ML20056G409

Responds to Util Rebutting Violations of Virginia Hazardous Waste Mgt Regulations Cited in 930607

ML20056G409
Person / Time
Site:	North Anna
Issue date:	08/20/1993
From:	Burton R VIRGINIA, COMMONWEALTH OF
To:	Marshall B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
NUDOCS 9309030093
Download: ML20056G409 (3)

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gb 3 U#iAh 5' mar COMMONWEALTH of VIRGINIA RICHARD N BunToN DEPARTMENT OF ENVIRONMENTAL QUAUTY won mar DIRECTon TDD (804) 371-8737 AUS 2 01993 fc-Ssr c5y Mr. B. M. Marshall, P.E.

Manager, Water Quality Virginia Power 5000 Dominion Blvd Glen Islien, Va 23060 Re: RCRA inspection, May 18, 1993, VEPCO - North Anna Power Station EPA ID #VAD065376279

Dear Mr. Marshall,

We have received your letter dated July 7, 1993, rebutting the violations of the Virginia Hazardous Waste Management Regulations (VHWMR) that we had cited for your facility in our letter of June 7, 1993.

Our response is as below, in the same item numbers as appeared in your letter.

1. We disagree that the drum of solid paint-related waste does not need to be marked with the words " Hazardous Waste". The material is considered a hazardous waste (D001/D008/F003/F005) until it can be tested and shown to be non-hazardous. This is indeed the way your facility has been handling this type of waste because on the date of the inspection, there was a full drum of this type of waste in the accumulation area with a

" Hazardous Waste label on.

2. We still believe that your f'acility was a Large Quantity Generator in 1992. The reason given in our letter of June 7, 1993 still stands. While it is true that you can rebut the presumption that used oil with high chloride content is a hazardous waste by proving that it does not contain hazardous constituents (section 13.4. A.2 of the VHWMR) , you must do that before manifesting out the waste as a hazardous waste. This is not a manifest discrepancy as referred in section 5.6. of the VHWMR. This section deals with situations where there is a difference between the quantity or type of hazardous waste designated on the manifest and the quantity or type that the off-site TSD facility actually receives. The TSD facility had accepted your waste without any argument and had incinerated t.

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i 3.' This issue has already been resolved by you sending the ,

Virginia Department of Emergency Services a copy of your  !

contingency plan. ,

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4. We have no problem with your wish to be classified as a SOG from June 8, 1993, as long as your facility meets the  !

definition of a SOG.  ;

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5. In item 14 of the Survey Sheet of the Inspection Report, we {

had intended to make a very rough estimate of the weight of  ;

the 1,500 gal of used diesel oil as 6,000 kg (your calculation f gave 5,100 kg) which was mistyped as 6,000 lbs. The estimation j was to point out that the amount of hazardous waste generated  :

in May 1992 was greater than 1,000 kg or 2,200 lbs, exceeding the threshold for SQG (section 6.4.E.4 of the VHWMR). The total amount of hazardous waste accumulated on site immediately before the May 13, 1993 shipment was also likely to be more than the limit of 6,000 kg for a SOG. While we have no way of knowing exactly how much hazardous waste present on site at a certain time, averaging method, as shown below, supports our judgement:

Although your manifests showed other hazardous wastes beside the liquid paint related waste, for simplicity sake and to err on the low side, let us count only the latter:

Shipment date Manifest # Shipped volume 3/19/92 31992 590 gal 8/17/92 70701 850 gal 12/15/92 73601 650 gal 5/5/93 50593 950 gal Assuming that you have been clearing out all hazardous wastes accumulated on site with each shipment, on May 13, 1992, you would have on site approximately:

5,100 kg +

I(850 4 650 4 950)oal x 7.5 lb/ cal x 1 ko/2.2 lb x 2 month]

14 month 3

== 6.3 x 10 kg which is greater than 6,000 kg In summary, violations of sections 6. 4. E. 3. a . (2 ) . , 6.4.E.1.

and 6.5.B. of the VHWMR as cited in our June 7, 1993 letter still .

stand.

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Because of the difference between the Office of Compliance and l Enforcement and your facility in interpretating the VHWMR, please l call me at (804) 371-0126 or Mr. Glenn Moore at (804) 225-2862 to t arrange for a meeting to discuss .the issues. You will need to bring - l to the meeting your records of all hazardous waste shipments during '

i the past three years up to "he date of the meeting.

Sincerely, i

/m  :

Yen T Bao .-

Analytical Chemist l Office of Compliance and Enforcement .

Waste Division  !

CC: Daniel L. James, Jr.

Environmental Specialist, Water Quality Department i Virginia Power ,

5000 Dominion. Blvd j Glen Allen, Va 23060  :

t U.S. Nuclear Regulatory Commission  !

Region II '!

101 Marietta Street, NW -j Suite 2900 1 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 Re: North Anna Unit 1-& 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 G. E. Moore, OCE i

1. 930747 OCE i

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