ML18153B676

NPDES Noncompliance Notification:Oil Spills Observed in Discharge Canal.Floating Containment Booms,Used to Contain Any Oil Discharges Permanently Installed Across Canal.Nrc to Be Notified If Release Escape Discrete Containment Area

ML18153B676
Person / Time
Site:	Surry
Issue date:	04/03/1989
From:	Marshall B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Ronaldo Jenkins VIRGINIA, COMMONWEALTH OF
References
NUDOCS 8904130619
Download: ML18153B676 (2)

Text

uut..)utuv~* 1f::Cu1uu..u 1.....,c-1ii..t.11 5000 Dominion Boulevard Glen Allen. Virginia 23060 Apri 1 3, 1989 CERTIFIED MAIL VIRGINIA POWER RETURN RECEIPT REQUESTED Mr. R. R. Jenkins Virginia Water Control Board Piedmont Regional Office 2201 West Broad Street Richmond, VA 23230 Re: REPORTABILITY OF OIL SPILLS -

SURRY POWER STATION DISCHARGE CANAL

Dear Mr. Jenkins:

As you are aware, Virginia Power has routinely provided the Virginia Water Control Board with a verbal and five-day written notification of all oil sheens observed in the discharge canal at Surry Power Station.

Many of these sheens have resulted from extremely minor events such as residual yard runoff and all have been easily contained and subsequently cleaned up within the boundaries of the concrete-lined portion of the discharge canal prior to release to the James River.

The discharge canal extends from the station to the James River. It is 3/4 of a mile long, 200 feet wide, and 20 feet deep. It serves as a conduit for discharges from the power station to the river and can be physically divided into two portions. The upper portion (photo 1) nearest the station is man-made, concrete-lined, and surrounded by an earth bank which is on approximately a 45° slope from the plant. In order to reach the upper portion of the canal one would have to go .

. out-side of the plant's fenced in area and down a long, steep staircase.

The lower portion (photo 2) extends from the concrete-lined area through a granite boulder groin into the river. Two floating containment booms, used to contain any oil discharges or spills, have been permanently installed across the canal between these two portions. A third boom has also recently been placed further up the canal below the storm drains as an additional control measure. These booms, in conjunction with the steeply banked slopes, effectively prevent navigation in the upper portion and act to contain any oil released to the discharge canal within this upper portion.

While we have continued to respond in writing to each oil spill event, it has been our contention that since the cooling water discharge canal is a concrete lined conveyance designated as waste stream outfall 001 in our NPDES permit VA0004090, it does not constitute state or navigable waters.

Therefore, any oil spills reaching only the concrete-lined portion of the 8904130619 890403

~DR ADOCK 05000280 PDC

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• • -~ Mr. R. R. Jenkins e

Page 2 April 3, 1989 discharge canal which are wholly contained within this area and subsequently removed do not constitute reportable releases.

The status of reportability in no way lessens our resolve to eliminate all spills in the first place. The resources necessary to locate, report and cleanup a spill are better and more properly focused elsewhere. We will therefore continue to emphasize prevention however, in the event a release should occur, immediate response and verbal notification will be provided to the Virginia Water Control Board regardless of the quantity or area involved. Reporting to the National Response Center and written notification to your office will also be provided shouid a release escape the discrete containment area provided by the concrete liner and booms.

If you have any questions or desire additional information, please contact Mr. Glenn Bishop at (804) 273-2988.

Sincerely, WGB: rw: 1894 cc: National Response Center (CERTIFIED MAIL)

Coast Guard Headquarters Bldg.

Room 2611 2100 2nd Street, S.W.

Washington, DC 20460 Environmental Protection Agency (CERTIFIED MAIL)

Region III Emergency Response Section 8411 Chestnut Building Philadelphia, Pennsylvania 19107 U.S.N.R.C., Atlanta Georgia, Docket #50/280-50-281 U.S.N.R.C., Washington, DC, Docket #50/280-50-281 U.S.N.R.C., Senior Resident Inspector, Surry Power Station