ML20205G819

Provides Comments on Revised Draft Rfa for Duke Power

ML20205G819
Person / Time
Site:	Catawba
Issue date:	03/30/1999
From:	Peed C DUKE POWER CO.
To:	Kumar N ENVIRONMENTAL PROTECTION AGENCY
References
NUDOCS 9904070387
Download: ML20205G819 (4)

Text

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Duke Energy Corpomtion

. bk Catawba Nuclear Station 4800 Concord Road York SC 29730 803-831-3361 _ I March 30,1999 Narindar M. Kumar, Chief RCRA Programs Branch Waste Management Division l EPA Region 4 l Atlanta Federal Center 61 Forsyth Stmet Atlanta, Georgia 30303-8960

Subject:

Catawba Nuclear Station EPA ID No. SCD070619796 l l

Comments On Revised Draft RFA for Duke Power File No.: CN-707.13 Certified: P 374 517 329

Dear Mr. Kumar:

As requested in your correspondence attached to the August 28,1998 RFA Facility Asses <, ment of this ,

I facility, Duke Power provides comments for your consideration.

L General Comments and Corrections l The draft document contains several items which are inaccurate or require clarification. Attachment i 1 is a marked copy of Sections I through Ill of the EPA document. Inserted text is shown in red and I underlined, and deleted text is shown in blue with strike through. j

2. SWh(U #2A - Old 90 Day Storage Area The EPA is requesting confirmatory sampling or documentation regarding the certified clean closure of this SWMU. Duke Power believes the description of this SWMU was inadvertently copied and pasted from previous sections of the report and is not applicable to this management unit.

Mixed waste was never stored at this unit. Paint waste and non-contaminated waste oil were stomd in (y this unit. The unit was never included in the Part A permit or in any revisions to the permit. When the uni; was to be retired, Duke performed TCLP sampling of the soil as a very conservative measure.

Since the unit was closed in 1992 and stored only paint waste and oil, Duke Power believes confirmatory sampling will not provide any meaningful results and is not necessary. Copies of the g\

TCLP sampling performed were presented to the EPA in the August 10,1998 Request for '

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3. SWMU#3A - Current Iandfill .

The EPA is requesting confirmatory sampling of this SWMU. Duke believes confirmatory sampling should not be required. Attachment 2 contains the analytical results used to charact.erize the sludge disposed in the landfill. SCDHEC-issued Permit IWP-192 allows for the disposal of cooling tower sludge, conventional wastewater sludge, and sanitary wastewater sludge. These results indicate concentrations of hazardous constituents are well below any level of concern.

One item for clarification is that the landfill does not have a leachate collection system.

4. SWMU#3B- Formerlandfill t

l The EPA is requesting confirmatory sampling of this SWMU. Duke believes confirmatory sampling should not be required. The former landfill was primarily utilized for the disposal of inert l construction debris. Duke did receive SCDHEC permission to dispose of cooling tower sludge in this unit until the current landfill (SWMU 3A) was operational. Attachment 3 contains the approvals for l disposal of sludge in the landfill. These approvals indicate that concentrations of hazardous l constituents were below levels of concern and additional samples are not required.

! One item for clarification is the landfill does not have a leachate collection system.

5. SWMU#3C-Soolls Area At The Trainine Center l The EPA is requesting confirmatory sampling of this SWMU. Duke Power believes confirmatory /

i soil sampling should be performed. Confirmatory sampling will be performed for this unit as q described in Attachment 4. j

6. SWMU #4B - Unit i Diesel Pad Used Oil Undereround Storage Tank The EPA is requesting confirmatory sampling of this SWMU. Duke Power believes confirmatory l groundwater sampling should be performed. Confirmatory sampling will be conducted for this unit j as described in Attachment 5.

7. SWMU #98- SAA 002 Inside Protected Area Paint The EPA is requesting confirmatory sampling of this SWMU. Duke Power believes confirmatory j soil sampling should be performed. Confirmatory sampling will be conducted for this unit as )

described in Attachment 6. l

8. SWMU #12A - Conventional Wastewater Treatment System -Initial iIolduo Pond l EPA is requesting confirmatory sampling due the release of known hazardous constituents to the soil. -

I Duke Power believes confirmatory sampling is not required.

A line transporting wastewater from the Turbine Building Sump (SWMU #20D) to the Initial Holdup Pond (SWMU #12A) broke and released 30,000 gallons of water containing trace amounts of hydrazine (Iow ppb range) on March 31,1993. This event was reported to SCDHEC and appropriate l

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. . i samples were taken at the time of the release. A SCDHEC rnandated ground water monitoring program is in place for the Conventional Wastewater Treatment System. The monitoring network is composed of one (1) up gradient well and three (3) down gradient wells. Samples are collected semi-annually with results reported to SCDHEC. This sampling will detect hazardous constituents in groundwater. Groundwater monitoring has been conducted since September of 1993 and has not detected hazardous constituents above levels of concerns.

Wastewater sludge in the Initial Holdup Pond (SWMU #12A) must be periodically removed. IWP-192 (SWMU #3A) is permitted to receive this waste stream. He sample results submitted in Attachment 2 for the current landfill can be used to indicate that hazardous constituents are below levels of concern. Any hazardous constituents that would have been released to the soit during the ,

event in question can be detected in the sludge sample taken routinely prior to disposal. Finally, hydmzine breaks down chemically to ammonia and neutral saks. The event being questioned I occurred during 1993 and sampling in 1999 will not provide any meaningful data.

9. SWMU #12B - Cenventional Wastewater Treatment Svstem - Settline Basins i EPA is requesting confirmatory sampling of sediments from the settling basins. The rationale is that since the basins are equipped with clay liners only, hazardous constituents may have been released to the environment. Duke Power believes confirmatory sampling of sediments from the settling basins is not required.

As discussed above for SWMU 12A, a SCDHEC mandated ground water monitoring program is in  ;

place for the Conventional Wastewater Treatment System. The monitoring network is composed of 1 one (1) up gradient well and three (3) down gradient wells. Samples are collected semi-annually with results reported to SCDHEC. This sampling will detect hazardous constituents in groundwater.

Groundwater monitoring has been conducted since September of 1993 and has not detected hazardous constituents above levels of concerns.

The wastewater sludge in the Initial Holdup Pond (SWMU #12A) must be periodically removed.

IWP-192 (SWMU #3A) is permitted to receive this waste stream. The sample results in Attachment 2 for the current landfill are used to indicate that hazardous constituents are below levels of concem.

Any hazardous constituents that would have been released to the soil or groundwater from the basins can be detected in the sludge sample taken routinely prior to disposal. l 1

To ensure that hazardous constituents are not being released to Lake Wylie at NPDES Outfall 002 at I levels above concem, Duke Power agrees to conduct confirmatory sampling as described in Attachment 7.

10. SWMU #18- CNS Garare OiUWater Separator The description of this unit incorrectly identifies the location as below grade. De unit is located above grade on a concrete pad with containment curbing incorporated. Any leakage or release from the unit is visible by the operators and is contained by the designed curbing. The EPA is requesting confirmatory sampling of this unit. Duke Power believes confirmatory sampling is not required base (

on the information stated above.

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11. AOC A - Diesel Fuel Contaminated Soil Area The EPA is requesting a RFI for this unit. Duke Power believes the RFI should not be required.

Confirmatory groundwater sampling will provide data that ensures hazardous constituents are below any level of concem. SWMU #4B described above includes this AOC. The confirmatory sampling described in Attachment 5 applies directly to this AOC.

12. AOCB-Sulfuric AcidRelease Area The EPA is requesting a RFI for this unit. Duke Power believes the RFI should not be required.

Duke Power has investigated the increased levels of sulfate and conductivity in this area. Attachment i 8 provides the details of this investigation.

'Ihe results of Duke's investigation indicate sulfate is restricted to a fairly limited area in the cooling tower yard and the area around the conventional wastewater treatment system. Sulfate is neither a listed hazardous substance nor is it included in the primar; drinking water standards. It is not contained in Appendix XIII to 40 CFR 261. Sulfate is included as a secondary drinking water standard with a limit of 250 mg/1. Groundwuer in the area of the sulfate detection is not used as a drinking water source. SWMU #12 contains the area described in this AOC. The sampling program described for SWMU #12 applies directly to this AOC. Semi-annual monitoring of the groundwater wells surrounding SWMU #12 continues with results reported to SCDHEC. Sulfate is included in this monitoring.

If you have questions or comments, please ccatact Cheryl Peed, Environmental and Safety Manager, at 803-831-3361 or Tim Harris, Environmental Management, at 803-831-3656.

Sincerely, Cheryl Pee Manager, Environmental and Safety Attachments 1 - 8 cc: Keehna Fraiser, SCDHEC Nuclear Regulatory Commission Standard Distribution (w/o attachments)

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