L-20-160, Submittal of Comments in Response to SOOP-04-00086 Draft Comments

Submittal of Comments in Response to SOOP-04-00086 Draft Comments

ML20150A333
Person / Time
Site:	Beaver Valley
Issue date:	05/18/2020
From:	Enos M Energy Harbor Nuclear Corp
To:	Hochhauser M Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection
References
L-20-160
Download: ML20150A333 (5)

Text

menergy

~harbor May 18, 2020 L-20-160 Martin Hochhauser, P.E.

Department of Environmental Protection Bureau of Air Quality 400 Waterfront Drive Pittsburgh, PA 15222

SUBJECT:

Beaver Valley Power Station SOOP-04-00086 Draft Comments Beaver Valley Power Station Route 168 P.O. Box4 Shippingport, PA 15077-0004 Energy Harbor (EH), formerly FirstEnergy Nuclear Operating Company (FENOC),

submits the attached comments in response to the draft of the State-Only Operating Air permit SOOP-04-00086 dated April 20, 2020.

Should you have any questions regarding the attached information, please direct them to Amy Savage, at 724-682-7359.

Ma h J. Enos General Plant Manager

Beaver Valley Power Station, Unit Nos. 1 and 2 L-20-160 Page 2 Attachment(s):

1. BVPS comments for draft SOOP 04-00086 cc:

Document Control Desk US NRC (NOTE: No new US NRC commitments are contained in this letter.)

. BVPS Comments for Draft SOOP-04-00086 L-20-160

• New -

- _, Old

-Section Permit

_P_ermit

• Permit Condition BVPS Comments Page No.

Paae.No.

On October 3, 2016, the Department received an application for a General Plan Approval/General Operating Per the sub facility update submitted Permit, GP-1: Small Gas & No. 2 Oil on 2/7/20, Aux boiler "A" (Source 1

Fired Combustion Units to reauthorize 031) is deactivated and Aux boiler "B:

operation of the Auxiliary Boilers (Source 032) is active having last (Source IDs 031 and 32), since they had operated on 9/9/2019 not operated for a period of greater than 1 year.

Subpart 1111 is applicable to compression ignition (Cl) engines with displacement of individual cylinders less than 30 liters that commenced construction, or 0

reconstruction after July 11, 2005 and An updated list of RICE engines was

~

were not fire pump engines. It is also provided to the state via email on w

~

applicable to fire pump engines with 5/1/2020. HP and LP Godwin pumps, 8

this cylinder size range that SSB Diesel Generator, and GDC Fire commenced construction, or Pump were installed in 2006 or later reconstruction after July 1, 2006. The and would potentially be subject to newest engine at the plant was this subpart.

constructed during 1986. Therefore, no engine at the facility is subject to the requirements of 40 CFR Part 60, Subpart 1111.

Rod Penfield, Site Vice President, BVPS requests clarification on this FirstEnergy Nuclear Operating statement. Was the intent for this 13 Company and Beth Speicher, Air sentence to state that Rod Penfield Quality Supervisor for the District, have reviewed the inspection report?

reviewed a copy of the draft permit.

New REOFF is Matthew Enos -

The REOFF listed is Rod Penfield and General Plant Manager 724-682-1 1

Permit Contact Person is listed as Susan 7773. The New Permit contact person Vicinie.

is Eli Crosby - Manager, Radiation Protection and Chemistry 724-682-

<C 7648.

z BVPS requests FML0l to be "EDG (2) 0 6 4

4 New Fuel Material Locations added DIESEL UNDERGROUND STORAGE w

TANKS."

II)

BVPS requests that the Site inventory Source ID 109, "Misc Emergency list for Source ID 109 be renamed 4

4 Engines (<500-BHP Each, 1,234-BHP "Small Emergency Engines (<500-BHP Total)

Each, 1,234-BHP Total)" and list the engines that fall under this category. - Page 1

. BVPS Comments for Draft SOOP-04-00086 L-20-160

.New Old

.Section*--

• Permit

. Permit Permit Condition

- ** BVPS Comments Page No. - Pc1ge NQ,.

Permit maps were updated based on BVPS suggests the following FMLs:

corrections to Permit Maps:

FML0l and FML02 FML02 FMLOl PROC101 STAC101 FML0l and FML02 FML02 FML0l PROC102 I

STAC102

<C FML06 and FML07 FML06 FML07 PROC103 z

STAC103 0

5 4-5 FML06 FML07 PROC104 5

FML06 and FML07 STAC104 w

II)

FML03 supplies the Security Diesel FML03 Security Diesel Underground Engine, one of the miscellaneous Storage Tank emergency engines listed under 109.

This FML does not supply PROC108.

PROC108, SOSB Emergency PROC108 Generator should have a Stack #108 and no FML associated with it.,

PROC108 STAC108 u

I

1. 003 Processes section was added:

z Particulate matter emissions into the BVPS requests additional information 0

15 13 outdoor atmosphere from any process on how compliance is demonstrated 5

w shall not exceed 0.04 gr/dscf as for this condition.

II) specified in 25 Pa. Code§ 23.13(c)(l)(i).

C z Permit Maps for Source Level Update permit maps in section D per 0

21-32 19-30 5

Requirements comments in section A above.

w II)

In previous permit Section E, #012(f)

(f) the following language was removed "Limited-use boilers are not subject in the new permit but was in the old to the emission limits in Table 1 to w

• permit- "Limited-use boilers are not this subpart, the energy assessment z

0 38 35 subject to the emission limits in Table 1 requirements in Table 2 to this 5

to this subpart, the energy assessment subpart, or the operating limits in w

requirements in Table 2 to this subpart, Table 3 to this subpart." This II) or the operating limits in Table 3 to this language does not appear in the subpart."

current draft, is this condition still applicable to Sources 031 and 032? - Page 2

. BVPS Comments for Draft SOOP-04-00086 L-20-160 New Old Section Permit Permit Permit Condition BVPS Comments Page No.* Page No.

5. The following was added: "PA DEP This observation method is not methodology for duration of standard at BVPS; BVPS requests observation and reduction of visual additional guidance on this.

opacity data observed in accordance with EPA Method 9: The observer shall record observations in accordance with EPA Method 9 for minimum of 60 minutes. The data reduction methodology differs from EPA Method 9 in that it does not require a single continuous time interval and does not

c average datum of individual z

observations. Visual observations in 0

52 N/A accordance with Method 9 take place 6

LU every 15 seconds and are recorded for II) this time interval. Since the observations of 20%, or greater, can be during multiple intervals, the number of high opacity observation readings are merely counted. For an emission limitation of opacity not to equal, or exceed, 20% for a period aggregating more than three minutes in any 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, a total of 13 observations equal to, or greater than, 20% would exceed this standard. - Page 3