ML063610119

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Comments on Draft Pottstown Limerick Airport NPDES Permit PA0054089
ML063610119
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 12/19/2006
From: Mudrick C
Exelon Generation Co, Exelon Nuclear
To: Garg S
Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection
References
NPDES PA 0054089
Download: ML063610119 (5)


Text

Exekln Exelon Nuclear www.exelonfcorp.com r

Limev ick Generating Station Nu ea P.O. Box 2300 Pottstown,-PA 19464 NPDES PA 0054089 December 19, 2006 Mr. Sohan Garg Chief, Permits Section Water Management Program Southeast Section Department of Environmental Protection 2 East Main Street Norristown, PA 19401

Subject:

Comments on Draft Pottstown Limerick Airport NPDES Permit PA0054089

Reference:

PADEP Letter from S. Garg dated 11/7/06

Dear Mr. Garg:

The subject draft permit has been reviewed, and the following comments are being submitted for consideration:

1. Page 15, Part C 1.8.b specifies the EPA test method for oil and grease sampling. It is requested that EPA Method 1664A for Total Recoverable Petroleum Hydrocarbons be added to this section.
2. Outfall 003 is currently specified in the, Permit as the representative storm water outfall for required annual sampling. Historically, Outfall 003 has not presented discharge flow without a significant rainfall event of extended duration. Consequently, this outfall has posed a significant challenge in satisfying the associated sampling requirements annotated in "Other Requirements",Section I.F.1. It is. requested that Outfa!l 003 be.replaced with Outfall 002, 007, or 008 as the designated representative storm water outfall. A site map is attached for reference.
3. From a historical perspective, the only chemical containing ethylene glycol that was stored at the airport was Teleflex AL-5, a deicing fluid. The use of this product was terminated several years ago, andall containers of the substance have been removed from the facility.

Based on this information, it is requested that sampling requirements for ethylene glycol be removed for. Outfall 001, and the storm water.outfall.

Should you have any questions concerning any of these comments, please contact Mr. Robert Alejnikov~at (610)"718-2513. It is also requested, that a copy of the Response to Comments Document be forwarded to Limerick Generating Station when complete. Thank you for your attention and cooperation regarding this matter.

Sudri Plant Manager - LGS Exelon Generation Company, LLC Doo(

Attachment:

Pottstown-Limerick Airport Location Map cc:

S. Collins, Region 1 Administrator, USNRC S. Hansell, Resident Inspector, USNRC Document Control Desk, USNRC, Wash. DC

Bcc R. DeGregorio GML 5-1 C. Mudrick GML 5-1 R. Kreider SSB 2-4 T. Basso SSB 2-2 S. Mitten SSB 2-2 R. Alejnikov SSB 2-2 T. Siglin KSA

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