ML20153G013

Requests Approval for Extended Compliance Schedule for Specific Provisions of Part III (9 VAC25-91-130,Pollution Prevention Requirements) for North Anna Nuclear Power Station

ML20153G013
Person / Time
Site:	North Anna
Issue date:	09/22/1998
From:	Hadder A VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Lilliard L VIRGINIA, COMMONWEALTH OF
References
NUDOCS 9809290321
Download: ML20153G013 (3)

Text

Innsbrook 1hhnical Center SIXX) Dominion ihmierard ie Glen Allen, Virginia 2J060 i

Hand Delivered VIRGINIA POWER September 22,1998 Mr. L. Samuel Lilliard Office of Spill Response and Remediation Virginia Department of Environmental Quality 629 East Main Street Richmond, VA 23240-0009 Re: AST REGULATIONS EXTENDED COMPLIANCE SCHEDULE-NORTH ANNA NUCLEAR POWER STATION (ODCP NO. FC-06-7030)

Dear Mr. Lilliard:

In accordance with section 9VAC 25-91-40.B of the Facility and Aboveground Storage Tank (AST) Regulations, Virginia Power is requesting approval for an extended compliance schedule for specific provisions of Part III(9 VAC 25-91-130, Pollution Prevention Requirements) for North Anna Nuclear Power Station. The facility has an aggregate storage capacity of less than 1 million gallons. The specific provisions and proposed compliance dates are as follows:

Inventory control and testing for significant variations (9 VAC 25-91-130.B.1) will be

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completed by February 28, IP99. The major portion of the work required to comply j

consists of revising procedures and reviewing instrumentation systems.

Safe fill and shutdown practices (9 VAC 25-91-130.B.3) will be completed by February

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28,1999. The major portion of the work required to comply is procedure revisions.

Visual daily and weekly inspections (9 VAC 25-91-130.B.5) will be completed by

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February 28,1999. Most of the provisions of this section are included in existing pro:edures; however, to include the remaining items will require procedure revisions.

The primary reason in requesting approval of an extended compliance schedule is the method of operation practiced at the station as required by the NRC and necessitated by the safety concerns related to operating a nuclear power station. In order to assure safe operation of the station we operate through an extensive system of written procedures. In fact, the NRC requires compliance with approved station procedures and it is not appropriate for us to operate systems without an approved procedure in place. To comnly with the previously specified provisions of the AST regulation we will need to revise more than 60 procedures.

Following the initial draft incorporating the pollution prevention requirements, each of the procedures must undergo an extensive review and approval process.

l 9809290321 980922 PDR ADOCK 05000338 P

PDR

Mr. L. Samuel Lilliard I.

^ September 22,1998 j

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The procedure revision process is also affected by the station undergoing an outage during September and October. The amount and scope of the major outage activities (e.g., refueling, equipment maintenance and replacements, system inspections) increases the time required for i

the procedure revision process.

Please contact Wes Sprouse at 273-3552 with any questions.

Sincerely, l

si.40 A. W. Hadder Manager Environmental Policy & Compliance i

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Mr. L. Samuel Lilliard

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September 22,1998

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U.S. Nuclear Regulatory Commission Region II 1

Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, GA. 30303 RE: North Anna Units 1 and 2 i

Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: North Anna Units 1 and 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 Mr. M. J. Morgan NRC Senior Resident Inspector North Anna Power Station