ML13163A468

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Modification of National Pollutant Discharge Elimination System (NPDES) Permit No. PA 0009733
ML13163A468
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 06/11/2013
From: Massaro M
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PA 0009733
Download: ML13163A468 (6)
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Text

Exelon Generation 10CFR 50.4 June 11,2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3 Renewed Facility Operating License No. DPR-44 NRC Docket Nos. 50-277 and 50-278

Subject:

Modification of National Pollutant Discharge Elimination System (NPDES)

Permit No. PA 0009733 In accordance with Technical Specifications Appendix B, Environmental Technical Specifications, Section 1.4.2.2 for the subject facility, this letter is being submitted to provide a copy of a modification to NPDES Permit 0009733 issued by the Pennsylvania Department of Environmental Protection and related correspondence. This permit modification revises the schedule for the performance of a thermal study of the Susquehanna River to determine the impact of cooling tower operation. The NPDES permit issued in 2011 had scheduled the study to be completed in 2014. This modification to the permit allows the study to be completed in 2013. This modification does not impact the conclusions of the environmental evaluation performed for the NPDES permit which was transmitted to the NRC by letter dated February 17, 2011 (Adams Accession No. ML110490533).

If you have any questions regarding this matter, please contact Mr. James Armstrong, Peach Bottom Regulatory Assurance Manager at (717) 456-3351 or Mr. Joseph Brozonis, Peach Bottom Sr. Environmental Chemist at (717) 456-3795.

Sincerely, Michael J. Massaro Site Vice President Peach Bottom Atomic Power Station MJM/dnd Attachment cc: US NRC, Regionaol Administrator, Region I US NRC, Senior Resident Inspector, PBAPS CCN: 13-50 tI

Q pennsytvania DEPARTMENT OF ENVIRONMENTAL PROTECTION Southcentral Regional Office CERTIFIED MAIL NO. 9171 9690 0935 033 0142 62 Michael J. Massaro Site Vice President - Peach Bottom Atomic Power Station Exclon Generation Co., LLC 1848 Lay Road Delta, PA 17314 Re: NPDES Permit Modification Request Exelon Generation - Peach Bottom Atomic Power Station NPDES Permit No. PA0009733 Peach Bottom Township, York County

Dear Mr. Massaro:

The Department received Exelon Generation's permit modification letter, dated April 5, 2013, on April 8, 2013, which requested modification of the NPDES permit Part C condition VI. - Cooling Tower Operation. Exelon Generation stated within the April 51h letter that a planned Extended Power Uprate or EPU will take place in December of 2014 for Unit 2 and October of 2015 for Unit 3 at the Peach Bottom Atomic Power Station. Exelon Generation has specifically requested that cooling tower operation from two to three towers be accelerated in order to satisfy the requirements of the 316(a) variance study currently being performed in order to meet NPDES permit renewal submission dates prior to the EPU.

Also, Exelon Generation has requested that the Department exercise its authority to not require Exelon to reduce power generation in the event of the inoperability of a cooling tower during 2013 because a spare cooling tower would not be available.

Based on the information provided within Exelon Generation's April 5ih letter, the Department grants Exelon Generations requests. Please retain a copy of this letter and attach it with the current NPDES permit to reflect the language modification as follows:

Part C VI. - Cooling Tower Operation As part of the Thermal Study set forth in Part C.I1 hereof, and as provided below, the cooling towers shall be operated continuously during the period from June 15 to September 15 during the period 2010 to 2014 according to the following implementation schedule. In the event of any action during the period of tower operation that results in a cooling tower not being operated, the Permittee shall notify the Department of the situation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If a cooling tower will be off line for a period exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as a result of an equipment failure or other situation, the Permittee shall propose a corrective action plan and schedule for returning the tower to full operation to the Department at the time of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification.

The permittee shall provide a report to the Department identifying the cause, steps taken to get the cooling tower back on line and the time that the cooling tower was off line within 10 days unless a longer period is authorized, in writing, by the Department. In the event a tower will be off line for a period greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or such longer period of time agreed to in 909 Elmerton Avenue I Harrisburg, PA 17110-8200 717.705.4707 1 Fax 717.705.4160 tp. www.depweb.state-pa-us Ptfnted on Recycled Paper (Zo

writing by the Department, the Permittee shall bring a spare tower on-line or reduce power generation coimmensurate with the tower's cooling effect until such time as the cooling tower is returned to operation unless otherwise directed by the Department.

  • 2011 - One Tower
  • 2012 - Two Towers
  • 2013 - Three Towers (only two towers are required during one unit operation) e- 2014 -Two Towers (Even though two towers are operating, thermal modeling and biological sampling are not required in 2014 since the Thermal Study will end in 2013.)

Any person aggrieved by this action may appeal, pursuant to Section 4 of the Environmental Hearing Board Act, 35 P.S. Section 7514, and the Administrative Agency Law, 2 Pa.C.S. Chapter 5A, to the Environmental Hearing Board, Second Floor, Rachel Carson State Office Building, 400 Market Street, P.O. Box 8457, Harrisburg, PA 17105-8457, 717.787.3483. TDD users may contact the Board through the Pennsylvania Relay Service, 800.654.5984. Appeals must be filed with the Environmental Hearing Board within 30 days of receipt of written notice of this action unless the appropriate statute provides a different time period. Copies of the appeal form and the Board's rules of practice and procedure may be obtained from the Board. The appeal form and the Board's rules of practice and procedure are also available in braille or on audiotape from the Secretary to the Board at 717.787.3483. This paragraph does not, in and of itself, create any right of appeal beyond that permitted by applicable statutes and decisional law.

IF YOU WANT TO CHALLENGE THIS ACTION, YOUR APPEAL MUST REACH THE BOARD WITHIN 30 DAYS. YOU DO NOT NEED A LAWYER TO FILE AN APPEAL WITH THE BOARD.

IMPORTANT LEGAL RIGHTS ARE AT STAKE, HOWEVER, SO YOU SHOULD SHOW THIS DOCUMENT TO A LAWYER AT ONCE. IF YOU CANNOT AFFORD A LAWYER, YOU MAY QUALIFY FOR FREE PRO BONO REPRESENTATION. CALL THE SECRETARY TO THE BOARD (717.787.3483) FOR MORE INFORMATION.

If you have any questions regarding this approval, please contact Julian Mazero at 717.705.4814.

Sincerely, Maria D. Bebenek, P.E.

Environmental Program Manager Clean Water Program

Exek n Generation, April 5, 2013 Ms. Maria Bebenek Program Manager - Water Management Program PA Department of Environmental Protection Southcentral Regional Office 909 Elmerton Avenue Harrisburg, PA 17110-8200 Re: Exelon Generation Peach Bottom Atomic Power Station NPDES Permit No. PA0009733 APS ID No. 343329 Authorization No. 687514 Peach Bottom Township, York County

Dear Ms. Bebenek:

Exelon Generation Company LLC ("Exelon") hereby requests a minor modification of the above-referenced permit from PA DEP ("DEP") for the Peach Bottom Atomic Power Station ("Station"),

for the reasons set forth below.

Background

" Exelon has determined that it will perform an Extended Power Uprate ("EPU") at the station on Units 2 and 3 and has submitted a License Amendment Request to the Nuclear Regulatory Commission ("NRC") dated September 28, 2012. Exelon expects NRC approval of the EPU by June 2014.

" Unit 2 is scheduled to commence the increase to EPU power in December 2014 upon completion of a planned refueling outage.

  • Unit 3 is scheduled to commence the increase to EPU power in October 2015 upon completion of a planned refueling outage.

Affected NPDES Permit Conditions

" Part C.I1 requires that Exelon perform a Thermal Study as its Clean Water Act (CWA) Section 316(a) variance, in order to study an alternative effluent temperature limitation, evaluate changes in the thermal plume created by operation of up to three helper towers, and as a predictive study of the changes to the station's thermal discharge associated with potential power uprates taking into account the impact of the operation of the helper cooling towers.

" Part C.VI requires that as part of the Thermal Study the cooling towers be operated continuously during the period from June 15 to September 15 from 2010 to 2014, according to the following implementation schedule:

0 2011 - One tower

  • 2012 - Two towers
  • 2013 - Two towers
  • 2014 - Three towers (only two towers are required during one unit operation)

Reasons for Minor Permit Modification

  • Given the scheduled commencement of the increase to EPU power on Unit 2 in December 2014, it is necessary to accelerate the modeling and sampling under the Thermal Study for the three tower operational scenario so that it can be completed in 2013. This acceleration will provide sufficient time for data evaluation and completion of the Thermal Study so that it can be included in the submission of the permit application for the EPU.

" The DEP has indicated in preliminary conversations that timely completion of the Thermal Study can be accomplished by revising the implementation schedule so that three towers are in operation during 2013. Also, while two towers would operate during the specified period in 2014, no sampling and modeling would be required for inclusion in the Thermal Study since necessary sampling and modeling was performed during the two cooling tower operational mode in 2012.

  • Approval by the DEP of this minor permit modification and DEP discretion under the condition in Part C VI - Cooling Tower Operation will constitute an alternate schedule for the Thermal Study pursuant to Section C.111 of the Permit.

Proposed Permit Revisions It is requested that the Permit be revised to read as follows to accomplish the minor Permit modification. In addition, it is also requested that the DEP exercise the authority included in the condition listed below not to require Exelon to reduce power generation in the event a cooling tower goes off line in 2013. Exelon believes this is appropriate given the accelerated schedule for completion of the modeling and sampling required under the permit:

PART C VI. - Cooling Tower Operation As part of the Thermal Study set forth in PartC.llI hereof, and as provided below, the cooling towers shall be operatedcontinuously during the period from June 15 to September 15 during the period from 2010 to 2014 according to the following implementation schedule. In the event of any action during the period of tower operationthat results in a cooling tower not being operated, the Permitteeshall notify the Departmentof the situation within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. ifa cooling tower will be off line for a period exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> as a result of an equipment failure or other situation, the Permitteeshall propose a corrective action plan andschedule for returning the tower to full operation to the Departmentat the time of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification. The Permittee shall provide a report to the Departmentidentifying the cause, steps taken to get the cooling tower back on line and the time that the cooling tower was off line within 10 days unless a longerperiod is authorized,in writing, by the Department.In the event a tower will be off line for a period greaterthan 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or such longer

period of time agreed to in writing by the Department,the Permitteeshall bring a spare tower on-line or reduce power generationcommensurate with the tower's cooling effect until such time as the cooling tower is returnedto operation unless otherwise directedby the Department.

0 2011 - One Tower

  • 2012 - Two Towers
  • 2013 - Three Towers (only two towers are required during one unit operation) a 2014 - Two Towers (Even though two towers are operating, thermal modeling and biological sampling are not requiredin 2014 since the Thermal Study will end in 2013.)

We appreciate the PA DEP's assistance in addressing this Permit modification request so that the EPU project can proceed as scheduled. Upon approval of this request we will work with the PA DEP Water Management Program Staff to make the corresponding modifications to the Thermal Study Work Plan.

Should you have any questions or comments, please contact Joseph Brozonis, Sr.

Environmental Chemist, at 717-456-3795.

Very truly yours, Michael J. Mass ro' Site Vice President Peach Bottom Atomic Power Station ccn 13-28

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