.
If you have any questions, please do not hesitate to call either myself or Georgi Hyde at 804-642-0168.
Thank you for your help and information.
Sincerely,
~f;7U Peter F. De Lisle President
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY NATIONAL EXPOSURE RESEARCH LABORATORY CINCINNATI, OH 45268 March 3, 1997 Peter F. De Lisle, President Coastal Bioanalysts, Inc.
P.O. Box 626 Gloucester Point, Virginia 23062
Dear Mr. De Lisle:
OFFICE OF RESEARCH AND DEVELOPMENT In regard to your February 20, 1997 letter to Paul Britton, DMRQA-Coordinator, requesting information on the background analytical conditions reported with the results from the DMRQA-Toxicity Study 16 toxicity tests, we do not currently have the information you requested summarized nor will it be available by March 14, 1997.
We can send you the data once it has been summarized but we do not anticipate it being completed for several months.
Should you still be interested in these data, please let me know and we will mail the summary to you once it has been completed.
cc:
Paul Britton John Helm Susan Cormier Ray Wesselman Recycled/Recyclable* Printed with Vegetable 011 Based Inks on 100% Recycled Paper (40% Postconsumer)
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Table I..Relationship ofFish Age to LC50 Study 16, Method 11 Test Fish Age
- 48-h
% Survival in Dare Source (days)
LCSO (%)1 JOO% Cone 2/5/97 CBI 1
33.0 0
2/14/97 CBI 1
25.0 0
2/19/97 CBI 1
36.6 0
cc 1
23.3 0
2/26/96 CBI 2
22.3 0
ABS 2
37.3 5
2/19/97 CBI 7
85.7 40 cc 7
48.6 5
ABS 7
77.1 35 2/5/97 CBI 14
>100 65 2/14/97 CBI 14
>100 80 2/19/97 CBI 14
>100 80 cc 14 54.7 20 2/26/96 CBI 14
>100 70 ABS 14
>100 70 1 Mean LC50s and standard deviations:
1-or 2-day-old fish LC50 = 26.7 S.D. = 6.56 7-day-old fish LC50 = 56.5 S.D. = 20.2
Worksheet size: 100000 cells
...-~_* _-.,
(.
MTB > TwoSample 95.0 Cl C2; SUBC>
Alternative o.
- Two Sample T-Test and Confidence Interval*
Twos*ample T N
LCS0-7D 6
LC50-1D 6
for LCS0-7D VS LCS0-1D Mean StDev SE Mean 56.5 20.2 8.3 26.72 6.56 2.7 95% C. I. for mu LC50-7D -
mu LC50-1D: ( 8. 6, 51.1) e T-Test mu LC50-7D = mu LC50-1D (vs not=): T=*3.44 P=0.014 DF=
6 MTB >
e wo:ckshee.t size: 100000 cells MTB > Correlation c2 c3.
Correlations (Pearson)
Correlation of lcSO and wt= -0.014 MTB > Correlation c2 c3o Correlations (Pearson)
Correlation of lc50-7d and wJ: = -00361 MTB > Correlation c2 c3o Correlations (Pearson)
Correlation of lcSO-ld and wt= -00103 MTB >
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