ML18153B235

Informs of Receipt of NOV in Ref to Dec 1994 Excursion of Total Suspended Solids Limitations of Vpdes Permit for Plant

ML18153B235
Person / Time
Site:	Surry
Issue date:	02/17/1995
From:	Marshall B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	VIRGINIA, COMMONWEALTH OF
References
NUDOCS 9502270125
Download: ML18153B235 (3)

Text

,. Innsbrook Technical Center e e 5000 Dominion Boulevard Glen Allen, Virginia 23060 CERTIFIED MAIL RETURN RECEIPT REQUESTED VIRGINIA POWER February 17, 1995 Gerard Seeley, Jr., Director Piedmont Regional Office Department of Environmental Quality P. 0. Box 6030 Glen Allen, VA 23058 RE: SURRY POWER STATION - VPDES PERMIT NO. VA0004090 TOTAL SUSPENDED SOLIDS EXCURSIONS, DECEMBER 1994

Dear Mr. Seeley:

We have received the Notice of Violation in reference to the December 1994 excursion of Total Suspended Solids limitations of the VPDES permit for Surry Power Station. The NOV was delivered to the station by an inspector from your staff on February 7, 1995.

We were surprised and somewhat dismayed to receive an NOV regarding this particular event.

The subject discharge was stopped as soon as it was recognized that there may be a high solids content. Prior to co;nf irmation by analysis, the event was promptly reported. Mr. Daniel James, Water Quality Department, discussed the situation with Ms. Camille Cook by telephone on December 27, 1994. The event was also addressed by my follow up letter dated January 3, 1995. The solids involved did not consist of any process waste discharge but were fine corrosion product solids, primarily magnetite and iron oxide, dislodged from the steam generator blowdown system during maintenance operations.

The relative magnitude of this discharge is relevant in that the flow via Outfall 181 of less than 200 gpm enters the station's cooling water flow which is one million gpm inside the station at the water boxs. The resulting instantaneous dilution would provide an undetectable increase in concentration of solids over the ambient river water solids well before the cooling water reaches the discharge canal.

To provide further perspective in this issue, the flushing of municipal water distribution lines makes for a convenient comparison. Water systems are frequently flushed of corrosion particles, sediment, etc., with direct discharge to surface waters of much greater quantities than the subject discharge at Surry. As far as we are aware, this practice is deemed so insignificant that it is not considered a violation and does not even require a permit.

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9502270125 950217 PDR ADOCK 05000280 Q PDR l 6¢'0

.... L The steam generator system from which the subject discharge originated is filled with very high purity water. Therefore, it is likely that this discharge contained fewer pollutants than do the municipal water systems that are freely flushed. The 257.7 mg/1 TSS consisted of magnetite and ~ron oxide. Data on the other contents, from the station's in-line chemistry analyzer instruments that were monitoring the system at the time of the discharge, are:

pH 8.81 SU conductivity 1. 81 sodium 2.5 ppb chloride <1. 0 ppb fluoride 1. 3 ppb sulfate 17.1 ppb silicate 182.0 ppb It would be appreciated if you would review this event with more consideration of the facts in the case to determine if issuance of the NOV is warranted. We request that, based upon the actual facts of this event, the NOV be rescinded.

Meanwhile, should you desire additional information or have any questions about this matter, please contact me at (804)273-2990 or Daniel James at (804)273-2996.

B. M. Marshall, Manager Water Quality

e cc:

Peter W. Schmidt, Director Department of Environmental Quality 629 East Main Street P.O. Box 10009 Richmond, VA 23240 Robert M. McEachern, Compliance Auditing Department of Environmental Quality 629 East Main Street P.O. Box 10009 Richmond, VA 23240 Camille S. Cook Piedmont Regional Office Department of Environmental Quality P. 0. Box 6030 Glen Allen, VA 23058 Robert A. Allen Tidewater Regional Office Department of Environmental Quality 287 Pembroke Office Park, Suite 310-11 Virginia Beach, VA 23462 U.S. Nuclear Regulatory Commission Region II 101 Marietta St., NW Suite 2900 Atlanta, GA 30323 Re: Surry Units 1 & 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: Surry Units 1 & 2 Docket Nos. 50-280/50-281 License Nos. DPR-32/DPR-37 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station