ML18153A989

Responds to VEPCO 940614 Ltr Re Proposed Procedure for Disposing of Low Level Radioactive Contaminated Asbestos Waste from Surry & North Anna Power Stations

ML18153A989
Person / Time
Site:	Surry, North Anna
Issue date:	07/01/1994
From:	Daley J ENVIRONMENTAL PROTECTION AGENCY
To:	Hadder A VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
NUDOCS 9407070065
Download: ML18153A989 (2)

Text

• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill 841 Chestnut Building Philadelphia, Pennsylvania 19107-4431 JUL O1 1994 Mr. A.W. Hadder Air Quality Manager Virginia Power Company Innsbrook Technical Center Glen Allen, VA 23060

Dear Mr. Hadder:

This is in response to your J:une 14, 1994 letter describing a proposed procedure for disposing of low .1'evel radioactive contaminated asbestos waste (RCAW) from your Surry and North Anna Power Stations. This letter also discusses methods for complying with EPA regulations found at 40 CFR §61.150(d) (3) and

§61.150(d) (4) (i) & (ii) which specify required timeframes for rece*i ving asbestos waste shipment records and reporting requirements.

During our April 19, 1994 telephone conversation, I was made aware and fully understand the unique circumstances for volume reduction*through compaction that you require for the asbestos wastes prior to final disposal. It is also understood that the asbestos abatement projects are done on an irregular and sometimes unpredictable schedules, resulting in time delays between waste shipments. This, coupled with the necessity of "topping off", with space available, trailers loaded with the compacted asbestos destined for the waste disposal site, will separate portions of the original shipment. Undoubtedly, there will be times when the remainder of the shipment will not be sufficient to fill the disposal trailer with compacted asbestos waste material, resulting in an interruption in final disposal until a "new" shipment from an abatement project is received.

I understand that Virginia Power Company will initiate the 35/45 day response actions required under the asbestos NESHAP regulation~. However, because of the uniqueness of this operation and assuming that we are dealing with a controlled situation with minimal possibility of mishandling, damage or improper disposal, there may be inevitable interruptions with the final disposal. The EPA can accept the likelihood that occasionally the 35/45/ day response periods will be exceeded, provided that notification is made as indicated in your letter.

C)10\ I o I,,.-- 9407070065 94-0701 PDR ADDCK 05000280 P PDR

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.. 2 Our prior conversation and your letter also clarify Virginia Power's intention to identify all sources of compacted asbestos materials making up the final waste shipment record which might be a combination of small and divided original shipments. Over the long term, the amounts of asbestos waste materials generated by Virginia Power and received for disposal should be equalized.

I believe that our communications over the last three months

~?lat have been informative and productive, and I trust that they will enable Virginia Power Company to achieve and maintain compliance with the asbestos NESHAP regulations. If I can be of further assistance, please feel free 215/597-1970.

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~~HAP Asbestos Coordinator

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cc: U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Mr. Clarence Wheeling Virginia Dept. of Labor and Industry