ML050740357
| ML050740357 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/04/2005 |
| From: | Braun R Exelon Nuclear |
| To: | Furjanic S NRC Region 1, State of PA, Dept of Environmental Protection, Bureau of Water Quality Management |
| References | |
| CCN 05-14020 | |
| Download: ML050740357 (4) | |
Text
Exe 6n.M Exelon Nuclear Telephone 717.456.7014 Nue Peach Bottom Atomic Power Station wwwexeloncorp.com udear 1848 Lay Road Delta, PA 17314-9032 March 4, 2005 Mr. Sean Furjanic Pennsylvania Department of Environmental Protection Water Quality Management 909 Elmerton Avenue Harrisburg, PA 17110-8200
Subject:
Peach Bottom Atomic Power Station NPDES Permit PA 0009733 Proposed Alternate Method to Reduce Thermal Discharge
Dear Mr. Furjanic,
The purpose of this letter is to formally request a change in the conditions of our NPDES Permit Number PA 0009733.
We are requesting to add the option to derate the Generating Units as an alternative to operating the cooling towers. We believe that this flexibility will allow us to adequately protect the biological communities in the Conowingo Reservoir.
The remainder of this letter provides you with some background information and then suggests some alternate language for our permit. We request to make this language effective immediately and to incorporate this language into our new permit, which we intend to apply for in May, 2005.
Background
During a construction project at Peach Bottom, the station severed three of the 13kV electrical cables that power the cooling towers.
More specifically, two of these three cables are the electrical feeds to the lift pumps for the B and C cooling towers and the third cable is the electrical feed to the transformer that powers the fans in the cooling towers.
The damage to these three cables means that the only operable lift pump is in the A tower.
The loss of one of the two 13kV fan feeds also means that only six of the eleven fans per tower are available.
cool
Mr. Sean Furjanic March 4, 2005 NPDES Permit PA 0009733 Proposed Alternate Method to Reduce Thermal Discharge Page 2 Peach Bottom is working diligently to repair the cables however, this work may not be completed by the summer months when the cooling towers could, potentially, be needed.
As a contingency plan, Peach Bottom is proposing to reduce total power, equivalent to the heat rejected by two cooling towers, as an alternative to running the cooling towers.
Permit Language Our current NPDES permit states:
In the event of a joint occurrence of 7ow river flows
(<3, 000 cfs) and high ambient water temperatures (>85 degrees F), the station will take appropriate measures to ascertain the potential effects on the local fish community.
The Department will be notified when such conditions occur.
Measures to be taken by the station will be communicated and discussed with the Department at that time.
The station will ensure that two cooling towers are available in the event it is determined that the probability of an adverse impact occurring is high.
If cooling towers are required, tower startup will be initiated as per station operating procedures.
Our proposed wording:
In the event of a joint occurrence of 7ow river flows (c3, 000 cfs) and high ambient water temperatures (>85 degrees F), the station will take appropriate measures to ascertain the potential effects on the local fish community.
The Department will be notified when such conditions occur.
Measures to be taken by the station will be communicated and discussed with the Department at that time. The station will communicate the possibility of needing to reduce power by the equivalent of 25*t per Unit or will ensure that two cooling towers are available in the event it is determined that the probability of an adverse impact occurring is high.
The total station power reduction wou7d be 1757 MWth. If it is determined that an adverse impact is occurring, tower startup will be initiated as per station operating procedures, or a power reduction by the equivalent of 25* per Unit will commence in accordance with the PJM ISO Rules and station procedures.
Mr. Sean Furjanic March 4, 2005 NPDES Permit PA 0009733 Proposed Alternate Method to Reduce Thermal Discharge Page 3 The station will notify PJM of an immediate (within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) load reduction of the equivalent of 25X of one unit (879
/Wth) due to the adverse effects Peach Bottom is having on the local fish community.
After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with no improvement to the local fish population, Peach Bottom will further reduce power by the equivalent of 25$ of one unit (879 WMth), for a total power reduction of the equivalent of 25* per unit.
The only exception to either power reduction or cooling tower startup will be due to emergency power operations as declared by the PJN.
The emergency procedures of the Pil ISO have five actions to take when generation capacity will not meet demand: Maximum Emergency Generation, Load Management Program, Load Reduction Program, Voltage Reduction and Curtailment of Non-Essentia7 Building Load, and Voluntary Customer Load Curtailment. The PJM may initiate these actions in any order.
If these actions fail to alleviate the capacity shortage, the PJi ISO will then begin manual load drops around the region (rolling brownouts or b7ackouts).
Peach Bottom will reduce power up to the point of the PJi initiating manual load drops.
If the PJi believes the Peach Bottom power restriction will cause grid instability and 'they are to the point of manual load curtailment, then Peach Bottom may invoke the emergency need for power and postpone the power restriction until grid stability is returned.
The grid stability will be indicated by the termination of one of the PJi emergency actions for shortage of generation capacity.
The PJM's purpose in all of these actions is to maintain the stability of the electrical grid so the entire region does not experience an uncontrolled blackout or brownout.
Under our current permit, if adverse effects were noted on the local fish community, and the PJM were in emergency operating conditions, they would~request that we delay starting the cooling towers.
The cooling towers place a large demand for electricity on the grid.
Mr. Sean Furjanic March 4, 2005 NPDES Permit PA 0009733 Proposed Alternate Method to Reduce Thermal Discharge Page 4 In closing, we would like to repeat our assurance to the PADEP that we are confident that this additional flexibility will be protective of the indigenous fish population. We look forward to working with you on this issue and we, once again, ask you to give our request prompt attention.
If you have any questions on this matter, please contact either Tracy Siglin (610) 765-5904, Bryan Holcomb (717) 456-3182 or Fred Crosse (717) 456-4494.
Sincerely, Robert C. Braun Site Vice President, Peach Bottom Atomic Power Station RCB/FHC/bcb cc US NRC Region I, Administrator US NRC Resident Inspector, PBAPS US NRC Document Control Desk S. Sklenar, KS B. Schott, PA DEP NPDES Chemistry File CCN Desk Records Management, PBAPS CCN 05-14020