ML20196G221

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Forwards Licensee Sampling & Testing Obligations Re Vpdes Permit VA0052451 Reissuance Application.Details of Requests for Sampling & Testing Waivers,Included
ML20196G221
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 06/21/1999
From: Livingstone J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: Pandey J
VIRGINIA, COMMONWEALTH OF
References
NUDOCS 9907010084
Download: ML20196G221 (13)


Text

4 Innshrensk lenhntual Center t e t s M100 thaninion ihnoleraral Glen Allen, Virginia JUKsn l

June 21,1999 Dr. Janardan R. Pandey b Valley Regional Oflice  %

P,0. Box 1129 vmointa rowest Harrisonburg, Virginia 22801-1129 Ee: Request for Waivers from Sampling and Testing Parameters 1

Reissuance of VPDES Permit No. VA0052451 Virginia Power- North Anna Power Station {

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Dear Dr. Pandey :

The attached document identifles our sampling and testing obligations for the above-mentioned VPDES permit reissuance application, and details our requests for sampling and testing waivers. While some of the waivers have been previously approved, the requests are formally restated in accordance with Forms 2C,2E and 2F instructions.

Outfall 019, Domestic Water Overflow is entirely composed of groundwater used for the potable water supply. No pollutants are added to this water, and a discharge would occur only if the holding tank overflowed. We request that this outfall be deleted from the permit. ,

Outfalls 101 and 102 are not in use. The flash evaporator systems have been dismantled and we would like to delete these outfalls from the permit. There are no plans to reinstall this equipment or reactivate I these discharges.

Outfall 114 is a new proposed outfall, Service Water Pipe Vault Drain. This new outfall will be used when leakage accumulates in the Pipe Vault adjacent to the Service Water Reservoir. Outfall 108 will be sampled to represent this outfall.

If you have any questions, please contact me at (804) 273-2985.

Sincerely, Joyce B. Livingstone Senior Environmental Specialist i Environmental Policy and Comphance l I

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. r Dr. .lm.crdin R. Pzndey ATTACHMENT June 21,1999 Page 2 of 14 REOUEST FOR WAIVERS FROM SAMPLING AND TESTING PARAMETERS VPDES PERMIT NO. VA0052451 - NORTH ANNA POWER STATION 1.1ST OF VPDES OUTFALLS EXTERNAL OUTFALLS Outfall 001 Discharge of Condenser Cooling Water from WHTF at Dike 3 Outfall 009 Settling Pond l Outfall 013 Turbine Bldg Sump #1 and Common Sump & Storm Water only l Outfall 014 Turbine Bldg Sump #2 & Storm Water only l Outfal1016 Intake Screen Wash Water Outfall 019 Domestic Water Overflow l Outfall 020 Reverse Osmosis Reject i

Outfall 021 Reverse Osmosis Drain Line Drainage Area #2A (storm water only)

Outfall 022 Outfall 023 Drainage Area #2B (storm water only)

Outfall 024 Drainage Area #3 (storm water only)

Outfall 025 Drainage Area #18 (storm water only) 0:iiiall 026 Drainage Area #25 (storm water only)

INTERNAL OUTFALLS Outfall 101 Flash Evaporator - Unit 1 Outfall 102 Flash Evaporator - Unit 2 Outfall 103 Process Waste Clarifier Oulfall 104 Oil / Water Separator & Storm Water Outfall 105 Bearing Cooling Tower Blowdown Outfall 107 Bearing Cooling System Discharge - LA to Lake Operation Outfall 108 Service Water Overflow Outfall 109 Hot Well Drain Unit 1 Outfall 110 Hot Well Drain Unit 2 Outfall 111 Main Sewage Treatment Plant Outfall 112 Steam Generator Blowdown Unit 1 Outfall 113 Steam Generator Blowdown Unit 2 Outfall 114 Service Water Pipe Vault Drain (NEW OUTFALL)

' Dr. Janirdin R. Pandey ATTACHMENT June 21,1999 Page 3 of 14 l

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This outfall continuously discharges condenser cooling water from the Waste Heat Treatment Facility (WHTF) to Lake Anna at Dike 3. The retention time in the WHTF is greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

BODsCOD and TOC, Total Suspended Solids, Ammonia Temocrature (summer): j We will submit data from a grab sample in accordance with Form 2C instructions (retention period of greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). A waiver for the off-season winter temperature is requested because it is regularly submitted in quarterly reports to DEQ.

Flow: Existing flow data for 1998 will be submitted consistent with reporting required by the current permit (1/ month, calculated).

pH Existing data for 1998 will be submitted consistent with sam 1, ling required by the current permit (1/ year, grab, at Dike 3 bafore subsurface discharge to the Lake).

'Part B and C narameters: All Part B parameters and Part C metals will be sampled with the following exceptions. Pesticides, PCBs, Dioxin, Fecal coliforms, sulfite, surfactants, color, volatiles an acid / base / neutral organics are believed absent based on previous data and will not be sampled.

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This intermittent discharge is from ground water, backwash cleaning from sand filters and reverse osmosis units with the majority of the discharge consisting of storm water amoff.

The retention time > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l BODS. COD TOC, Ammonia, Temperature (summer): We will submit data from a single grab sample in accordance with Form 2C instmetions. A waiver for the off-season winter temperature requested.

Total Suspended Solids: Existing TSS data for 1998 will be suaitted consistent with reporting l required by the current permit (1/ month, grab).

, Flow: Existing flow data for 1998 will be submitted consistent with reporting required by the current permit (2/ month, estimated).

pH: Existing data for 1998 will be submitted consistent with sampling required by the current permit (1/momh, grab). Form 2C specifies that grab samples be used for pH and oil and greas Part B and C oarameters: All Part B parameters and Part C metals will be sampled with the following exceptions. Pesticides, PCBs, dioxin, fecal coliforms and sulfite are believed abs previous data and will not be sampled.

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- : Dr. Janirdin R. Ptndey ATTACIIMENT June 21,1999 Page 4 of 14

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O,stfall 0137 ,,

4 Turbine ~ Bide Sumn #1 & C6,nsmon Sumn & Storm Wakr osly i l

This intermittent outfall is an alternate discharge route for the emuent making up the majority of the flow at Outfall 104. Outfall 104 will be sampled to represent this outfall.

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This intermittent ouifall is an alternate discharge route for the emuent making up the majority of the flow at Outfall 104. Outfall 104 will be sampled to represent this outfall.

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l This outfall is a low volume, non-process discharge that consists entirely oflake water. This outfall is represented by intake data.

g .p,s We request that this outfall be deleted from the permit. This infrequent intermittent discharge is composed entirely of groundwater that is used for the potable water supply. No pollutants are added and no treatment occurs. A discharge would occur only if the holding tank overflowed. The retention time i of the holding tank is < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. To support our request that this outfall be deleted, the following data l will be submitted from a sample collected from a tap inside the Domestic Water Pump House buildmg. l 1

! BODS. COD, TOC, Total Suspended Solids Ammonia. Temperature (summer): We request a waiver from the 4 hourly grab sampling requirement to be substituted with results from a single grab i sample, and a waiver for the off-season winter temperature is requested.

l l pJill A single grab sample will be collected and analyzed in accordance with Form 2C instructions.

Part B and C parameters: We request a waiver from the 4 hourly grab sampling requirement to be substituted with results from a single grab sample. All Part B parameters and Part C metals will be sampled with the following exceptions. Pesticides, PCBs, dioxin, fecal coliforms, sulfite and surfactants are believed absent based on prevhus data and will not be sampled.

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  • i Dr.Jarrd:n R. Pandcy ATTACHMENT June 21,1999 Page 5 of 14 l

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This outfall is designed to discharge continuously, but there are times, which are rare, normally during outages when no make-up water is needed and all tanks are full, when it does not discharge. It consists of reverse osmosis reject water that contains only a 3.3x concentration of constituents oflake water, and l a potential residual of 0-1 ppm free chlorine from sodium hypochlorite used in the Ionics system. No process waste waters or pollutants from other sources are added. Also, this outfall discharges into the incoming cooling water flow just outside the intakes. The retention time < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. {

BODS COD. TOC, Ammonia. Temocrature (summer): We request a waiver from the 24-hour composite sample requirement to be substituted with results from a single grab sample, and a waiver for .

the off-season winter temperature is requested.

Total Suspended Solids: Existing TSS data for 1998 will be submitted consistent with sampling required by the current permit (2/ month, grab).

Flow: Existing flow data for 1998 will be submitted consistent with reporting required by the current permit (2/ month, estimated).

oH Total Residual Chlorine: Existing data for 1998 will be submitted consistent with sampling required by the current permit (2/ month, grab).

Part B and C parameters: We request a waiver from the 24-hour composite sample requirement to be substituted with results from a single grab sample. All Part B parameters and Part C metals will be sampled with the following exceptions. Pesticides, PCBs, dioxin, fecal colifotms and sulfite are believed absent and will not be sampled.

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'6ffi$llWiiP W IREpFAFDiliidilf63{5?DEE This outfall intermittently and infrequently discharges pure lake water from the reverse osmosis system.

Intake water will be used to characterize this outfall.

This outfall has never been used and is in the permit for emergency use only in the case where the whole ionic system is down and the line needs to be drained.

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.  : Dr.J=:rds R.P ndey ATTACHMENT l June 21,1999

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y gQff*ff5 F w*T yj.g[g y y q Q jfy*jgfyy[Qg[gy y [Gf This is an area of approximately 52 acres, with approximately 7.1 acres ofimpervious area. Storm water collected in the higher portion to the south, contractor shops, parking lots and the switch yard, flows into i a drop grating to a culvert near the nonheast corner of the switch yard and discharges into Lake Anna at Outfall 022. The lower, more level portion includes a vehicle maintenance shop, a paint shop and part of an outdoor equipment lay down area. Storm water runoff from the grassed portions of this area adjacent to the lakeshore is generally sheet flow. Form 2F will be submitted.

Oil and Grease, pH. Total Residual Chlorine: Grab samples will be collected and analyzed.

l RCh COD. TSS. TKN. Nitrate plus Nitrite. Total Phosphorus: Grab and flow-weighted cor@osite samples will be collected. Samples will not be analyzed for sulfite or radioactivity.

Bromide. Color. Fluoride. Sulfate. Sulfide. Surfactants. Aluminum Barium. Boron. Cobalt, Iron.

Mannesium. Molybdenum. Maneanese. Tin Titanium: Grab and flow-weighted composite samples l will be collected and analyzed.

Antimony. Arsenic. Beryllium. Cadmium. Chromium. Conner. Lead. Mercury Nickel. Selenium.

Silver. Thallium and Zinc: Grab and flow-weighted composite samples will be collected and analyzed. Samples will not be analyzed for fecal coliforms, cyanide, phenols, volatiles, acids,

! base / neutrals and pesticides. Based on previous analytical results these pollutants are not believed to be present.

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This is a small area of approximately 6 acres. The only impervious area is the 0.09 acre storage building which is used for hazardous waste accumulation, with other miscellaneous storage. This storage l

i building is constructed with a curbed foundation to contain any spillage and prevent any discharge outside the structure. Storm water collected in the higher portion to the south flows into a culvert under this storage building then discharged into Lake Anna at Outfall 023. Storm water runoff from the grassed portions of this area adjacent to the lake shore is generally sheet flow.

Same Monitorine as Outfall 022 l

l U5dA (N55 W Yb 5iEE E YEE5iN5 ?Ei$5fEf555 EYE $iEi A small drainage area of 9 acres with primarily sheet flow runoff of stormwater to Lake Anna. About l

0.08 acre is paved impervious areas. A ponion of the laydown area, shared with Area 2A has runoff throufdha drop culvert under the roadway and into Lake Anna at Outfall 024.

Same Monitorine as Outfall 022 l

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!- r Dr.J n:rd= R. Prndcy ATTACIIMENT June 21,1999 i Page 7 of 14 g gg}ge g e nty g(gg g g g r g p g g g grg g This 56 acre drainage area, with 4 acres ofimpervious area, includes a portion of the warehouse I facilities, an outdoor laydown area and some small utility buildings. Storm water from the northern l portion of this drainage area is conveyed under the paved roadway via two culverts. The culvert to the l west carries the smaller amount of storm water flow which drains from open, grassed fields with no industrial activity. The culvert to the east was chosen as the sample point from Area 18 because it l carries the collected drainage from the larger portion of the area, from the warehouse and laydown I

facilities, and would be more likely to contain any contaminants. Outfall 025 discharges storm water l from this drainage into the Waste Heat Treatment Facility.

l Same Monitorine as Outfall 022 l 1

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M Ostfall 026: U.. .:erainnee Ar,ea #254c yi.yp.m y.y.4__s orm water on:y l A 61 acre drainage area with no impervious surface area. In the northern portion of Area 25, there is a site used l for temporary exposed storage of discarded miscellaneous material such as large concrete " dead weight" blocks l for crane weight testing, small movable buildings, etc. This portion of the drainage area has runoff through a j culvert under the roadway and into Lake Anna at Outfall 026. This culvert was selected as the sample point for )

Area 25; no industrial activities occur downstream. As with other lakeside areas, sections adjacent to the shoreline, north of the graveled roadway have sheet flow runoff of storm water.

Same Monitorine as Outfall 022 P

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We request that this outfall be deleted from the permit.

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We request that thie outfall be deleted from the permit.

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  • f Dr.Jan:rd:2 R. P;ndcy ATTACHMENT June 21,1999 Page 8 of 14 i r

mpy y gg g This intermittent discharge now includes intermittent lower volumes of steam generator blowdown, also l package boiler blowdown (not currently in use) and mat sump system discharge and ion exchanger l waste. We would like to initiate continuous blowdown of the Service Water Reservoir through this outfall with this new permit. Engineering data will be submitted to characterize this additional flow which will be substantially identical to Outfall 108. There is a holding tank at the end of this system with a retention time > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

BODS. COD. TOC Total Suspended Solids. Ammonia. Temperature (summer): We will submit data from 1 individual grab sample in accordance with Form 2C instructions, and a waiver for the off-season winter temperature is requested. ,

Flow: Existing flow data for 1998 will be submitted consistent with reporting required by the current permit (2/ month, estimated).

oH. Oil & Grease: We request a waiver from the single grab sample to be substituted with existing data for 1998 submitted consistent with sampling required by the current permit (2/ month, grab).

Part B and C oarameters: All Part B parameters and Part C metals will be sampled with the l

following exceptions. Pesticides, PCBs, dioxin, fecal coliforms, bromide, fluoride, sulfate, sulfide and 4 sulfite are believed absent and will not be sampled.

g g gmmq q g g g g gyg This discharge was previously approved to represent Outfalls 013 and 014 (Turbine Building Sump

  1. 1, Common Sump and Turbine Building Sumps #2). The flow is intermittent, and the retention time is

< 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

BODsCOD. TOC. Ammonia. Temperature (summer): We request a waiver from the 4 hourly grab sample requirement to be substituted with results from a single grab sample, and a waiver for the off-season winter temperature is requested.

Flow: Existing flow data for 1998 will be submitted consistent with reporting required by the current permit (2/ month, estimated).

Total Suspended Solids, pH. Oil and Grease: Existing data for 1998 will be submitted consistent with sampling required by the current permit (2/ month, grab). Form 2C specifies that grab samples be used for pH and oil and grease.

Part B and C parameters: All Part B parameters and Part C metals will be sampled with the following exceptions. We request a waiver from the 4 hourly grab sampling requirement to be substituted with results from a single grab sample. Pesticides, PCBs, dioxin, fecal coliforms, sulfite, volatiles and acid / base / neutral organics are believed absent and will not be sampled.

t . Dr.Jan:rd:n R. Pandey ATTACHMENT June 21,1999 Page 9 of 14 gggen 7rgrgg^grggy"ggg*ggg+g This outfall was previously intermittent but used very infrequently. To control the water chemistry in the system, it will become a continuous discharge when either of the units is operating. The retention I

time will be < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Engineering data has been previously submitted to characterize the treatment chemicals that will be used in this system and will be included with this application. A grab sample will i also be collected from the Bearing Cooling Tower reservoir. l l

BOD 5, COD, TOC, Total Suspended Solids, Ammonia, Temperature (summer), nH, Oil and Grease: We request a waiver from the 24-hour composite sampling requirement and request approval l

to submit data from 1 individual grab sample, and a waiver for the off-season winter temperature is requested.

Flow: Flow data will be estimated based on projected operations.

Part B and C narameters: We request a waiver from the 24-hour composite sampling requirement and request approval to submit data from 1 individual grab sample. All Part B parameters and Part C metals will be sampled with the following exceptions. Pesticides, PCBs, dioxin, fecal coliforms and sulfite are believed absent and will not be sampled.

ggggy my gg g.g.ggggggggsgg.gg This outfall is not currently in use. If a discharge were to occur, it would be temporary when the bearing ,

cooling tower is valved off for maintenance work, and this is likely to occur within the next five years.

Lake water would pass through the bearing cooling system, bypass the cooling tower and go straight to the WHTF. No treatment chemicals are used. There is no retention time. Intake data will be submitted to represent this outfall. October Free Cl2 and flow data are available.

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- t Dr.Jrrd a R. Pandey ATTACHMENT June 21,1999 Page 10 of 14 ggfjjiggg?Tgfg[gg%if76);Wify This outfall is manually operated with a valve, and is intermittently used to control the level of the Service Water Reservoir as necessary. The retention time of the service water reservoir is > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

A sample can be collected from the bank of the Service Water Reservoir near the intake structure.

Outfall 108 is substantially identical to the proposed new Outfall 114, the Service Water Pipe Vault Drain and we request approval to sample Outfall 108 as the representative outfall. Outfall 108 will also characterize the additional new flows from the Service Water Reservoir to the Process Waste Clarifier.

BODsCOD TOC Total Suspended Solids. Ammonia. Temperature (summer). Flow: We will submit data from a grab sample in accordance with Form 2C instructions, and a waiver for the off-season winter temperature is requested.

pH. Oil and Grease: A single grab sample will be collected and analyzed for pH and oil and grease in accordance with Form 2C instructions.

Part B and C parameters: All Part B parameters and Part C metals will be sampled with the following exceptions. Pesticides, PCBs, dioxin, fecal coliforms and sulfite are believed absent and will not be sampled.

Q fg g y w p y g g g f;g g This intermittent outfall was previously approved to represent Outfall 110 (Hot Well Drain #2),

relatively high-purity condensate water, with small concentrations of corrosion chemicals. The drains are normally used once per 18 months, on alternating schedules, during maintenance shutdowns of the respective units. To obtain a representative sample, this must be sampled during outages (Unit 2 - Hot Well #2, September 1999; Unit 1- Hot Well #1, March 2000). The retention time > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

BODS. COD. TOC Ammonia. Temperature (summer): We will submit data from a single grab sample in accordance with Form 2C instructions, and a waiver for the off-season winter temperature is  ;

requested.

Total Suspended Solids: Existing TSS data for 1998 will be submitted consistent with reporting required by the current permit (1/ month, grab).

Flow: Existing flow data for 1998 will be submitted consistent with reporting required by the current permit (1/ month, estimated).

pH. Oil & Grease: Existing data for 1998 will be submitted consistent with sampling required by the current permit (1/ month, grab). Form 2C specifies that grab samples be used for pH and oil and grease.

Part B and C parameters: All Part B parameters and Part C metals will be sampled with the following exceptions. Pesticides, PCBs, dioxin, fecal coliforms, bromide, fluoride, sulfite, sulfate, surfactants, volatiles and acid / base / neutral organics are believed absent and will not be sampled.

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  • 1 Er. Janordan R. Pmdey AITACHMENT June 21,1999 Page 11 of 14

{jg fjjjijlf?%? *iT g h qj[jips[g Tj Outfall 109 will be sampled to represent this outfall.

'6"d&lii?illfPT65NiinTdIEEN5 FEE $ipjAEl All domestic sewage is routed to the main sewage treatment plant. The plant is equipped with two .

i equalization basins, each with a capacity of18,700 gallons. During normal operation only one side is used but during periods of high demand (outages) both sides are used.

' BOD TSS pH. Total Residual Chlorine Flow: We request a waiver from the 24-hour composite sample as required by Form 2E and request approval to submit existing data for 1998 consistent with I

reporting required by the current permit for these parameters.

Ammonia: We request a waiver from the 24-hour composite sample as required by Form 2E and request approval to submit data from a single grab sample to be taken for ammonia.

Temocrature (summer). Oil & Grease. Fecal Coliform: Existing data from 1998 grab samples collected in accordance with the current permit will be submitted for these parameters, and a waiver for the off-season winter temperature is requested.

COD. TOC: Not required, per instructions on form (non-contact cooling water is not discharged).

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This outfall was previously approved to represent Outfall 113 (Steam Generator Blowdown Unit 2), and discharges relatively high-purity condensate water from e closed system with small concentrations of corrosion chemicals continuously while Unit 1 is operating. It is only shut offduring outages (every 18 months) for maintenance. The retention time < 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

BOD (COD. TOC. Ammonia. Temperature (summer): We request a waiver from the 24-hour composite sampling requirement and request approval to submit data from a single grab sample. A waiver for the off-season winter temperature is requested.

Total Suspended Solids: Existing TSS data for 1998 will be submitted consistent with reporting required by the current permit (1/ month, grab).

Flow pH. Oil & Grease: Existing flow data for 1998 will be submitted consistent with reporting required by the current permit (Flow - 1/ month, estimated; pH, Oil & Grease 1/ month, grab). Form 2C specifies that grab samples be used for pH and oil and grease.

Part B and C Darameters: All Part B parameters and Part C metals will be sampled with the L

following exceptions. Pesticides, PCBs, dioxin, fecal coliforms and sulfite are believed absent and wi not be sampled.

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' Dr. Jancrdan R. Pandey ATTACHMENT June 21,1999 3

Page 12 of 14 I

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! 6Ellijiif{Ji""*"T5[ElWdEEEEdiEF5jfWgfGEDEiii Outfall 112 will be sampled to represent this outfall.

ggggggmepuggggggggg7gggggg7pggggyp;;gygggggggggg;j This new outfall will be used when leakage accumulates in the Pipe Vault adjacent to the Service Water Reservoir. We request approval to represent this discharge with data from Outfall 108, the Service Water Overflow.

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  • o Dr.Janardan R. Pandey ATTACIIMENT June 21,1999 Page 13 of 14 cc: (w/ attach.)

U. S. Nuclear Regulatory Commission Region 11 Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 RE: North Anna Units 1 and 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 U?S Nuclear RsguEstory ddmniissio$

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

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