ML18153A968

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Confirms Agreements Reached During 940419 Telcon Re Util Proposed Procedure for Tracking low-level Radiologically Contaminated Asbestos Waste Once Shipped to Interim Processor for Vol Reduction
ML18153A968
Person / Time
Site: Surry, North Anna  Dominion icon.png
Issue date: 06/14/1994
From: Hadder A
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: Daley J
ENVIRONMENTAL PROTECTION AGENCY
References
NUDOCS 9406200257
Download: ML18153A968 (3)
v • d • e


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Dear.Mr. Daley:

This letter is being submitted in order to confirm the agreements reached during your April 19, 1994 telephone conversation with Mr.

Robert B. Asplund, Mr. Earnest H. Greene, Mr. F. Lee Thomasson, Jr.

and Mr. Thomas J. Szymanski of Virginia Power. During that conversation, Mr. Asplund explained Virginia Power's proposed procedure for tracking low-level radiologically contaminated asbestos waste (RCAW) once it is shipped to an interim processor for volume reduction, prior to being transported to the ultimate disposal site. The proposed tracking procedure was explained as follows:

1. The Radiological Material Control Departments at the Surry and North Anna Power Stations will begin tracking the RCAW when it leaves the station.
2. If the signed waste shipment record (WSR) is not returned to the station by the waste disposal site operator within 35 days, the station will determine the status of the shipment and notify Virginia Power's Air Quality Department (AQD). If the WSR is not received 45 days after shipment, the station will contact the AQD and written notification will be made to the Environmental Protection Agency (EPA).
3. If the shipment is sent to an interim processor for *volume reduction, and, following processing, the RCAW is to be transported to the ultimate disposal site in partial shipments, the interim processor will make a sufficient number of copies of the original WSR to accompany each partial shipment of RCAW to the ultimate disposal site. Each WSR copy will be given an appropriate identification number (e.g., WSR Nos. lA, lB_, lC, etc.) and must include information describing the portion that this partial shipment represents of the original shipment. If the volume of the waste has been altered, this information must be described in the copy sent with the partial shipment. If the original shipment of RCAW is combined with other shipments, the original -WSR will accompany the entire consolidated shipment.

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1 Mr. John Daley Page No. 2 June _14, 1994

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The original WSR will be sent with the final shipment of the processed RCAW. The WSR will indicate that the shipment is closed and also indicate the identification numbers and amounts of the partial shipments sent earlier. The disposal site operator will forward the WSR copies and signed original to the station. The station then must notify the AQD so that the EPA can be notified that the outstanding WSR has been received . . The station will retain the WSRs for at least two years.

5. Copies of the above written notifications will be sent to the Nuclear Regulatory Commission concurrent with transmission of the original notifications to the EPA.

After the complete . explanation and discussion of the proposed

. ti-acking p2-ocedure, y-ou granted 'lirginia ;>cv,er ,rerbal apprc"tral to begin utilizing the new procedure.

  • Also during this conversation Mr. Asplund discussed the possibility that Virginia Power may not receive all of the waste shipment records within 45 days, due to the unique processing procedure.

Mr. Asplund explained the steps that would be taken to correct such a situation. The steps include written notification to the EPA to explain the. reason for the delay. It is our understanding that if the WSR is not returned within 45 days*, EPA will not initiate any enforcement action provided Virginia Power notifies the agency as soon as possible thereafter.

If the information stated in this letter agrees with the procedure we discussed during the April 19, 1994 telephone conversation, please confirm your approval in writing. If you have any further questions .or concerns regarding this procedure please do . not hesitate to contict me.

  • Very truly yours, A. W. Hadder Manager Air Quality cc: u. S. Nuclear Regulatory Commission Attn: Document Control-Desk
  • Washington, D. C. 20555 Re: North Anna Power Station Units 1 and 2 Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF-7 Surry Power Station Units 1 and 2 Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37
  • Verification of .curacy 1.

Regulatory requirements set forth in 40 CFR Part 61, (National Emission Standards for Hazardous Air Pollutants (NESHAP) Subpart M-National Emission Standard for Asbestos.

2. October 14, 1993 Memorandum from T. J. Szymanski to W. A.

Thornton concerning Shipping Asbestos: Update.

3. January 5, 1994 Memorandum from W. A. Thornton, to A. W.

Hadder requesting assistance in resolving the issue of shipping radiologically contaminated asbestos.

4. January 26, 1994 Memorandum from R. B. Asplund, to W. A.

Thornton, explaining discussions with the Utility Air Regulatory Group and also with the Region III Office of EPA, regarding tracking waste shipment records for radiologically contaminated asbestos waste.

5. March 17, 1994 Memorandum from R. B. Asplund to W. A. Thornton explaining an agreed upon procedure for tracking asbestos waste shipment records.
6. April 19, 1994 conference call involving R. B. Asplund, E. H.

Greene, F. L. Thomasson and T. J. Szymanski to Mr. John Daley of the EPA to discuss Virginia Power's proposed procedure for tracking radiologically contaminated asbestos waste.

7. Health Physics Procedure HP-1070.040, "Radioactive Waste Disposal Using the Barnwell Disposal Facility", North Anna and Surry Power Stations.
8. Health Physics Procedure HP-1072.050, "Radioactive Waste Transfer to Licensed Waste Processors", North Anna and Surry Power Stations.

Commitments/Action Plan

1. The AQD will issue a written notification to EPA, with a copy to the NRC, informing them that the WSR has not been received and why.
2. The AQD must notify EPA, with a copy to the NRC, that the outstanding WSR has been recei~ed by the station.

Changes to the UFSAR or QA Topical Report None

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