ML20069K258

Responds to Insp Rept & Deficiency Notice Received at Plant Following 940322 Insp.Since No Prior Notice of Changes to Std Methods Rule Given,Impacted Permittees Should Be Allowed Reasonable Time to Come Into Compliance W/Any Changes

ML20069K258
Person / Time
Site:	North Anna
Issue date:	06/09/1994
From:	Marshall B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Warner S ENVIRONMENTAL PROTECTION AGENCY
References
NUDOCS 9406150345
Download: ML20069K258 (5)

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CERTIFIED MAIL RETURN RECElPT REQUESTED VMGMM POWM June 9,1994 Ms. Susan Warner USEPA Region ill 839 Bestgate Road Annapolis, MD 21401 RE: NORTH ANNA POWER STATION, VPDES PERMIT #VA0052451

Dear Ms. Warner:

This is in response to the inspection Report and " Deficiency Notice" received at North Anna Power Station following your March 22,1994, inspection. On the date of that inspection, you deemed the station operation to be "a model lab," and only a few minor concerns were identified during that inspection. This was also reflected in the body of the written inspection report. However, we were disappointed that the minor concerns were characterized as " deficiencies" in a " Deficiency Notice" which appears to have a high degree of significance. Considering the actual nature of the concerns described in the inspection report and the significance of the changes, updates and/or improvements needed, it would seem more appropriate to convey such items in a comment section of the inspection report rather than as a " Deficiency Notice." Virginia Power practices a policy of going beyond mere compliance with environmentallaws and regulations. While minor isolated errors may have been made, we feel that they were truly insignificant, and damage has neither been done to our overall state of compliance nor to the environment.

The following points address the specific issues identified in the notice and inspection report:

l Standard Methods North Anna Power Station had obtained the 18th edition of Standard Methods prior to the inspection and copies of the publication are on order for the System Lab.

The new edition is now being used as the reference for analysis methods instead of the 17th, for parameters where Standard Methods is cited.

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c i Ms. Susan Warner

. June 9,1994 Page 2 We do not agree that this issue should be characterized as a " deficiency" in the report. It should be noted that, in the 1-31-94 Federal Register notice of the change from the 17th to the 18th edition of Standard Methods, the USEPA stated that "the 18th edition methods were found to be technically equivalent to the approved 17th edition methods." Also, in substantiating its decision to forego notice to the rulemaking, EPA said "the updates to method references do not change the methods contained therein." Since the EPA had deemed the methods in use as technically equivalent and had claimed that they were not changed, no urgency to change a cited methods source existed. Further, since there was no prior notice of the rule change, any impacted permittees should be allowed reasonable time to come into compliance with any changes.

Total Chlorine / Additional Samples At the time of this inspection, we provided you with information which related to the l station's OC/OA methods. Some of those data were from sampling and analyses conducted by the Station Chemistry department as internal process control, as l opposed to discharge sampling conducted by the VPDES laboratory staff. Station Chemistry samples are, intentionally, taken from upstream locations within the station processes and facilities other than the outfalls and/or sampling locations covered by the discharge permit to provide an opportunity to adjust any process inadequacies in order to meet effluent discharge limitations. These data are not reported on the DMR since they are not equivalent to VPDES sampling and not representative of any discharges.

Records of VPDES sampling data indicate that all relevant data have been properly reported on the DMRs, including extra samples. If this concern is based on data from Station Chemistry sampling as opposed to data related to VPDES sampling, this item should be deleted from the Deficiency Notice.

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1 Chain-of-Custody Form Il l

The use of a chain-of-custody form, as recommended, will be implemented as of 6-1-94.

Total Suspended Solids  !

i Forms and procedures are currently being reviewed and will be revised where necessary to incorporate the appropriate weighing time notation and to provide for demonstration of sufficient drying time.

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Ms. Susan Warner June 9,1994 Page 3 pH and Residual Chlorine Holding Times All sampling where "immediate" analysis is required shall be done in compliance with the 15 minute limitation indicated in 40 CFR 136. This has already been implemented.

However, we do not agree to this item being characterized as a " deficiency" since a 30 minute limitation was being applied at the direction of our delegated Virginia r3gulatory agency. In instances where there is inconsistency over a procedure, interpretation, etc., between USEPA and the Virginia DEO, which issues the permit and provides guidance to the permittee, that inconsistency should be resolved between the agencies and the regulated community informed of the specifics of the resolution prior to holding the permittee accountable in the issue.

July 1992 DMR Data During preparation of the July 1992 DMR, the values for Total Chlorine and Chlorine Maximum were incorrectly transcribed from the data sheet to the DMR form.

The average value for Oil & Grease was correctly listed as 2.65. The values for samples taken were 2.40 and 2.90. This item should be removed from the report.

Laboratory Recommendations As recommended, the use of duplicate and spiked samples will be evaluated and they will be used when found to be helpful to improve validity of analyses.

An apparatus to capture Freon from the Oil & Grease analysis for recovery has been purchased for North Anna Power Station and will be put into use when installation can be accomplished.

The presence of zinc in the field and trip blanks associated with Outfall 010 toxicity samples has been recognized. But, one purpose of the blanks should be to identify contaminants from sampling and analysis methods and equipment so that they are not attributed to the discharge being sampled. However, we are currently evaluating " clean" sampling techniques which may alleviate problems with extraneous contaminants.

Ms.-Susan Warner June 9,1994 i Page 4 l Should EPA insist that a Deficiency Notice remain a part of the record in this matter, we l respectfully request that an amended notice be issued which construes the factual nature l of those items. For example, the Sample Collection / Holding Time item should indicate l that we were complying with the state agency's interpretation of the generic term "immediate" as requiring analysis within 30 minutes rather than EPA's interpretation as within 15 minutes. It should also be considered that, if the time frame for the procedure has analytical significance, the method itself should indicate a specific measurement rather than a generic term.

Accordingly, the Test Procedures item should state that the source publication of the procedures had recently been changed from the 17th to the 18th edition of Standard Methods. At the time of this inspection, EPA was on record that the procedures had not been changed by this reference source update. We feel that this should have been a mere informational update as opposed to a deficiency in our procedures.

We feel that the changes already begun, or to be implemented, satisfy EPA requirements and that the issues raised by your report have been resolved. I hope that you will honor our request to change the characterization of thosa l'cns as we suggested. If you have any further questions, please feel free to call me at 904) 273-2990 or Daniel James at (804) 273-2996.

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

Manager Water Quality cc: Mr. William Purcell Water Division Department of Environmental Quality P.O. Box 11143 Richmond, VA 23230-1143 l Ms. Carol Amend-Lovell (3WM55) l Water Compliance Section EPA Permits Enforcement Branch 841 Chestnut Street Philadelphia, PA 19107 i

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Ms. Susan Warner June 9,1994 Page5 ,

cc: U.S. Nuclear Regulatory Commission Region ll l 101 Marietta St., NW Suite 2900 i Atlanta, GA 30323 Re: North Anr.a Units ' & 2  :

Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 j l

U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Re: North Anna Units 1 & 2 i Docket Nos. 50-338/50-339 '

Ucense Nos. NPF-4/NPF-7 Mr. R. D. McWhorter NRC Senior Resident inspector l North Anna Power Station 1

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