ML072470389

NPDES Noncompliance Re Outfall 020 - Perkiomen Storage Tank Discharge

ML072470389
Person / Time
Site:	Limerick
Issue date:	08/24/2007
From:	Callan E Exelon Generation Co, Exelon Nuclear
To:	Garg S Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection
References
NPDES PA 00051926
Download: ML072470389 (3)

Text

Exekn@

Exelon Nuclear www.exeloncorp.com Nuclear LimeTicl Generating Station P.O. Box 2300 Pottstown, PA 19464 NPDES PA 00051926 August 24, 2007 Mr. Sohan Garg Chief, Permits Section Water Management Program Department of Environmental Protection 2 East Main Street Norristown, PA 19401

Subject:

Outfall 020 - Perkiomen Storage Tank Discharge

Reference:

LGS Industrial Waste NPDES Permit PA00051926

Dear Mr. Garg:

The Perkiomen Storage Tank at Limerick Generating Station, fed from the East Branch of Perkiomen Creek, contains river water used for cooling tower makeup. This tank is drained occasionally to support inspections and equipment repair, typically at a twenty-four month average frequency. On 5/26/07, it was drained to perform a preventative maintenance inspection and cleanout, with most of the inventory being gravity fed to the cooling tower basin. Approximately 66,000 gallons of the 1.2 million gallon inventory was discharged to Outfall 020, which has a daily maximum effluent limit of 100 mg/L for Total Suspended Solids. This parameter was a monitor/report value under the previous Permit, with the limit established as part of the LGS NPDES Permit renewal in April 2006.

Sampling of Outfall 020, located 200 yards downhill from the storage tank, is not safely accessible due to the terrain at the tank discharge pipe. Because of personnel safety considerations, the sample is obtained in an area below the pipe, at the Possum Hollow Creek. Water exiting the pipe flows over a rocky area enroute to this location, resulting in the likelihood of introducing non-representative solids into the sample stream. During the draining activity on 5/26/07, four samples were obtained, with TSS analyses results averaging 121 mg/L.

From an equipment configuration perspective, the discharge line is hard piped from the tank to the outfall location, with no sample taps available at ground level. It does not afford a safe or practical means of adding a sample point.

In light of the aforementioned evolution frequency and sampling constraints, this correspondence is to request a reevaluation of the requirement for the Outfall 020 Total Suspended Solids limit, or consideration relative to an increase in the TSS daily maximum limit.

This letter contains no commitments Thank you for your cooperation in this matter. Should you have any questions regarding this information, please contact Bob Alejnikov at 610-718-2513. C O&(D/

Sincerely; Edward W. Callan Plant Manager Limerick Generating Station Exelon Generation Company, LLC cc: S. Collins, Region. 1 Administrator, USNRC S. Hansell, Resident Inspector, USNRC Document Control Desk, USNRC, Wash. DC

bcc: E. Callan - GML 5-1 C. Mudrick - GML 5-1 T. Basso.- SSB 2-1 S. Mitten - SSB 2-1 R. Alejnikov - SSB 2-1 T. Siglan - KSA 3N R. Kreider - SSB 2-4