L-21-121, Draft NPDES Permit No. PA0025615
| ML21123A166 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/05/2021 |
| From: | Enos M Energy Harbor Nuclear Corp |
| To: | Decker R Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection |
| References | |
| L-21-121, PA0025615 | |
| Download: ML21123A166 (2) | |
Text
- e~ergy harbo*r April5,2021 L-2_1-121 Ryan Decker,, P.E.
- Department of Environmental Protection, Clean Water Prog*ram Southwest Region.al Office 400 Waterfront Drive Pittsburgh,.PA 15222-
SUBJECT:
Beaver Valley Power Statwn Route 168
.P.O.Box4 Shippingport, PA 15077-0004 Beaver Valley Power Station (BVPS) Draft NPDES Permit No. PA0025615
Dear Mr. Decker,
In response to several potential ch~llenges associated with the new permit, the BVPs* is.
- requesting the followi.ng modifications to the implementatio"n of the new permit:
1". The plant requests a-two-year extension to *make the ~odifications n~ary to manage and treat low volume waste stre~ms at internal monitoring po!nts (IMP) 601 and 701. These IMPs were created to monitor low volume waste streams, as part of the new draft permit pub~ish~d M~rch 27, 2021:
As you might.recall from our previous discussions, IMP 601 is a small sump with an estimated flow of <0.001 MGD. _IMP -701 is intended to capture various sources of equipment drainage and leakage that is di~chargecf_ to tne cooling tower blowdown line (Outfall 001). These internal monitoring points will be monitored for low volume*
waste parameters pH, TSS, and Oil & Gre~se.
BVPS ~as ide~tified thi:it sampling ~nd potentially treating wastewater at these new.
IMPs will be a-challenge due to limited ~ump.and *storage capacity and limited space*
inside the p!ant. Additionally,* we may periodically be challenged with meeting pH and TSS limits at these. IMPs depending on plant conditions and _Ohio River conditions. Per prior. ~iscussions with PADEP staff, BVPS is.exploring *several options *including operational and equipment *modifications to meet'. the new requiremel"!ts. BVPS has *identified pot~ntial solutions. for water management both.
onli~e and during outages; however, these solutions are not' easily or quickly. -
implemented due to the complex process for ma~ng changes at *a nuclear facility.
The time required to develop the engineering design.changes, allocate funding, plan the work,** and implement. these changes wiil take longer than the available time
~fore the permit renew~I is anticipated to be.issued.
Beaver-Valiey Power Station, Unit Nos. 1 and 2 L-21-121.
Page 2_
n,erefore,
- a two-year extend.ed _.implementation period at. lMPs 601 and 701 will provide addit,onal time n~ed to make the modifications -neces~ry to manage snd treat these low vofume waste streams. The* pH.. limit at final outfall 091 is not e~(;lcho be challenged at any time by the flow contrit;>Utio~s of the 601/701 waste
-s~ms based on our operating experience and sampling history. *
- 2. The plant requests a tw<ry~r delayed implementation of the mercury iimits being established in this permit* renewal. During th~ time, we propose to continue to *_
- sample at all required outlets as a rep_ort-o(liy parameter. Based on our very limited sampling history with this parameter, there *is some uncertainty* as to whether we will
~ challe,:iged to meet these limits all year With changing *seasons and river -
conditions. We* would like some more time t~ ~tablish a comprehensive sample
- history so that'we can understand what correlation, jf any, there may be between our in~ke water mercury ~rJcentrations and our discharge water.*
- 3. The plant requests a twp-y~r delayed implementation of the stormwater iron *
- benchmark limits established in this permit* renewal. Severi *new sformwater outfalls have been established with th.is permit* with which We have very limited sample -
- history. The_re is some uncertainty as to whether we will be challengeq to meet these benchmarks. We would like some more time to establish a comprehensivErsample history so that we can understand what cnalleng8$ we might have with managing stormwater* iron. During this time, we will coritini.J_e to sample *a_nd report results from these outfalls,-implement pest management practices, and pursue any necessary corrective actions associated with elevated storrilwater contaminants.
- 4. BVPS i~ also requestihg a period *of ninety (90) *days to i:9.mply with the final permit
- following issuance to a_llow the site sufficient tim~ to align the current procedures and business practices with the new permit requireme~ts.
- _We-appreciate your consideration of 01.:1r concerns a*nd would like an opportunity to talk about the issyes discussed in this letter. Should you _have any questions please contact Amy Savag~ at aesavage@energyharbor.com or 7~4-68_2-7359.-
- Sincerely, J. Enos*
ral :Plant Man*ager
- cc:
mtfeMiireiSU@G>fitiilijfll!)e'_sRlt!J;SIN~~w-US NRC commitments_*ar~ contair,ed in this letter.)