ML20073H470
| ML20073H470 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 05/01/1991 |
| From: | Lyster M CENTERIOR ENERGY |
| To: | OHIO, STATE OF |
| References | |
| NUDOCS 9105070136 | |
| Download: ML20073H470 (4) | |
Text
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.y CENTERIOR ENERGY 6200 004 kee Boulevard Mod Address independence OH PO Bo.t 94661 216 447 310 0 Clevesona. 0H 441014661 May 1, 1991 PY-CEI/0 EPA-0127 L Ohio Environmental Protection Agency Division of Water Pollution Control Permite Section P.O. Box 1049 1800 Watermark Drive Columbes,. Ohio 43266-0149 OEPA Permit No.: 3IB00016*DD Public Notice No. OEPA-91-04-017 Gentlemen:
Pursuant to Ohio Environmental Protection Agency Public Notice Number OEPA-91-04-017,- dated Apri? 4,1991, the Cleveland Electric Illuminating Company (CEI) submits the following comments to Draf t NPDES Permit Number 3IB00016*DD for the Perry Nuclear Power Plant (PNPP), located in Lake County, Ohio.
Outfall 6004, Point Representative of Discharge Prior to Entry to the Tunnel Which Discharges to Lake Erie, page 4 of 14:
1.
CEI recommends that proposed Discharge Limitations and Monitoring Requirements for Residue, Total Non-filterable (Reporting Code 00530) be i
deleted. The previous NPDES permit (No. 31B00016*CD) states in Part II, item D, page 7 of 14, the permittee's cooling water intake has been determined to reflect best technology available pursuant to Section l
316(b) of the Clean Water Act (CWA). Therefore, it is our understanding that no discharge limits for residue, total non-filterable (or total L
suipended solids) are applicable per 40CFR Part 423.13.
k.
l In addition, it is our position that plant operations have no deleterious i
ef fect on Lake Erie and that its water quality is being adaquately l'
protected. The proposed limit for Residue, Total Non-filterable (17MG/L) is overly restrictive and would be impossible to obtain with any degree of conoistency, based on the following information.
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Our assumption is that the limit proposed by the Ohio EPA was based on data provided by CEI in the Permit to Install (PTI) application for PNPP, filed June 10, 1974 (see Answer 1 to Question No. 14 of the PTI).
However, the data provided in Answer i to Question No. 14 of the PT1 was l
only intended to show the negligible effect of plant operation on i
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4 OEPA Permit No.83IB00016*DD Public Notice No. OEPA-91-04-017 discharge water quality, based on nominal lake water composition, and was not intended to represent a design limit independent of lake water composition. The inconsequential effect of Outfall 6004 on lake vater quality is also provided in the ansver to Question 16 or the PTI, which shovs that the daily loading of suspended solids (in pounds / day) in lake vater intake is not altered by plant discharge.
Additionally, the data on lake water suspended solids provided in the PTI application was based on limited early studies.
Additional lake water suspended solids data are presented below to put this in the proper perspective.
The source referenced la the PTI application for vater quality data was the Environment Report prepared by NUS Corp. for PNPP. Additional data vere later compiled in the Invironmental Report - Operating License Stage (ER-OLS), docketed with the U.S. Nuclear Regulatory Commission (Docket Number 50-440). Data from Table 3.6-2 of the ER-OLS shovs that lake water had a suspended solids range from 1 to 200 HG/L.
Most recently, daily suspended solids levels of 1989 and 19R9 samples from our EastlL4e and Ashtabula C fossil plant intakes were revieved.
These sites vere selected because their location and construction make it possible to predict probable suspended solids results for PNPP. This review revealed that for the two referenced years, suspended solids in lake waters ranged from 0 to 200 HG/L at both plants.
a.
b.
averaged above 18 HG/L, 50% and 40% of the tima at Eastlake and Ashtabula respectively.
averaged above 50 HG/L, 20% and 14% of the tamJ st Eastlake and c.
Ashtabula respectively.
d.
averaged the following number of months at the suspende.' solids levels listed below:
Ashtabula tas'.take Year (MG/L)
< 30 30 - $_0
> 50
< 30
}G - 50
> 50 1989 Honths 7
4 1
8 3
1 1988 8
3 1
7 2
3 Based on these rav vater analyses, the proposed limit (17 HG/L) is unreasonable and probably not achievable during certain periods.
2.
CEI recommends that the proposed Discharge Limitation and Honitoring Requirement for 011 and Grease, Total (Reporting Code 550) be deleted.
Federal effluent limits in 40CFR Part 423.13 for Best Available Technology (BAT) do not include oil and grease.
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OEPA POrmit No.131000016*DD
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Public Notice No. OEPA-91-04-017 e
In addition, the proposed limit (6.8 MG/L) is overly restrictive and has no legitimate basis. There are no contribucions to oil and grease levels resulting from discharge of vaste water from PNPP.
Also, the proposed limit of 6.8 MG/L is too close to the minimal detection limit (5.0 MC/L) for the analytical technique, and could result in (false) positive readings and unnecessary violations.
c 3.
CEI recommends that the proposed daily limit (0.2 MG/L) for Chlorine, i
Total Residual (Reporting Code 50060) be deleted. The BAT effluent limit for total residual chlorine in 40 CFR Part 423.13 applies to once through cooling systems. This limit is not applicable, since PNPP uses a recirculated cooling vater system design.
Additionally,-the limit proposed for total residual chlorine does not coincide with the daily limit for Free Available Chlorine (Reporting Code i
50064).
Standard Methods for the Examination of Vater and Vastevater 1
(reference 40 CFR Part 136.3, Table 18, Ite.n 17), Standards Method 408C states " Subtracting the free available chlorine from the total (residual y
chlorine) gives the combined residual chlorine." Since total residual chlorine is defined as the sum of combined and free available chlorines, then a limit for total residual chlorine which is less than the limit for free available chlorine ir unreasonable.
n 4.-
CEI recommends that the proposed pH limit, item 2, page 4 of 14, be revised to 6.0 S.U.'from 6.5 S.U..
The pH of discharge from outfall 004 is dependent on Lake Erie, rather than plant operations. Lake v4.ter pH
-was documented in the PNPP Environmental Report - Operating License Stage to be in the range from 7.7 to 8.5 S.U., with a nominal value of 7.9 S.U..
Operational pH data for discharge from outfall 004 since 1986-
-range from 6.3 to 8.7 S.U.,
and averaged 8.1 S.U..
Acids are not added to the cooling tower to control pH, so there is no impact on discharge. pH t
from cooling tower blowdown. Also, there are no BAT effluent pH limits per 40 CFR Part 423.13.
Outfc11 6002, Discharge from the Chemical Cleaning Lagoon, page 3 of 14:
i 5.
CEI recommands that the Discharge Limitations and Monitoring Requirements
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for Phosphorus, Total (P), Reporting Code 00665, be deleted. -CEI has demonstrated with its fossil plants that monitoring for Phosphorus is unnecessary..
0utfall 6001, Discharge From Regenerant Neutralization Pits, page 2 of 14 r 6.
CEI. recommends that the Measurement Frequency for Residue, Total 1
Nonfilterable (Reporting Code 00530) and Oil and Grease Total (Reporting Code 00550) be revised to 2/ Month, consistent with the previous permit,
-rather than the proposed 1/2 weeks. This provides better operational
OEPA Permit No. 3IB00016+DD Public Notice No. OEPA-91-04-017
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flexibility. Operational data from PNPP has shown that the required sampling frequencies have been representative.
If you need any additional information, please contact Al Lambacher, (216) i 259-3737, extension $520, or John Grimm, at extension 5406.
Since al,
e n.
h e
Michael D. Lyster 4
MDL AHL:njc I
cci B. Hall, OEPA - Northeast District Office NRC Document Control Desk NRC Project Manager NRC Resident Inspector Office NRC Region III l
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