Do inon Pamela F.F azgert Dominion Vice Presidenr and Chief Environmental Officer 5000 Dominion Boulevard, Glen Allen, VA 23060 Phone: 804-273-3467 S0- Sa/f'3q CertifiedM ail Return Receipt Reguested June 28, 2005 Mr. Tom Faha Virginia Department of Environmental Quality Northern Regional Office 13901 Crown Court Woodbridge, Va. 22193 Re: North Anna Power Station Application for Reissuance of VPDES Permit No.VA0052451 Dear Mr. Faha: Submittal Deadline Enclosed is the original reissuance application and a copy of VPDES Permit No. VA0052451 submitted for your review prior to the regulatory deadline of July 11, 2005. Request for Continued 316(a) Variance There have been no substantial changes in the conditions described in our request for a variance under Section 316(a). We request that the 316(a) variance and the alternative effluent limitations referenced in the current permit (VA0052452), Part I.C.12 be continued in the reissued permit. Waiver Requests It is our understanding that waivers granted by the DEQ for the last VPDES permit reissuance continue to apply provided there have been no significant changes at the power station. In accordance with Forms 2C, 2E and 2F instructions, requests previously approved are formally restated in our April 28, 2004 submittal. In addition, we make the following waiver requests. These items were discussed in a meeting on August 19, 2004 attended by Tom Faha, Christine Joyce, Arthur Cooke and Joyce Livingstone. * Dominion requests a waiver for dioxin sampling and analysis for all North Anna VPDES outfalls. * Dominion requests a waiver from conventional sampling and analysis for all storm water outfalls (Outfalls 022, 023, 024, 025, 026) because there is no industrial activity in the drainage areas associated with these outfalls. Elevated iron values are to be expected due to the iron-rich soil types around this area. The previous 2F application forms (2000) are submitted for these outfalls. Mr. Tom Faha June 28, 2005 Page 2 Outfall 103 - Request for Oil & Grease Monitoring Removal - Clarifier: Dominion requests that oil & grease monitoring be removed from internal Outfall 103 in the reissued permit because of the scarcity of laboratories set up to run the hexane method on samples with low levels of radioactivity. Our laboratory manager has advised us that EPA will mandate the hexane extraction method possibly as early as next year followed by a 4-month grace period. If DEQ would consider a substitute parameter, for example, Total Organic Carbon or Chemical Oxygen Demand, these are analyses that the current contract laboratory could perform. The current sampling frequency is quarterly, but we request this be reduced to an annual requirement. The only possible source of oil in the clarifier would be from the mat sump pumps. The mat sumps direct groundwater from around the base of the containment building to the clarifier discharge. There is a small air driven pump in each mat sump with an attached oiler. The only synthetic oil used on site (EHC and snubber fluid) is heavier than water and not a component of the clarifier discharge. The remainder of the discharge is service water, steam generator blowdown and ion-exchange discharge which should not have any oil in it. Outfall 105 -Bearing Cooling Tower - Representative Samples The bearing cooling tower is a closed cycle cooling system. The permanent chemical addition should be completed by the end of August. By mid-September, equilibrium "cycles of concentration" will be established for the system to include bleach, phosphate, zinc and bromine. Dominion expects that representative samples from this system would be attainable in September, and analyses would be available in October. Outfall 009 - Settling Pond - New Contributing Flow Outfall 009 may in the future include bearing cooling tower effluent during periods of maintenance work. This was authorized on a case by case basis in the past, but going we request that the bearing cooling tower effluent be included as an intermittent component of the Outfall 009 effluent. Outfall 111 - Sewage Treatment Plant All the small package plants are closed. Dominion requests approval to submit existing discharge monitoring data and new data for fecal coliforms, ammonia, and oil and grease. Form 2A requests three fecal coliform samples, however Dominion requests a reduction in sampling from three samples to one sample. Outfall 013 - Turbine Building Sump and Common Sump #2 & Storm Water Only Outfall 013 is the discharge for turbine sumps #1 and #2 (unit 1 and common). This outfall is covered in the existing permit, but this description is being added for clarification. Outfall 014 - Turbine Building Sump #2 & Storm Water Only It has been determined from station drawings that Outfall 014 does not release effluent from the Unit 2 (sump #3) high capacity turbine sump. This effluent discharges from Outfall 104, and the current permit describes the contributing flows for this outfall as turbine sump discharges. This pathway (Unit 2 high capacity discharge) has not discharged in over 15 years. There is no industrial discharge for Outfall 014, and we request it-be removed from the permit or redesignated as a stormii water outfall. Mr. Tom Faha June 28, 2005 Page 3 Thank you for the assistance that you have provided to us during the development of this application. We look forward to working with you during the permit development process. Please feel free to contact Joyce Livingstone at (804) 273-2985 should you have any related questions or concerns. Sincerely, Pamela F. Faggert Attachments cc: Mrs. Christine Joyce Virginia Department of Environmental Quality Northern Regional Office (1 additional copy of complete application) 13901 Crown Court Woodbridge, Va. 22193 U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 RE: North Anna Units I and 2 Docket Nos. 50-338/50-339 License Nos. NPF-4/NPF-7 U. S. Nuclear Regulatory C6mmission 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. J. T. Reece NRC Senior Resident Inspector North Anna Power Station Mr. Tom Faha June 28, 2005 Page 4 List of Attachments: 1) DEQ applicationn otification letter- 12/17/04 2) Requestf or Waivers from Sampling and Testing Parameters, 4/28/04 3) VPDES Outfall Descriptions, Sampling Points, Photos 4) EPA Form 3510-1 - GeneralI nformation 5) TopographicM ap - requiredb y EPA Form 3510-1, Section XI 6) PropertyB oundariesM ap - required by EPA Form 3510-1, Section XI 7) VPDES Outfall Location Map - requiredb y EPA Form 3510-1, Section XI 8) VPDES PermitA pplication Addendum 9) EPA Form 3510 -2A Applicationf or Permit to DischargeM unicipal Waste from POTWs 10) EPA Form 3510-2C Applicationf or Permit to DischargeI ndustrialP rocess Wastewater 11) One Line Diagram - requiredb y EPA Form 3510-2C, Section II.A 12) Detection Levels -for analyses on EPA Forms 3510-2A, 2C, 2E and 2F 13) Routinely Used Chemicals and PotentialP ollutants to Surface Water - to support EPA Form 3510-2C, Section V 14) Bearing Cooling Tower System - to support EPA Form 3510-2 C, Section V 15) Data ProcessingD escription - to support EPA Form 3510-2 C, Section V 16)Addendum -Additional Information - to support EPA Form 3510-2C 17)M aterial Safety Data Sheets 18) Outfall 001 Toxicity Data Summary - to support EPA Form 3510-2 C, Section VII 19)E PA Form 3510-2EA pplicationforP ermit to DischargeI ndustrialN on-processs Wastewater 20) Treatment System Component Description (to support EPA Form 3510-2E, Section VI) 21) VPDES Sewage Sludge PermitA pplication Form* 22) TopographicM ap - required by Sewage Sludge PermitA pplication, Section A.5 23) Flow Diagram WWTP - requiredb y Sewage Sludge Permit Application, Section A.6 24) Sludge Management Plan - Revised 10/23/97, Reviewed by Ed Stuart 12/04 25) O&M Manual, Revised 6/23/05 26) EPA Form 3510-2FA pplicationf or Permit to DischargeS torm Water - IndustrialA ctivity 27) Storm Water DrainageA rea Description - to support EPA Form 3510-2F, Section IV-B 28) Heat Rejection Derivation4 /14/05 06/28/2005 20:24 5408942131 NAPS OVERSIGHT PAGE 07 Mr. Tom Faha June 27, 2005 Page 6 W b, ebc: (without attachments) Cathy C Taylor/N/FHIVANCPOWER@VANCPOWER' Robert M Bisha/lN/FH/VANCPOWER@VANCPOWER Alice Corey/IN/FHJVANCPOWER@VANCPOWER Jack Davis/NUC/VANCPOWER@VANCPOWER, Larry LaneINUCIVANCPOWER@VANCPOWER, Jerry Bischof/NUC/VANCPOWER@VANCPOWER, lDebiec @o dec.com bc: (with attachments) Arthur C Cooke - North Anna Joyce Livingstone - Innsbrook Power Records Management - IN/GW File code: Water-Waste Files / North Anna/ ENV 55 / NPDES application EES-Electronic Files: Water-Waste Files / North Anna EEN V 55 NPDES Concurrence: Mr. N.L. Lan G A Mr. P.A. Kemp Mr. A.C. Cooke Dominion - North Anna Power Station NPDES Permit No. VA0052451 Application for Reissuance - -. s - - , _ , , 4~' - ; ., .4;- .. June 28, 2005 Table of I DEO application notification letter -12117104 wJ Contents 2 Request for Waivers from Sampling and Testing Parameters, 4128/04 3 VPDES Outfall Descriptions, Sampling Points, Photos 4 EPA Form 3510-1 General Information 5 Topographic Map 6 Property Boundaries Map 7 VPDES Outfall Location Map 8 VPDES Permit Application Addendum 9 EPA Form 3510 -2A Application for Permit to Discharge Municipal Waste from POTWs 1 0 EPA Form 351 0-2C Application for Permit to Discharge Industrial Process Wastewater I I One Line Diagram 1 2 Detection Levels -for analyses on EPA Forms 3510-2A, 2C, 2E and 2F 1 3 Routinely Used Chemicals and Potential Pollutants to Surface Water 14 Bearing Cooling Tower System 15 Data Processing Description 16 Addendum -Additional Information - to support EPA Form 3510-2C 17 Material Safety Data Sheets 1 8 Ouffall 001 Toxicity Data Summary 19 EPA Form 3510-2E Applicationfor Permit to Discharge Industrial Non-process Wastewater 20 Treatment System Component Description 21 VPDES Sewage Sludge Permit Application Form 22 Topographic Map 23 Flow Diagram WWTP 24 Sludge Management Plan - Revised 10/23197, Reviewed by Ed Stuart 12/04 25 O&M Manual, Revised 6123/05 26 EPA Form 351 0-2F Application for Permit to Discharge Storm Water - Industrial Activity 27 Storm Water Drainage Area Description 28 Heat Rejection Derivation 4114105 29 30 31 tAVERY' READY INDEX INDEXING SYSTEM DEQ Application Notification Letter 12/17/05 Red USC 2C 2004 EP&C m e-e L io, re4 COMMONWEALTH of VIRGINIA DEPARTMENT OF ENVIRONMENTAL QU ALITY Northern Virginia Regional Office NV. Tayloe Murphy, Jr. 13901 Crown Court Robert G. Burnley Secretary of Natural Resources Woodbridge, VA 22193-1453 Director (703) 583-3800 fax (703) 583-3801 www.deq.state.va.us Jeffery A. Steers December 17,2004 Regional Director Ms. Pamela Faggert Virginia Power 5000 Dominion Boulevard Glen Allen, VA 23060 Re: Reissuance of VPDES Permit No. VA0052451, Virginia Power - North Anna Dear Ms. Faggert: This letter is to remind you that your VPDES permit will expire on January 11, 2006. You must reapply for this permit if you wish to continue coverage under the VPDES program. The State Water Control Board's VPDES Permit Regulation requires that we receive a complete application for the Virginia Power -North Anna at least 180 days before the existing permit expires or July 11, 2005. Earl! Submissions are welcome and will better enable us to complete processing before permit expiration. The following is included in the apFion package: * NPDES Form 1 - General Information NPDES Form 2A - Application For Permit To Discharge Municipal Waste From POTWs and Instructions VPDES Permit Application Addendum VPDES Sewage Sludge Permit Application Form and Instructions NPDES Form 2C -Application For Permit To Discharge Industrial Process Wastewater . NPDES Form 2E -Application For Permit To Discharge Industrial Nonprocess Wastewater . NPDES Form 2F -Application For Permit To Discharge Storm Water Associated With Industrial Activity . Common Application Errors Sheet . Public Notice Authorization Form . Pollution Prevention Flyer If you would like a waiver request from any of the sampling or testing requirements in the application forms, please submit a thorough justification for the request as part of your application submission. DEQ must approve these waiver requests at least 180 days before the existing permit expires. DEQ will review your waiver request and forward it to EPA if it is justifiable. Upon completing the application, please return the signed original and a copy of the application to the Department of Environmental Quality Northern Regional Office (DEQ-NRO) at 13901 Crown Court, Woodbridge, VA 22193. DEQ may request that additional copies of the final application package be submitted later. Feel free to contact me at (703) 583-3903 or [email protected] if you have questions regarding submittal of this permit application. Sincerely, Christine Joyce -Environmental Spe list II Request for Waivers from Sampling and Testing Parameters Original submitted 4/28/05 Revised 6/20/05 I)
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