ML18152B817

Discusses Results of Data Contained in Discharge Monitoring rept-QA (Dmr/Qa) Dtd 980114

ML18152B817
Person / Time
Site:	Surry, North Anna
Issue date:	05/18/1998
From:	Hadder A VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Stewart R VIRGINIA, COMMONWEALTH OF
References
NUDOCS 9805220256
Download: ML18152B817 (11)

Text

S1,,te111 Laboraton*

e POW 04/QA Results i 1..:0 I Old Stage *Road Cbeste1; Virginia .1383 I Mr. Roger Stewart March 18, 1998 Page 1 \

CERTIFIED MAIL VIRGINIA POWER RETURN RECEIPT REQUESTED March 18, 1998 Mr. Roger Stewart Virginia Department of Environmental Quality OWRM-WQAP P. 0. Box 10009 629 E. Main Street Richmond, VA 23240-0009 RE: DMR-QA RESULTS FOR VIRGINIA POWER FACILITIES

Dear Mr. Stewart:

We have carefully evaluated the data contained in the Discharge Monitoring Report-Quality Assurance (DMR-QA) report dated January 14, 1998, where results were judged to be unacceptable.

A ,,checls was made at each facility for potential sources of error and we have determined the following:

Bath Countv Power Station (Permit No. VA0053317)

Ceriodaphnia Chronic Data as % of Sample: Reprod., IC25 - MHSF testing was performed by Coastal Bioanalysts, Inc. Corrective action for this test is detailed in the attached two letters from Peter F. DeLisle, PhD. and the EPA.

Bremo Power Station (Permit No. V A0053317)

Ceriodaphnia Chronic Data as % of Sample: Reprod., IC25 - MHSF - see attached letters.

/

Chesterfield Power Station (Permit No. 004146) ,1

/\;~tv7 Ceriodap_1Ei-ia C4tc;mic D_fil<J__a_s_o/o of Sample: Reprod., IC25 - MHSF - see attached letters.

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• c,aos220256 PDR ADOC_t( 6~g&A~aoPDR

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S1,,tem Laboratory*

i 1201 Old Stage *Road Mr. Roger Stewart e

POW 04/QA Results 0Je.,*rc,; Virginia 2383 I March 18, 1998 Page 2 North Anna Power Station (Permit No. VA 0052451)

'VIRGINIA POWER Ceriodaphnia Chronic Data as% of Sample: Reprod., IC25 - MHSF - see attached letters.

Possum Point Power Station (Permit No. VA 0002071)

Ceriodaphnia Chronic Data as % of Sample: Reprod., IC25 - MHSF - see attached letters. -

The Station analyzed another Chlorine blind sample which was procured by System's Laboratory from Environmental Resources Associates. The analyst ran this sample blind.

This was a "dilute to analyze" sample yielding 0.76 ppm by the station. The true values stated for the sample by Environmental Resource Associates was 0.734 ppm with an acceptance range of 0.551-0.918. As you can see this was well within the acceptance range.

The analyst reviewed the DMR testing and noted all the standards were freshly prepared and a new standardization curve was determined. New rechargeable batteries were properly conditioned before running the study 17 tests.

Prior to analyzing the follow up sample the DPD reagent was purchased new in November 1997 and the potassium permanganate in March 1998. No other apparent sources of error were noted. Since the removal of the sewage treatment plant, the station only runs this test annually for the DMR QA study.

Surrv Power Station (Permit No. V fi. 0004090)

Toe Station analyzed another TSS blind sample which was procured by System's Laboratory from Environmental Resources Associates. Toe analyst ran this sample blind. This was a "ready to analyze" 500 ml. sample yielding 29.4 ppm by the station. The true values stated for the sample by Environmental Resource Associat,~s was 30.9 ppm with a11 acceptance range of 26.3-35.6. As you can see this was well within the acceptance range.

The analyst reviewed the actual procedure performed for the DMR sample and found the apparent problem to be one of mixing. While transferring the dry powder, a deionized water bottle was used to rinse the powder into the volumetric flask. Toe analyst noted a puff of powder fly up while spraying into the flask. A loss of powder would result in a low reading, which is what was recorded for this location.

Yorktown Power Station (Permit No. VA 0004103)

Ceriodaphnia Chronic Data as % of Sample: Reprod., IC25 - MHSF - see attached letters.

S1'.~te111 Laboraton*

Mr. Roger Stewart e

POW 04/QA Results j I .JO I Old Stage *Roacl Cbeste1; \'irgi11ia .2383 I March 18, 1998 Page 3

• VIRGINIA POWER All Virginia Power laboratories take pride in their ability to perform accurate analyses contributing to the success of our in state VPDES program. They will strive to improve, however and wherever feasible. An internal quality assurance program utilizing check samples three times per year is in place and we believe that this program assures that all of our laboratories are performing with a high degree of precision and accuracy.

If you have additional sugge:;;tions of how to improve our programs, or if you have any questions regarding the information provided, please feel free to contact Mr. David Yaworsky of my staff at (804) 717-5901.

Sincerely, a.~-~~

A. W. Hadder Manager ,

Environmental Policy & Compliance cc: U.S. Nuclear Regulatory Commission Region II .

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 Regulatory Commission Document Control Desk Washington, DC 20555 RE: North Anna Units 1 and 2 Docket Nos. 50-338/50-339

• . License. Nos*.NrF~41NPf-7:

M )y[~~-.M*_; {_:;;¥9.rg~c~ * . : . *~

,- *, NRC Senior Resident Inspector North Anna Power Station

S1"*tem Laborato111 i 1201 Old Stage Road e e Cbeste,; Virgi11ia 23831 POW 04/QA Rc:su1i:s 7'&. Roger Ste;wart .

March 18, 1998 Page 5 Concurrenc::s fig~

..1.. c.-S < o.. ~ . .

VIRGINIA POWER Mr. D. S. He3Cock lvfr. p. A.. Kemu

Mr. A. C. Cooke Action Plan No action is required.

V eriiication of Accuracv S= attached lette:s.

Commitments No commitments for North Anna Power Station.

Chan!Zes to the* UFSAR or OA Totiic:tl Re=ort

' None.. -~

Concurrences for Surrv Mr.M.A.Holland  ?.:_Cr~~ l f f l . i { . ~ ~ ~ ~)-f6-'i3

- = e Coastal Bioanalysts Inc.

i' March 9, 1998 Mr. Ken Roller Virginia Power Innsbrook 3 SW 5000 Dominion Blvd Glen Allen, VA 23060

Dear Ken,

In response to the "not acceptable" results reported by our lab for method code 21

( chronic Ceriodaphnia IC25, moderately hard synthetic freshwater) in EPA Dlv1R-QA Study 17, we have reviewed the original bench sheets for errors (none found) and re-analyzed the original reference toxicant. I believe the following points will clarify the matter and confirm the ability of our laboratory to perform these tests.

1. Because the "true value" and acceptance limits are based on statistical 95% prediction intervals there is always a 5% probability that a competent laboratory will report a value outside the limits. However, as noted in the attached letter from Paul Britton (EPA-NERL, February 20, 1998) the value for such "in-control" laboratories would likely be close to the acceptance limit. This is the case for our laboratory where our reported IC25 of3 l.1% was only 0.2% different from the upper acceptance limit of30.9%. Also, the lower 95% confidence limit (26.'5%) of our IC25 value falls well within the EPA acceptance limits .

._,/  :?

2. The Study 17 reference toxicant was re-tested from 2/16/98 to 2/22/98. The reproduction IC25 of 21.9%, reproduction NOEC of 12.5% and survivai NOEC of25%

are in agreement with the EPA values.

3. Finally, regarding any issues of permit compliance, reporting ofIC25s is not required in VPDES permits. Although IC25 values are evaluated in the DMR/QA study (because they are used by many other states for regulatory purposes), they do not need to be reported by VPDES permittees. Of course the ability of a laboratory to correctly evaluate additional end-points of the same test used for compliance monitoring is a concern for the permittee. In regard to this latter point I am confident of our ability to measure the "true" IC25 of toxicants based on the statistical considerations and re-test results discussed above.

In response to the "unusable" results reported for method code 44 (acute Menidia beryllina) these results are to be considered "typical and completely acceptable

e e EPA D.MR-QA Response March 9, 1998 Page 2 of2

= Coastal Bioanalysts Inc.

100% for this species. This was because less than 50% of the organisms died in the highest concentration tested ( 100%). After submission of study results to EPA we tested the toxicant on numerous batches of J\1. beryllina concurrent with effluent tests and were never able to kill 50% or more of the animals in the 100% concentration. Apparently this was the also case for 28 of the 53 labs reporting (see attached EPA summary report).

This was because the toxicant concentration selected by EPA to prepare 100% simulated effluent was too low.

If you have any questions or concerns please do not hesitate to call me at 804-694-8285.

Sincerely, Peter F. De Lisle, Ph.D.

President Attachments

UNITED ST!s ENVIRONMENTAL PROTECTION NATIONAL EXPOSURE RESEARCH LABORATORY Alcv CINCINNATI, OH 45268 February 20, 1998 OFFICE OF RESEARCH AND DEVELOPMENT

Dear Toxicity Laboratory:

Thank you for sending a copy of your DMR-QA Study 17 whole-effiuent toxicity results to the .

USEP A at the same time you sent it to your permittees. Your data were used in conjunction with

• data from other reporting laboratories to establish the study acceptance limits for the toxicity endpoints. Enclosed is a complementary copy of the Performance Evaluation Report on your data and a summary report which allows you to compare your performance to results for the entire study. Reported data were "usable" whenever they were NOT less-than or greater-than values. However, even though judged "UNUSABLE" in the enclosed report, less-than values must be considered acceptable responses whenever the acceptance interval ends in "D.L."; and greater-than values must be considered acceptable responses whenever the acceptance interval ends in "10 l 11. See the enclosed page discussing interpretation of "UNUSABLE" performance evaluations for the three DMR-QA Study 17 endpoints that had acceptance limits ending in "101 11

• Acceptance limits for NOEC results were set at the median reported value plus and minus one dilution. Acceptance limits. for all other endpoints were set statistically as 95% prediction intervals using robust statistical techniques, i.e., such intervals should contain 95% of the data reported by laboratories operating "in control". Since 93. 7% of the data reported by toxicity laboratories during DMR-QA Study 17 were within the acceptance limits, most of these laboratories would seem to be doing a good job. The 5% of data from "in-control" laboratories that might fall outside the acceptance ljmits would tend to be close to a limit. Those interested in

• limits for endpoints they did not report can get them by calling Mantech at (919)406-2164.

Sincerely yours, Paul W. Britton, Statistician *

• National Water Quality Assurance Programs Branch Ecological Exposure Research Division Enclosures (3): As Stated.

cc: Region and State DMR-QA Coordinators John Helm, USEPA, OECA, Mail Code 2225A, 401 M Street, S.W., Washington, DC 20460 James Lazorchak, USEP A, Room 642, 26 M.L.King Drive, Cincinnati, OH 45268 Ryan Boera, ManTech Env. Tech., P.O.Box 12313, 2 Triangle Drive, RTP, NC 27709 Paulette Yongue, ManTech Env. Tech., P.O.Box 12313, 2 Triangle Drive, RTP, NC 27709 Internet Address (URL)

• http://www.epa.gov Recycled/Racyclabl*

• Printed wtth Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)

i' IJr.. ID 1 e 2 3 4 e 5 . 6 4* --------------------------------------------------------------------

.nc. Tested O 6.25 12.5 25 50 100 esponse 1

. .*20 10 21 19 0 0 esponse 2 25 22 23 27 14 0 esponse 3 25 23 26 25 0 0 esponse 4 24 27 19 21 0 0 2sponse 5 29 24 21 27 9 0 2sponse 6 22 24 30 26 0 0 2sponse 7 15 27 19 19 0 0

sponse 8 22 24 23 21 0 0

~sponse 9 22 19 19 18 0 0

~sponse 10 24 23 24 12 13 0

• Inhibition Concentration Percentage Estimate***

)Xicant/Effluent: EPA fst Star~ Date: /62797} Test Ending Date: 7397

st Species: C DUB IA

st Duration: 6D TA FILE:

nc. Number Concentration Response Std. Pooled D Replicates  % Means Dev. Response Means 1 10 0.000 22.800 3.676 22.800 2 10 6.250 22.300 4.900 22.400 3 10 12.500 22.500 3.536 22.400 4 10 25.000 21.500 4.813 21.500 5 10 50.000 3.600 5.929 3.600 6 10 100.000 0.000 0.000 0.000 I-------------------------------------------------------------------

' Linear Interpolation Estimate: 31Ll453 Entered P Value: 25 b~ of Resamplings: 80 Bootstrap Estimates Mean: 30.2034 Standard Deviation: 1.8254 ginal Confidence Limits: j Lower: 26. 5306 Upper: j 32. 8571 ampling time in Seconds: 0.22 Random Seed: 717006905

1 3 4 e 5 6

c. Tested 0 6.25 12.5 25 50 100

sponse 1 *35 34 34 30 0 0

sponse 2 24 30 25 25 0 0 asponse 3 30 26 28 27 0 0

sponse 4 26 28 26 18 0 0

sponse 5 35 16 17 21 0 0 asponse 6 37 32 31 8 0 0

sponse 7 36 34 32 32 0 0

sponse 8 31 37 36 29 0 0

sponse 9 28 25 30 26 0 0 esponse 10 34 42 32 3 0 0

• • Inhibition Concentration Percentage Estimate***

~xicant/Effluent: EPA STUDY 17 TOXICANT est Star~ Date: j021698f Test Ending Date: 022298 est Species: C DUBIA est Duration: 6 D TA FILE:

ne. Number Concentration Response Std. Pooled D Replicates  % Means Dev. Response Means 1 10 0.000 31.600 4.502 31. 600 2 10 6.250 30.400 7.214 30.400 3 10 12.500 29.100 5.446 29.100 4 10 25.000 21. 900 9.643 21.900 5 10 50.000 0.000 0.000 0.000 6 10 100.000 0.000 0.000 0.000 e Linear Interpolation Estimate: !21.8750] Entered P Value: 25 rnser of Resamplings: 80 e Bootstrap Estimates Mean: 21.2602 Standard Deviation: 3.6155 iginal Confidence Limits: Lower: 16.0748 Upper: 29.3080 sampling time in Seconds: 0.16 Random Seed: -919295565

e e To Toxicity Laboratories that Participated in DMR-QA Study 17:

u Normally, the frequency ofless-than or greater-than responses among DMR-QA study toxicity results is very low, because we have instructed you to prepare each simulated effluent at a toxicant concentration that makes such indefinite responses unnecessary. This is important because less-than and greater-than responses are not _compatible with the statistical procedures we use to set most of the acceptance limits. Therefore, our computer system is programmed to judge less-than or greater-than responses as "unusable" whenever the interval identified by the indefinite response covers some portion of the acceptance interval.

In DMR-QA Study 17, we received an unusually high number of "> 100" responses for three toxicity endpoints; the endpoints with acceptance limits ending in "101 ". This was caused by the concentrations of the related simulated effluents being too high. For these three endpoints in DMR-OA Study 17, "UNUSABLE" evaluations for "> 100" responses should be considered as typical and completely acceptable performance.

All definitive values reported above 100 were judged "UNACCEPTABLE", because such values are not normally reported on DMR reports.

• If you have questions or comments on the way we evaluated toxicity data during Div1R.-

QA Study 17, you may contact Dr. James Lazorchak by calling* (513)569-7076.

We regret any inconvenience or concern that this situation may have caused you, and we

,. pledge to tty harder to avoid such situations in the future.

1 '

summary Report for All P~rticip~nts D~R-QA to1icity Study Number 017 e

Pe ~ er t :

P a,1e:

rate: 2.3JANQe I= F. Cl C 2

Total

Participants:

278

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~--------------------

True Results Net Value ~~epo rtP.rl usable \ccept.

\PfilHA 11 AG NA . ACUTE: DAT.\ AS

.,,. 0" 5.~ MPLE:

! d- r.: 5 0 - ~ HSf, 20 DEG.

2e.2 60 60 '3 6 LI

., OF lPHMIA PULEX ACUTE DAT! "s /Q SA~?LP.:

12-L: 50 MHSf, 20 DEG.

35.4 52 52 so 2 14-L:SO - l'!HSf, 25 DEG.

ll 9 Q9 Q5 *q 26.5

'.SI DO PSIS BAHIA. ACUTE *oAT.~ AS

...... OP !B:i!PL~::

lo- LC 50 - 40F, 20 DFG*

68.7 q 57 q7 10

'SIDOPSIS BAHIA CHRONIC DATA AS% or SA~PLE:.

19-SUHVIVA.L, NOEC - 40F 50 48 47 3

.: .... ,( ~ ....... .' ";'

10-GHO*TH, IC25 40F 62.3 Q2 31 2

• . ~:.. ..

11-GRO*TH, NOF.C - 40F 50 47 46 ,, 0 . 6

NIDIA BERTLLIN! ACUTE DAT, AS: or SAMPLE:

I J- .LC 5 0 - 40F, 2 0 DEG

• 9 0 .ti 5*3 25 20 5 lEEPSHfAD ~!~NOW ACUTE DAT! AS: or SA~PlE:

,q-J_cSO - l!Of ,.'i 20 DEG.

25.0 33 33 32 .1 EtPSHEAD ~tNNOW CHRCNIC DATA AS% OF SA~Pt!:

s-sa RVIVAL,. NOEC - tJOF 25 23 *2 .3 23 c*

,6-GkOWTH, IC25 LIOF 3 s.s 19 19 18 1 7-GROWTH, NOEC uor 25 23 23 21 2 tals foe TOXICITY 017

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2,150 2,092 1,961

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1.31

. .~ "*' .

... .. . .....