ML20029A001

Denies That Abnormal Events Re Water Releases to Lake Anna Should Be Classified as Unusual Discharges,Per 910121 & 23 Telcons.Discharges Contained No Pollutants

ML20029A001
Person / Time
Site:	North Anna
Issue date:	01/25/1991
From:	Marshall B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Kregloe W VIRGINIA, COMMONWEALTH OF
References
NUDOCS 9102010028
Download: ML20029A001 (2)

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• l -Inndwtx>k krhnkalG1tler 5000lJomunon (toutes etrci s' Glen Allen, Vorganut 23060 i )

January 25, 1991 VlltGINIA POWER CERTIFIED MAIL RETURN RECEIPT REOUESTED Mr. William L. Kregloe Virginia Water Control Board Valley Regional Office 116 North Main Street P. O. Box 268 Bridgewater, Virginia 22812

Dear Mr. Kregloe:

Re: Notificai; ions of Water Discharges - North Anna Power Station In the past week North Anna Power Station has experienced several water releases to Lake Anna that were not discharges of wastewaters from our operations. You have been informed of each event (see letter dated 1-21-91 and by telephone 1-23-91). On two occasions, water purified for use as makeup in plant operations was released to the Lake. :In the purification process lake water is filtered then put through a reverse osmosis process to produce water from which nearly all lonic species have been removed. This highly '

purified water is critical for steam generation with minimal effects on equipment. It is obviously more pollutant-free than the surface water from which it is drawn and to which it was discharged.

L on another occasion, a domestic water pipe froze and burst due to l the extreme cold. This drinking water, untreated, from the station -

domestic water wells went into a storm drain and flowed to-the l Lake. Again the water released was. free of pollutants.

At your suggestion, these incidents were preliminarily reported as l- " Unusual Discharges".

. Upon further evaluation we do not agree that

[_ these - abnormal events should be so classified. The unusual

-discharge designation only applies to certain - discharges which would otherwise require a VPDES permit. We do'not believe that the -

referenced releases fit the criteria set out in-the regulations

_(VR680-14-01$1.5 A) and reaffirmed in recent guidance from the Office.of Water Resource Management. VPDES permits were intended to authorize the discharge of pollutants to surface waters. Where point sources to surface waters do not contain pollutants, no-permit _is required and therefore no unusual discharge could occur (see VR680-14-01$2.2.I.2).

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• 4-Mr. William L. Kregloe ,

1 Page 2-January 25, 1991 l i

The resources of both the Water Board and Virginia Power need to be focused on real threats to the quality of Virginia's waters and not' distracted by incidents which present no such threat. Several times a year it is necessary to release stored purified water or I discharge unused lake water. In the next few days it will be necessary to discard unused lake water from a portion of an intake tunnel in order to inspect the tunnel. Water has entered the 12 ft. diameter tunnel'but not yet entered the condenser or any part of the plant process. . Approximately 600,000 gallons of lake water will be returned to the lake via a nearby storm drain. We will consider such releases to be outside the-VPDES system and that as such do not require reporting as-Unusual Discharges.

As always, I hope our free and open communications will keep the Board sufficiently informed . of operations at North Anna Power Station to address any concerns that may arise. -If you find our interpretations incorrect, please inform us at your earliest convenience.

Sincerely, B. M. Marshall, P.E.

Manager Water Quality cc: Mr.-. Larry Lawson, OWRM U.-S. NRC Docket No. 50-338/50-339

~101 Marietta'St., NW Suite 2900 Atlanta, GA 30323 U. S. NRC.

l Attn: Docket Control Desk Docket No. 50-338/50-339 Washington, DC 20555 NRC Senior-Resident Inspector

-Docket No. 50-338/50-339 North Anna Power Station l

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