ML20045G403

Responds to State Re Findings Noted in RCRA Insps on 930518.Licensee Has Demonstrated That No Violations W/Respect to Unmarked Drum & Accumulation Time & Annual Rept & Contingency Plan Occurred

ML20045G403
Person / Time
Site:	North Anna
Issue date:	07/07/1993
From:	Marshall B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Bao Y VIRGINIA, COMMONWEALTH OF
References
NUDOCS 9307130307
Download: ML20045G403 (3)

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talen.Illen. Virguna J finuo QRRTIFIED MAIL RETURN RECEIPT REOUESTED VIRGINIA POWER July 7, 1993 Ms. Yen T.

Bao Analytical Chemist Office of Compliance and Enforcement Waste Division Department of Environmental Quality James Monroe Bldg., lith Floor 101 North 14th Street Richmond, VA 23219 NORTH ANNA POWER STATION - EPA ID NO. VAD065376279 MAY 18, 1993 HAZARDOUS WASTE MANAGEMENT COMPLIANCE INSPECTION

Dear Ms. Bao:

We are in receipt of your June 7, 1993 letter and inspection report detailing the findings of your May 18, 1993 RCRA inspection of the subject f acility. Our response to your findings is provided below:

1.

We believe the unmarked drum in the paint shop satellite area was not a violation of the VHWMR.

The open-top drum in the paint shop satellite area was for dried paint only, which is not RCRA hazardous and therefore does not require marking.

This material consists of dried paint scraped out of buckets so the buckets can be reused, dried paint brushes and rollers, plastic, paper, and debris.

A nearby closed top drum used for the collection of solvents was properly marked.

2.

We believe North Anna Power Station is properly classified as a

small quantity hazardous waste generator (SQG) and accordingly complies with the VHWMR applicable to a SQG.

Your letter cites the May 1992 generation event of "1500 gallons of F001 diesel generator lube oil waste" as the basis for triggering large quantity hazardous waste generator (LQG) status and consequently, for incurring the accumulation time, annual report, and contingency plan " violations".

We do not agree with your conclusion that the May 1992 event caused North Anna Power Station to exceed the monthly hazardous waste generation threshold and become a LQG.

Quite simply, the 1500 gallons of oil, although classified as F001 hazardous waste on the manifest, was determined to be non-hazardous used oil in accordance with Section 13.4 of the VHWMR.

Information provided by the oil's manufacturer,

chevron, Inc.,

and analysis performed by Virginia Power yielded data that lg' rebutted the presumption that the oil was a hazardous waste.

We regar,ded go characterization of, the oil on the manifest as l' hU 9307130307 930707 PDR ADOCK 05000339 if G

PDR a

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Ms. Yen T.

Bao July 7, 1993 Page 2 a manifest discrepancy in accordance with Section 5.6 of the VHWMR.

Because the oil was not a hazardous waste, the power station did not exceed the 1000 kg monthly generation threshold and did not become a LQG.

As a SQG North Anna Power Station did not exceed an accumulation time threshold, is not required to submit an annual report, and is not required to have a

hazardous waste contingency plan.

Your letter correctly concludes that North Anna Power Station is in compliance with the VHWMR for a SQG.

Importantly, regardless of generator status, the oil was properly and safely managed by Virginia Power and our contractor, Laidlaw Environmental Services, Inc.

3.

Regarding item 2.c.

of your letter, North Anna Power Station is not required to maintain a hazardous waste contingency plan as a SQG.

The station elects to maintain a plan to remain in compliance with the VHWMR in the event a monthly accumulation threshold is exceeded and LQG status triggered.

Your letter indicated the " Commonwealth emergency response team, i.e. the Virginia Department of Emergency Services" (VDES) is the appropriate state agency for compliance with Sections 9.3.B.3 and 9.3.C.2 of the VHWMR.

Neither section specifically identifies the VDES.

North Anna regarded the Virginia State Police as an appropriate " Commonwealth emergency response team" and accordingly contacted and submitted the plan to the State Police.

If the VDES is the desired or designated

" Commonwealth emergency response team", Sections 9.3.B.3 and 9.3.C.2 need to be amended to specify the VDES.

Nevertheless, a copy of the plan was mailed to the VDES on May 24, 1993 (see attached copy of mail receipt).

4.

North Anna Power Station intends to remain a SQG and, on June 8,

1993 prior to receiving your letter, we submitted an updated Form 8700-12 confirming our status.

The amount of hazardous waste generated in the future is expected to decline as we have acquired a solvent recovery system to reclaim paint solvents.

5.

Item 14 of the inspection report attached to your letter erroneously states that the 1500 gallons of oil shipped off-site in May 1992 weighed approximately 6,000 lbs.

The weight of the oil was approximately 11,250 lbs. or 5100 kg based upon a unit weight of approximately 7.5 lb/ gal.

Item 14 goes on to state that the facility violates the SQG requirement found in Section

6. 4.E.4.a of the VHWMR which provides an allowable maximum accumulation amount of 6000 kg.

The oil shipped off-site in May 1992 did not exceed the 6000 kg threshold.

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Ms. yen T.

Bao

.,Tuly 7, 1993 Page 3 Your letter instructs us to "take corrective actions for violations 1 and 2.a."

(unmarked drum and accumulation time) and provide

" procedures that will prevent their recurrence."

We have demonstrated that no violations occurred and consequently no procedures are submitted.

Your letter also instructs us to " submit the required documentation as cited in violations 2.b.

and 2.c."

(annual report and contingency plan). We have demonstrated that no violations occurred and consequently, except for the attached mail receipt confirming mailing of the contingency plan to the Virginia Department of Emergency Services, no documentation is submitted.

If you have any questions regarding our response or our facility, please do not hesitate to call Daniel James (273-2996) or Bob Williams (273-2994) of my staff.

Sincerely, f(6Y B.

M.

Marshall, P.E.

py Manager Water Quality cc:

U.S.

Nuclear Regulatory Commission Region II 101 Marietta Street, NW Suite 2900 Atlanta, GA 30323 Re:

North Anna Unit 1 & 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 U.S.

Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 i

Re:

North Anna Unit 1 & 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 NRC Senior Resident Inspector North Anna Power Station j

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