ML20082U773

Annual Environ Operating Rept for North Anna Power Station Units 1 & 2 for 1994

ML20082U773
Person / Time
Site:	North Anna
Issue date:	12/31/1994
From:	Bowling M VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
95-217, NUDOCS 9505050314
Download: ML20082U773 (21)

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• .c VIRGINIA ELucTHIC AND Powna COMPANY Hicunown,VinorwxA 20201 April 28, 1995 United States Nuclear Regulatory Commission Serial No.95-217 ~

Attention: Document Control Desk NAPS /JHllCMC Washington, D. C. 20555 Docket Nos. 50-338 50-339 ,

License Nos. NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT NOS.1 AND 2 ANNUAL ENVIRONMENTAL OPERATING REPORT Pursuant to Section 5.4.1 of the Appendix B Technical Specifications, Environmental Protection Plan, enclosed is the Annual Environmental Operating Report for North Anna Power Station Unit Nor 1 and 2 for 1994. .

if you have any questions or require additional information, please contact us.

Very truly yours, l

M. L. Bowling, Manager Nuclear Licensing and Programs Enclosure cc: U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. R. D. McWhorter NRC Senior Resident inspector North Anna Power Station

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VIRGINIA ELECTRIC AND POWER CONPANY NORTE ANNA POWER STATION UNI'TS 1 AND 2 APPENDIX B ,

ENVIRONNENTAL PROTECTION PLAN 3 1994 ANNUAL REPORT DOCKET NOS. 50-338 AND 50-339 ,

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INTRODUCTION This 1994 Environmental Operating Report for the North Anna Station is submitted by Virginia Electric and Power Company as required under Section 5.4.1 of Appendix B, Environmental Protection P.'.an (EPP). The objectives of the EPP are to verify i

that the power station is operated in an environmentally acceptable manner, to coordinate NRC requirements, maintain consistency with  ;

other federal, state and local requirements, and to keep the NRC l informed of the environmental effects of facility construction and  !

operation. During 1994, no significant adverse environmental impact occurred as a result of the operation of North Anna Power '

Station, Units 1 and 2. Aquatic issues are addressed in the ,

licensee's VPDES permit number VA 0052451 issued by the Virginia State Water Control Board. The VPDES permitting program is administered by the Department of Environmental Quality-Water  !

Division and the NRC relies on this agency for regulation of matters involving water quality and aquatic biota.

t Listed below are the summaries and reports as required under .

Section-5.4.1 of the EPP. ,

i PLANT DESIGN AND OPERATION (SECTION 3.1) i There were no changes in station design and operation proposed in 1994 that involved a potentially significant unreviewed environmental issue. ,

TRANSMISSION LI.EE RIGHT OF WAY HERBICIDE MANAGEMENT l' (SECTION 4.2.11 No harbicides were used for brush control on the North Anna-Midlothian, North Anna-Morrisville, North Anna-Ladysmith 500 kV  ;

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lines or the North Anna-Gordonsville 230 KV line during 1994.

Ta n MISSION LINE RIGHT OF WAY EROSION CONTROL INSPECTION (SRCTION 4.2.2) ,

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Erosion inspection on right of way.was made on the North .j J

Anna - Midlothian, North-Anna - Morrisville, North Anna -- j l

'Gordonsville, and North Anna - Ladysmith lines on August 24, 1994. f i

Locations were recorded where erosion was taking place on the North j

t Anna - Morrisville, North Anna - Midlothian, North Anna - l t

Gordonsville and the North Anna - Ladys'mith lines. Most of these l locations noted were caused by vehicle travel up and down the right' of way. These areas were disced, fertilized, seeded, and mulched,-

l to prevent erosion. l 1

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STATION SITE EROSION CONTROL (SECTION 4.2.2)

An on-site erosion control inspection was performed at North Anna Power Station by the Civil / Design Engineering Department l

bc?i nning December 20, 1994 and ending on January 5, 1995, f

1 according to Periodic Test Procedures 1-PT-9.3, Erosion Control

Inspection - Station Site. Although erosion was minor or non-  !

existent in most areas, several areas were determined to require l remedial attention. Erosion gullies / holes required filling on the  !

l west face of the floodwall, also adjacent to the heater / boiler room l and'by the railroad tracks adjacent to the site Construction l

Building. A side-hill erosion ditch in the borrow area required l

4- l tiaing into previously established erosion barriers. Clean-out l

'was recommended for a culvert near the switchyard and a box weir f below the station parking area, which also required the filling in of a washed out section. All of the above maintenance activities (2) l l

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have been completed. i

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MOMCOBEPL1ABICE (SECTION 5.4,1)  !

i' There'were'no Environmental Protection Plan occurrences of-noncompliance during 1994.  ;

NONROUTIME REPORTS (SECTION 5.4,2) l Enclosed are copies of letters detailing the occurrence of-

'i two. unanticipated discharges (pages 4 - 7), two oil spills (pages 8 - 11) and seven VPDES exceptions (pages 12 - 15) occurring during t

1994. None of these events resulted in a significant environmental impact causally related to ststion operation. However, the VPDES-exceptions, resulting from two sewage treatment plant upsets, did  !

result in a Notice of Violation (page 16) generating a response l letter (pages 17 - 19).  !

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N rth Annn COR 14/ Violations January 31, 1994 .

b Mr. Kemper Loyd Valley Regional Office l Department of Environmental Quality l 116 North Main Street ,

P. O. Box 268 Bridgewater, VA 22812 RE: NORTE AMMA POWER STATION - YPDES PERMIT NO. YA0052451  !

UNUSUAL DISCEARGE t

Dear Mr. Loyd:

i As Mr. Daniel James of my staff discussed with you by telephone on January 25, 1994, the North Anna Power Station experienced an

• unusual discharge of chromate to the clarifier from a leak in the  :

component cooling system. The clarifier discharges to the l circulating water tunnel via outfall 003. -

l At the time the chromate leat was discovered, analysis of samples  ;

from outfall 003 showed 0.16 ppa at the internal discharge point.  ;

Chromate inventory calculations indicate that the leakage probably  ;

occurred over four days at a rate of 0.3 pounds per day.

The source of the chromate 3eak was found to be the component  ;

cooling system heat exchanger. tubes which were replaced following i similar leaks reported in November 1993. The replacement tubes were apparently defective. Leaking tubes in the heat exchanger  ;

have been replaced to stop the loss of chromate from the system.  ;

i While the system is being evaluated to determine if additional ,

tubes will require replacement, the blow-down pump discharge which receives leaks, from the component cooling system will be sampled ,

every four hours and analyzed for chromate. If chromate is detected in the pump discharge, the system can be isolated to ,

prevent additional untreated releases to the clarifier. ,

As with the previous losses of chromate from this system, no other ,

contaminants were involved and no violations of any permit limitations occurred. The chromate present in the water discharged .

would not be expected to be detectable in the discharge canal or  !

the waste heat treatment facility, and would have no impact on >

water quality in the canal, the waste heat treatment facility, or at the station's discharge to state waters.

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Nr. Kemper Loyd January 31,.1994 Page 2 Should you desire additional information or have any questions about this matter, please contact Daniel James at (804) 273-2996.

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

. Nanager

• Water Quality cc: U.S. Nuclear Regulatory Commissi,on l Region II 101 Marietta St., NW Suite 2900 '

Atlanta, GA 30323 RE: North Anna Units 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 Units 1 & 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 Mr. R. D. McWhorter NRC Senior Resident Inspector North Anna Power-Station t

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North Anna ,

COR 14/Volations March 4,1994 Mr. Kemper Loyd l valley Regional Omce _i Department of Environmental Quality j' 118 North Main Street P. O. Box 288 '

Bridgewater, VA 22812 RE: NORTH ANNA POWER STATION -VPDES PERMIT NO. VA0052451 - SEWAGE OVERFLOW

Dear Mr. Loyd:

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This is in follow up to the reported sewage overflow at North Anna Power Station that l Mr. Daniel James of my staff discussed with you by telephone on February 28,1994.

On the morning of February 28, station personnel found that a clog in a sewer leading to 7 the package treatment plants which discharge through Outfalls 005 and 007 had caused  ;

a backup in the sewer. The backup erupted through a broken cleanout in the line and e sewage overflowed onto the ground surface. Most of the sewage overflow went onto,  !

i and into, the ground in the vicinity of the broken cleanout. A small portion was carried by ice melt runoff into the settling pond which discharges via Outfall 009. .

The overflow apparently occurred during the weekend when very few personnel are in the  :

building served by the sewer involved. Therefore, although no volume of sewage lost ,

could be determined, the amount would be very small. Due to the volume of water in the .

settling pond, the portion of the sewage which would have reached this pond with runoff  !

would have been minute. Fecal coliform testing of the 009 discharge is being performed ,

but the results of such analysis may be invalid since the ceiuruution from wild animal sources (deer and beavers are frequently sighted in the settling pond depression) would far exceed any coluibution possible from the small amount of sewage involved. l l

Station personnel have cleaned up the sewage solids in the area of the overflow, limed -

the area, and repaired the pipe cleanout. A rooter service hydrolazed the pipe and i cleared the plug. j t

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Mr.' W W -

March 4,1994 -

1 Page 2 No contaminants other than domestic sewage were irwolved in this event and no  :

violations of any permit effluent limitations occurred. Eve for the insignificant potential contribution to the OutfaB 009 Gewf,6, nor,e of the sewage overflow was to state i waters. The smal amount of sewage which could have overflowed from this pipe would not be expected to have detrimental impacts on any other wastewater treatment processes or on the station's didwi,es to state waters. j Should you desire additional information or have any questions about this matter, please contact Daniel James at (804) 273-2996. ,

i Sincerely, B. M. MarshaR, P.E.

Manager Water Quality oc: U.S. Nuclear Regulatory Commission Region ll 101 Marietta St., NW ,

Suite 2900 l Atlanta, GA 30323 Re: North Anna Units 1 & 2 Docket Nos. 50-338/50-339  !

l Ucense Nos. NPF-4/NPF-7 U.S. Nuclear Regulatory Commission l Document Control Desk Washington, DC 20555 ,

Re: North Anna Units 1 & 2  :

Docket Nos. 50-338/50-339 Ucense Nos. NPF-4/NPF-7 Mr. R. D. McWorter NRC Senior Resident inspector North Anna Power Station l

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1 North Anna ENV 43/011 Spir May 5,1994 Mr. Kemper Loyd

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Water Regional Office Department of Environmental Quality 116 North Main Street Bridgewater, VA 22812 RE:

NORTH ANNA POWER STATION - OIL SPILL 5/1/94

Dear Mr. Loyd:

l An oil spil occurred at the Lake Anna Dam on May 1,1994. This letter confirms our 4 report of the incident to the Department of Emergency Services at 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br /> on that l date. .

At approximately 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br /> on May 1,1994, a hydraulic oil leak was discovered on the SA hydro unit that is located below the Lake Anna Dam. The unit was immediately shut down and the oil cleaned up from around the leak area. From a measurement of the fluid l remaining in the hydraulic oil reservoir, approximately 2 to 3 gallons may have been lost 1 over the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. It appears that most of this oil remained on the  ;

structure and only a smaN portion reached the river. The oil was subsequently cleaned  :

off of the structure. A smaH oil sheen was visible below the hydro unit when the leak was discovered but this dissipated before it could be removed due to the turbulence of the water below the dam.

No evidence of environmental damage, residual floating oil, or sludges were found during an inspection of the river downstream. The leak was repaired and the hydro unit was  :

retumed to operation on May 2,1994. This event is being evaluated to determine if there l are any remedial actions which could prevent a similar leak from entering the river in the i future.

Should you desire additional information or have any questions about his matter, please  :

contact Daniel Jari,ss at (804) 273-2996.

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

Manager Water Quality l (8)

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cc: U.S. Nuclear Regulatory Cc,iTiiT,iesic,7

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Region 11 J 101 Marietta St., NW Suite 2000 Atlanta, GA 30323

Re: North Anna Units 1 & 2 Docket Nos. 50-338/50 339 ,

4 Ucense Nos. NPF-4/NPF-7 U.S. Nuclear Regulatory Cc,iTri,ieeirni Document Control Desk  :

Washington, DC 20555 .

Re: North Anna Units 1 & 2 i Docket Nos. 50 338/50-339 Uoense Nos. NPF-4/NPF-7

Mr. R. D. McWhorter

NRC Senior Resident IriepecAn-North Anna Power Station i

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ENV 43/ OR Spul Reports.

j CERTIFIED MAIL -

RETURN RECEIPT REQUESTED July 14,1994 '

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Mr. Kemper Loyd  !

Water Regional Office Department of Environmental Quality  ;

116 North Main Street -

P. O. Box 268 Br$;4w, VA 22812 RE: NORTH ANNA POWER STATION - OIL SPILL REPORT 7/9/94  !

Dear Mr. Loyd:

1 An oil spiB to the North Anna River occurred at the Lake Anna Dam on July 9,1994. This letter cc-Jirms our reports of the incident to the Department of Emergency Services and  !

l to the National Response Center at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, on that date.

At approximately 1930_ hours on July 9,1994, station personn61 discovered two oil drums l and a five gallon bucket in the North Anna River adjacent to the Lake Anna Dam. The drums and bucket had been stored in a temporary berm during maintenance operations  ;

at the dam. High winds associated with a violent thunderstorm the previous evening dislodged the berm and blew these items into the river. The bucket was used to transfe.-  ;

oil between the gate operating mechanism and the barrels. One barrel was empty and  ;

. the other contained about two gallons of oil; both were closed. A small amount of oil I

recidue was on the bucket.  !

This event caused a very light oil sheen on the water below the grassed slope beside the i dam. After removal of the drums and buck'et, the light sheen dissipated and no oil or -

sludges [emained to be captured or cleaned up. No oil was lost from the drums. The j sheen on the water was apparently caused by residuals remaining in the bucket and/or the exterior surfaces of the drums.

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Mr. Kemper 1.oyd July 14i1994 Page 2 Should you desire additional information or have any questions about this matter, please ,

contact Daniel James at (804) 273-2996. l t

Sincerely,  ;

B. M. Marshall, P.E. .

i Manager ,

Water Quality '

oc: U.S. Nuclear Regulatory Commission ~

Region 11 i 101 Marietta St., NW Suite 2000 '

Atlanta, GA 30323 '

RE: North Anna Units 1 & 2 Docket Nos. 50 338/50-339 License Nos. NPF-4/NPF-7  ;

U.S. Nuclear Regulatory Commission i Document Control Desk Washington, DC 20555 RE: North Anna Units 1 & 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 Mr. R; D. McWhorter '

NRC Senior Resident inspector North Anna Power Station i

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t North Anna COR 14/ Violations October 13, 1994-Mr. Janardan R. Pandey .

Valley Regional Office  !

-Department of Environmental Quality ,

P. O.. Box 268 i Bridgewater, VA 22812 l Re: North Anna Power Station - VPDES Permit-No. VA0052451 '

Sewage Treatment ~ Plant Upsets, 9-20-94  :

Dear Dr. Pandey:

This is in follow up to the reported sewage treatment plant. upsets  :

at North Anna Power Station on September 20,'1994, that Mr. Daniel' James of my staff discussed with you by telephone on October 6,  ;

1994. These upsets impacted the facilities' discharging via VPDES  ;

Permit Outfall 007 and Outfall 011.

On September 20, 1994, personnel from the Water Quality Department sampled several outfalls at North Anna, including.007 and 011, to -

obtain data for preparation of an application for reissuance of the ,

VPDES permit. These samples were transported .to our System  ;

' Laboratory for analyses. Routine monthly sampling under the permit . 1 is conducted by station staff, and the sampling required for .;

September had been conducted at an earlier date.  ;

On October 6,1994, when the' sample results'were available from the System Lab,.. it was discovered that BOD, and TSS results for Outfall 007 and TSS results for Outfall.011 exceeded permit limitations. l All .other parameters and all other outfalls 'were well within permitted limits. Our investigations revealed the following- i factors involved in these limits' excursions:

Outfall 007, Package Sewage Treatment Plant-  !

L This small, 10,000 gpd design package plant serves an office l building and contractor shops. Influent flow is light and 3 intermittent. The influent flow rate was only 4,315 gpd on ,

September 20.

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October:13, .1994 , j Page 2 '

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. j At' the time of the initial sampling visit on 9-20, 'it was noticed by the Water- Quality staff that the aerators did not q cycle on during the time they were at the facility and -that j the STP contents were changing to a blacker color than normal.  !

Although the effluent was black, it was still transparent with i what appeared, at that time, to be. very few visible solids. .

.. l This was reported to the facility operator after the first set. >

of samples for the day had been taken.

The STP operator checked the plant that day and found that the aerators had been electrically. tripped out. This was apparently done by contractors working on~ unrelated equipment 1 served by the same power source. The operator reset the i blower switches and, after aeration was reestablished, the  ;

plant contents quickly began returning to a normal light brown-Color.  ;

During the period of the plant upset due to accidental.  :

interruption of aeration, the following excursions were  !

experienced;  ;

BODS TSS  !

1450 hrs. 182.75 i 1550 " 208.50 -61.5  !

1650." 165.00 61.5  ;

1750 " 237.75 66.0 since it was not realized at the time that there had been an i upset- which impacted effluent quality, additional samples 1 beyond the above, taken for permit application data, were not analyzed. A new operator is now working with this facility;  ;

the previous operator left the company at - the end of i september. The performance of the facility is being improved  !

but still suffers evidently from a loss of microorganism i populations during the upset period. )

Outfall 011, Main Sewage Treatment Plant- j During the Water Quality Department staff's-sampling period,.

there did not appear to be any obvious problems with the plant or its effluent. . After discovery of the higher than normal TSS results, inquiry results revealed that the operator had wasted sludge the morning of the sampling visit. At the time of this process, the operator had wasted more than he normally did in an effort to remove some old sludge from the system.

The excessive sludge wasting likely caused resuspension of particulates in the plant which had not had time to resettle (13)

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, October 13, 1994 Page 3 l prior to the sampling visit. However, these particulates were  !

evidently inert solids; BODS results during this period were I less than 2 ppm. ,

During the period of the plant upset due to extended sludge  !

wasting, the following excursions were experienced; j TSS  ;

1420 hrs. -84.0 . L 1520 " 66.0 f

'1620 " 84.0 l 1720 " 56.0- l i

As with the upset event at t he package STP, since'it was not' l realized at the time that there had been an upset. which  !

impacted effluent quality, additional samples beyond the '

above, taken for permit application data, were not analyzed. ,

This facility typically produces effluent with relatively low - i BODS and TSS results. {

1 A new operator is now working with this facility; the previous operator ~-left the company at the end of September. The l performance of the facility is being improved but still-  !

suffers evidently from insufficient aged sludge.

The results of the Water Quality-Department sampling were provided to the station's Environmental Compliance Coordinator and included  ;

in the data reported on the Discharge Monitoring Report submitted for the month of September. During sampling of the impacted, and other, outfalls, the Water Quality personnel were in the vicinity

- of the respective discharge points and did not observe 'any evidence  ;

of environmental problems from the" discharges ~ nor was there any.  ;

indication of abnormal discharges at any of the discharge points.

The discharge rate of the Outfall 007 during sampling was only an i estimated 2-3 gpm, which would have been quickly assimilated by the q receiving waters at the subsurface outfall pipe. The solids in the "

Outfall- 011 discharge would likely settle. out again in the ]

discharge canal or the Waste Heat Treatment Facility. No detrimental environmental damage would be expected from either i

discharge.  ;

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Mr. Janardan R. Pandey October 13, 1994 Page 4 We believe that both of these incidents are properly characterized as sewage treatment plant upsets. There are no operational connections or mutual causative factors between the two facilities so, their occurrence on the same day, and on the day of sampling for permit application data, is coincidental. Operations will be monitored and adjustments made to bring these units back into their normal acceptable level of treatment.

Should you desire additional informat! ion or have any questions about this matter, please contact Daniel James at (804)273-2996.

Sincerel

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B. M. Marshall, P.E. l Manager Water Quality j cc: U.S. Nuclear Regulatory Commission Region II 101 Marietta St., NW Suite 2900 Atlanta, GA 30323 Re: North Anna Units 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 Units 1 & 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 Mr. R. D. McWorter NRC Senior Resident Inspector North Anna Power Station (15) ,

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, COMMONWEALTH OF VIRGINIA DEPARTMENT OF ENVIRONMENTAL OUALITY WATER DIVISION A -

P. O. BOX 10009 RICHMOND, VIRGINIA 23240-0009 A

uvann orsmum or rmwmumu ryurn E2[e]f[el::Ke]39[e]F3g[e]23 NOTICE OF VIOLATION NO. 94-10-VRO-017 PERMIT / PC / OTHER ID NO. VA0052451 FACIUTY/ COMPANY NAME VEPCO-OLD DOMINION ELEC. COOP-NORTH ANNA RESPONSIBLE OFFICIAL A.C. COOKE TEL. NO. 703-894-2856 MAluNG ADDRESS 5000 DOMINION BLVD., GLEN ALLEN. VA 23060 This Notice of Violation is not a Case Decision under Sec. 9-6.14:1. et sea, of the Code of Virginia nor an adjudication but advises the named facility that available evidence indicates that violations of the Code and/or utations have occurred, and that the Board may consider talung cMI action under Secs. 62.1-44.15(8),62.1-44.23,62.1-44.32(a), 1-44.34:20, or other portinant section of the Code of Virginia.

VIOL.ATION DATE EVIDENCE PERMIT-BOD LOAD.AV. 2.603943/1.13 SEP 1'994 DNR-DISCHARGE 007 PERMIT-BOD LOAD. MAX. 3.887450/1.7 SEP 1994 DMR-DISCHARGE 007 PERMIT-BOD CONC.AV. 159.2/30 SEP 1994 DMR-DISCHARGE 007 PERMIT-BOD CONC. MAX. 237.7/45 SEP 1994 DMR-DISCHARGE 007 PERMIT-TSS CONC.AV. 43.9/30 SEP 1994 DMR-DISCHARGE 007 PERMIT-TSS CONC. MAX. 66.0/45 SEP 1994 DMR-DISCHARGE 007 PERMIT-TSS CONC.AV. 58.9/30 SEP 1994 DMR-DISCHARGE 011 PERMIT-TSS CONC. MAX. 84.0/45 SEP 1994 DMR-DISCHARGE 011 Please advise the Office below within 10 days if this information is incorrect, or if there is other information that the Board should consider. Each listed violation may constitute a separate offense for which penalties or other enforcement action could be sought. State Law requires, and it is in your interest, that you abate any violations as promptly as possible.

Valley Regional Office Phone: (703) 828-2595 116 North Main Street P.O. Box 268 Fax: (703) 828-4016 Bridgewater, VA 22812 JRP ENFORCEldENT REFERRIbThis Nbtice'of ViolNi6nIhis'tidhnNfNr$dt to th

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'Date Time j DEQ Form ENF - 1 (5/94)

I FACIL.lTY OPERATOR (16)

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o North Anna COR 14/. Violations j November 10,~1994 ,

'e'RRTIFTED MAIL.  !

Rarmui RECEIPT REOUESTED i

, , 1 DJanardan R. Panday t

. Valley Regional Office- ,i Department of Environmental Quality  !

P. O. Box 268 'l Bridgewater, VA 22812 RE: ' . NORTE A300L POWER STATION - VPDES PERMIT NO. VA0052451 i

-NOTICE OF VIOIJLTION NO. 94-10-VRO-017- ,

Dear Dr.-Pandey:

This is in response to the subject Notice of Violation (NOV) 1994. The delivered to North Anna Power Station on October 27, ,

violations listed in the NOV.were those experienced as a result of-separate, unrelated sewage treatment plant upsets at the package STP which discharges via Outfall 007 and the main STP, Outfall 011.

Upon discovery of the violations of permitThe limitations, you of explanations were the 1 notified by telephone on October 6, 1994.then discussed in my follow up letter dated upset eve,nts were .!

October 13,'1994. I since the upset events, the previous primary operator has left the l company, new operators have been assigned to these facilities and l operations have been changed to improve performance of.all of the STPs and to help preclude recurrence of similar events. Upset I

conditions were corrected and facility performance improved by:

Outfall 007, Package Sewage Treatment Plant- ,

- The plant was seeded to replace the microorganism 4 population lost during the upset and to increase biological activity.

-- The mixed liquor suspended solids was increased.  ;

- A malfunctioning timer was replaced. .

A failing joint on an air compressor was repaired.

Additionally, in anticipation- of possible increased i

1l flows, the sister package STP (Outfall 005) was started up to be prepared to treat future influent increases. ,

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Outfall 011, Main Sewage Treatment Plant-

- One side of the plant was shut down to increase flow to  ;

the other to 25% of design.

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- one . side ~ of the equalization tank was shut down to decrease holding time 1before influent is processed.. ,

- . Mixed: liquor: suspended solids was increased.to increase Reseeding of microorganisms was used E, -

biological activity. .

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Sludge was cleaned from the equalization tank sides-and l 4

bottom. . ..

Aeration on/off timing was changed from 15 min./15 min.. i

- j to 30 min./30 min.  !

{

Plant -upset recovery and performance improvements brought Results~ BODfor l results at the 007'STP down to 33 mg/l by.10-14-94. 17 'and 21 mg/1,. l TSS .on 10-21, The 10-23 and 10-24 were 33, i

main STP,.011,.was producing TSS of 19 mg/l on respectively. Other BOD results are. not yet  !

10-15 and - 24 mg/l on 10-17. .

i available but will be reported on the appropriate DMRs.  !

As discussed in my follow up letter, ' the receiving waters of the.  ;

STP discharges did not show any evidence there any of environmental indication that problems abnormal. i from the discharges nor was The  :

discharges had ' occurred at any of the discharge points. i discharge rate at outfall 007 is small enough that it likely would  !

have been quickly assimilated by the re .uiving waters at the i subsurface outfall pipe. Any excessive solidsLin the outfall 011 discharge would likely settle out again in the discharge canal or-the Waste Heat Treatment Facility.- No detrimentalWe environmental believe that-damage would be expected from properly either discharge.

characterized as sewage both of these incidents were treatment plant upsets. 1 j

Also, during the visit for delivery of the NOV, the inspector, Mr.

C. L. Auckerman, pointed out that our maximum results had not been

. properly . calculated.

The actual highest single values had been The only item

}

reported on the DMR rather than weekly averages. r where the proper calculation method has any significant impact is Concentration Maximum for discharge 007 This should be 43.9/45 as opposed to the with respect to the'TSS listet 66.0/45 on originally the NOV.reported and is therefore not a violation of the ,

limitations. Corrected DMR pages for the affected outfalls have l,

been submitted.

Should you desire additional information or have any questions ,

about . this matter, please ~ contact Daniel James at . (804) 273-2996. J Sincerely, f .

1 i

B. M. Marshall, P.E.  !

Manager l Water Quality l

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__ _ _ _ _ . _ . _.. . ~. .

0- .

', *Janardan R. Pandey

-November 10, 1994 Pag 2 3 cc: .U.S. Nuclear Regulatory Commission Region II 101 Marietta St., NW Suite 2900 Atlanta, GA 30323 Re: North Anna Units 1 & 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 j j

U.S. Nuclear Regulatory Commission 4 Document Control Desk Washington, DC 20555 '

Re: North Anna Units 1 & 2  !

Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 Mr. R. D. McWorter NRC Senior Resident Inspector North Anna Power Station i

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