ML20094K091

Forwards Copy of Proposed Change to Util NPDES Permit Sent in 920214 & 0224 Ltrs to PA Dept of Environmental Resources Per Environmental Protection Plan,Section 3.2.Change Would Allow Daily Use of Chemical Additive to Control Foaming

ML20094K091
Person / Time
Site:	Limerick
Issue date:	03/12/1992
From:	Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9203180398
Download: ML20094K091 (11)

Text

,

'i' 9 EPP 3.2 PIIILADELPIIIA ELECTRIC COMi%NY

. . NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.

WAYNE, PA 19087 5691 (215) 640-6000 NUCLEM ENGINEERING & $0RVICES DEPARTMENT March 12, 1992 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 NPDFS Permit No. PA 0051926 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Limerick Generating Station, Units 1 and 2 Proposed Changes to the National Pollutant Discharge Elimination System Permit Gentlemen:

The Limerick Generating Station (LGS), Units 1 and 2, Environmental Protection Plan (EPP), Section 3.2, stipulates that the NRC shall receive a copy of any proposed change to the LGS National Pollutant Discharge Elimination System (NPDES) permit at the same time the proposed change is submitted to the permitting agency.

-By letter dated February 14,'1992 to the Pennsylvania Department of Environmental Resources (PA DER) Philadelphia Electric Company (PECo)_ requested a change to the.LC3 NPDES P.ermit No. PA 0051926 to allow a chemical additive (i.e., Foam Trol CT) to be used on a daily basis. This chemical additive has been previously authorized-for use, as_specified in the enclosed PA DER letter dated September 25, 1991, to control foaming in the_ secondary cooling water system at LGS.

However,-the PA DER letter dated September 25, 1991, stated that this chemical additive was to be used at a rate of 70 pounds per day but only added a few days per year. Recently, foaming has become a iproblem at LGS, and therefore, we are requesting that this chemical.be added daily at the previously approved usage rate of 70 pounds per day to control this problem.

In addition, by letter-dated February 24, 1992 to the PA DER, -

PECo again requested that the LGS NPDES Permit No. PA 0051926 be amended. The Feeruary 24, 1992 letter indicated that this Permit is scheduled to be reissued for a five (5) year period, and that we wanted to take advantage of this opportunity to request changes-prior to it being reist,aed.

9203180398 DR 920312 #

p ADOCK 05000352-

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. s-U.S. . Nuclear Regulatory Commission March 12, 1992 LGS

• NPDES Permit No. PA 0051926 Page 2 Therefore, in.accordance with the LGS EPP Section 3.2, a copy of the .

-February 14, 1992 and February 24, 1992 letters to the PA DER requesting the changes to the LGS NPDES permit are enclosed.

If you have any questions or require additional information,

-.please-do not hesitate to contact us.

Very truly yours, h d? b l G. J. eck i Manager Licensing Section t

Enclosure cc: T. T. Martin, Administrator, Region I, USNRC (w/ enclosure)

T. J. Kenny, USNRC Senior Resident Inspector, LGS (w/ enclosure) l-l.

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PIllLADELPIIIA ELECTRIC COMPAhY 2301.\f ARKET STREET P.O. BOX 8699 PHILADELPHIA, PA 19101 (215) 841-4000 I

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. Mr. Sohan Garg-l' 8 5. I'd Department of Environmental Resources Lee Park, Suite 6010 ,

555 North' Lane Conshohocken, PA 19428

Dear Mr. Garg:

PA0051926 Limerick Generatino Station NPDES Permit'.P.'.00322:1,, . . . . . . .g. :

Attached is a copy of an approval letter, sent by you, for In your usage of Clam Trol CT-1, Betz DTS and Foam Trol CT.

letter, you stated' that these additional chemical additives may be used at the approved usage rate a few days a year.

We are requesting that the Foam Trol CT be approved to be used daily -at the previously approved usage rate of 70 lbs./ day.

roaming ,has become a problem at the station, so a f avorable response would be appreciated by February 24, 1992.

If- you. have any questions or require additional .information, please contact Robert M. Matty, Jr., at 841-5177.

Very truly -yours, o"' George M. Morfey, Manager Environmental Affairs Attachment .

cc. J. A.'Feola w/o attachment bec J. E. Madara, Jr. w/o attachment G. M. Leitch- " "

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COMMONWEAtill OF PENNSYLVANIA ,

l rwm a .,um===== DEPARIMENT OF ENVIRONMENif f. RESOURCES rIN N5YtVANI A  !

FIELD OPERM10ris - WATER QUAllfY H'HAGEHENT )

'i tulle C010, Lee roi A 555 North Lane Censhohocken. PA 19128 j

215 832-6130 5eptember 25. 1991 4

Philadel)hla Electric Company 2301 Hartet Street P.O. Box 8699 ri. o a.wi.io , rn m os Attention Hr. George H. Horley Olrector, Environmental Affairs Re: In:Iultrial Vsste llPDES Permit Ho. PA0051926 Liraerick Generallnp Stetton i Limerick Township Hontgcmery County neai Hr. florley:

This is In response to your PJy 1,1%I, H:7 .'O. l??) and ?N ;&Mr 13, ISM

) W nical additt'.9 for a few $iys letters requesting rpproval to use Mdittoralto u e c #al',1 v)1er rystani e- th't subject j - rer 3ese to-ecotret .u n t s c i rii:.

Itcility.

We have_' Completed our revl.tw and hereby ap ig o,! your a rquest to use the f ollowing additional cbt nical addit!ves in the cooling water 4.sl.*a at tha l._

Lt.inierick tienerattog st ation. The wasteuter >l continue to discharge en an The approval h

average rate of 14.27 rnillion gsllons per (tay uirough Outfall f'rt.

is subject to the following conditions:

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1. 1he approvers additites 'ind usage rol9 ere the rolle.,' .1:

i Rage Rate {lbs/ day).

.N. .a.m..e.

1491

. Clam Trol CT-1 6716 .

! Betz DTS 70 Foam Tr'ol Cr

?. The usage rate or 1491 lbs/ day of Cism Irol CT.1 vill tr lve.e 1 us/1 Sah concentration concentr.ition of tho whole prod' art at outf all r:01 i level is harafu; k the aquatic lif e of the river therr/>.'re detoylff ng I.

[' agent Betz Dif ' hall t'a used ef fectively to reduce thrt f. ncentration to an acceptable lovel as required undar Conditions 3 and 4 below.

n-eye.t.orerv(D

Philadelphia Electric Cwpany >

September- 25,-1991

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3.: During the event of a discharge contalning Clam Trol Ci-1 through Outfall 001, a daily grab sample shall be collected st Llie Outfall 001.  ;

The sample shall be analyzed for Clant Trol Cf 1. ,

d. The concentration of the

• hole product of Clan Trol CT-1 at the (overage) and 0.20 mg/l ef fluent sha'.1 not exceed 0.06 rng/lAlso the use of Clam Trol Cl 1 and Bett D15 (instantaneousmaximum).

shall be controlled to rnest a total suspended sof tds net /1 af 18 fluent daily limitations, of in tng/l as an averag= innthly and 100 r f msX1 mum.

5. - Usage. rates of additives.: and bic4 do n discharge rates shall be contrclied by the permittee to ensure that toxic affects in the receiving stream are prevented. Usage rates shall be limited to the minimum amount necessary to accomplish ther intended purpote3'of chemical ~ addition.

6.- Accurate records of uso;t (nami o r cJditiva, quaritti.y added, date added,-concentration nf C1.1m Trol cr 1 in the erriuent) or any approved

. chemical additive and er blev-do,,n .tivhargs volvnrs emst brmainteined and kept- on-tite by 11 a cetmittet.

7 Whenever a change in additives <>r Im:ro.ises-in unge ra tes is desired

.by the pannittee, , vrltten request, 5.htch Ir.cludes preposed additive, shall be sebmitted to tha 09partment frr Prp': ova!.-

Thelaxisting-NPDES permit will bn- revised to 1 tc1wis these sher.lc.11 additives

. once our_ revlev :or the p1rmit renewal appitcation is co41tl*4.

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e i' t'lilladelpnla tiectric Company September 25, 1991 3

li you have any questions, pleare feel frae te Contact Schan G2Jg of our Fertnits Section.

Very truly yours, ,

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/ JOSEPH A. FEGLA Regional Water Quality Manager rt: EFA(3WHS1)

Delaware River Basin Coamtssion Limerick Township Opera t Iotts Permits and Compliancet Re 30_(1)248 r-h 4

PIIILADELPlHA ELECTRIC COMPANY 2301 MARKET STREET P.O. DOX 8699

' PIIILADELPHIA, PA 19101 (215) 841 4000 j!gLC h

February 24, 1992 Mr. Joseph A. Feola '

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Regional Water Quality Manager - s D artment of Environmental Resources -

555 North Lane Lee Park, Suite 6010 -

Conshohocken, PA 19428

Dear Mr. Foola:

Limerick Generatino Station NPDES Permit PA0051926 A lcev.'ew of Limerick Generating Station's last NPDES permit application was performed as requested by Mr. Schan Garg. There have been no significant changes

-in any of the permitted discharges. However, since this permit will be reissued

- for the next five years, we would like to take this opportunity to request that the follcuing amundments be made L Perkiomen Water Storage Tank Freeze Protection Overflow currently, freeze protection for the Perkiomen storage tank is achieved by providing a cor.tinuouc flow of Perkio%: Creek water to the storage tank. Overflow frem the tank is dischcrged to Possum Hollow Run. This mothod is acceptable per the prenenc NPDES permit. Howsver, it is not the designed methoti and involves temporary plant alterations to the

, operhtion of the station.

The designed method utilizes a continuous flow of 55 GPM from the cooling towerc - to tne storage tsnk. Since freeze protection would not start until the. Perkiomen make .sp pmping system is shut down, there would be very little mixing of Parkiomen Creek and cooling tower water.

Therefore, the overflew to Possum Holle> Run will essentially consist of cooling' tower water af ter a short period of time. This method has never been used occause the overflow outf all is only permitted for Perkiomen

~ Creek water.

We ' are requesting that this designed method be approved for use and included in the reissued NPDES permit. It is anticipattd that this l" method of freeze protection wculd be in service from November 15 to Harch 15. Sinca the flow rate of cooling water to the tank is 55 GPM, the overflow rate to Possum Hollow Run will also be 55 GPM. The flow to thL storage tank is initiated by temperature control valves when tank water temperature reachea 34 degrees F. and is secured when tank l-  : temperature reaches 44 degrees F. As stated, the water is cooling tower E: water and was characterized in our previous permit application end is currently a permitted discharge to outfall 001.

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2. Outfall-Redesignation Due to the inclusion of storm water outf alls, the numbering scheme at the station is being redesignated to simplify the plan. Attached is-a table listing the present outfall numbers and the redesignated (new) outfall numbers. Also included in this table are the longitudes and {

latitudes for the outfalls, i

Storm water snmpling and analysis will be done in compliance with the now storm water regulations and submitted later this year.

3. . Holding Pond Operational Description (monitoring point 201)

The current permit describes the holding pond as receiving " power plant ,

wastes and water treatment plant wastes." While the types of waste being routed to the holding pond have not changed since our last application analysis, we wish to ensure that this description-is accurato.

As stated in previous supplements, Borax, Boric Acid, and Sodium Nitrite are used in treating various plant systems such as closed-loop cooling and the stand-by liquid cont rol system. These systems are drained a few times a year for maintenance and testing. They are not a normal discharge to the holdJng pond.

Alec, discharge of chemistry laboratory facilities is routed to the

< holding pond. solvents and hazardous * .stes are collected for disposal,

- but non-hazardous aqueous chemical reagents are flushed to the holding ,

pond.

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We would like to reiterate that these discharges are not new additions.

They existed during the sampling and analysis done during the first permit application.

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• l 4. Use of Anti-foamants

, We are precently permitted to use Toam Trol CT at a usage rate of 70 lbs./ day. We are requesting tha' this limit be amended to 700 lbs./ day and the use be approved on a year round, as needed basis, a

Also, we are investigating the use of other anti-foamants sold by Betz, Calgon, and Nalco. We anticipate that these products will be of equivalent toxicity as Foam Trol CT and wilt be used at tne same daily rate. We are requesting that. the use of these alternatives be approved for use as substitutes to Foam Trol CT. Information on these products

=will be provided by the end of February. ,

5. Lubricating / Hydraulic Fluids In our previous application, Supplement I contained a list "of' chemicals used on site that could potentially be present in the discharge.

, Although not specifically identified, 'various lubricating and hydraulle fluids, aspecially Fyrquel EHC f.1uid, could periodically be present in.

the discharge. These substances would be detected and reported as oil

, _ snd grease during our weekly monitoring requirements. Therefore, this

~does not reprecent a change in the makeup of discharge but an operational description change / clarification.

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, 6. Tolytriazole-(TTA)-

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, Nalco 1336 is. presently authorized for use in cur NPDEf permit.

The-monitoring limitation is based on the whole product. Since Nalco 1336 is 42% TTA and it is the only active ingredient in the product, we are requesting that the monitoring requirement be based on TTA.

Also, we are requesting that alternative products be approved as substitutes to the Nalco product. Attached are Material Safety Data  ;

Sheets _for Detz Powerline 3023 (43% TTA) and Calgon PCL-50 (431 TTA). l Total s* te usage for any of _ these products is not expected to exceed 220 gallons per day (21'#8 lbs./ day}.

7. Additional inputs tu Schuylkill River Pumphouse Traveling Screen Backwash, Outf all 011 (previously outf all 007)

Three additional inputs have been identified as contributing to outf all 001. They ares river water used as pump cooling water, river water leakage from piping, and condensation from an air compressor.

The pump cooling water is supplied from the putp discharge at approximately ' 5 GPM per pump. The discharge drains to the wet pit and  !

only occurs when the pump is in service. Piping leakage is minor, and '

flow rates are dif ficult to determine. The condensate drain from the air compressor is also minor, and a flow rate cannot be determined.

-f. Discharge of Reactor Enclosure / Refuel HVAC Room Water Via outf all 003 Located in both-Units 1&2 reactor enclosurc/ refuel HVAC rooms are floor drains that are routed to storm water outf all 003. These drains are intended to- collect precipitation that enters .the room via ventilation louvers. Also, chilling and heating coils are located in the room, and 3-4 gallons per. day of condensed. boiler steam leaks to tne drain. The  !

- chillers, which are chemically treated with sodium nitrate, do not normally leak to the drain. _ They only represent a potential discharge _

to the drain-via a system failure. Current procedures exist calling for the coils to be drained and laid up at the end of each service season.

They are then pressure treated prior to being put back in service.

Therefore, we. believe it is unlikely that this treated water will enter the floor drain.

During normal operations, flow to outfall 003 is routed to the holding pond via a diverter valve. The operation of the valve is '

administratively controlled by plant procedures. A red blocking tag is

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secured to the valve operator and is removed only with approval from supervision. The valve is only operated during periods of excessive l rainfall which cause the input rate to the holding pond to exceed the discharge rate _(approximately 1000 CPM). Once the rainfall subsides and

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the ficws normalize,- the diverter valve is repositioned, and flow is _

again routed to thn holding pond.

We are ' requesting that this discharge be approved in our NPDES permit.

Understanding that water quality criteria is based on the receiving stream's Q 7-10 flow, we believe that an exception can be made in this j case. As stated, discharge from the HV # room would only go to outfall l~ CO3' during periods of excessive 2 ainf all. Therefore, c ae discharge would only occur when the flow in Possum Hollow Run ib at a high point and not during low flow conditions (i.e. Q 7-10). Administrative l

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, ' procedures' are in place to assure that this operatinn occurs as i described, i

Samples have. been tnken, and the analysis will be submitted as soon as the results are' received.

9. Detection Level for Clam Trol CT-1 In your approval letter for the subject chemical additive, a limit on .)

the concentration of the whole product not to exceed .06 mg/l was required as part of the approval. In our original request, we indicated that the lower -limit of detection was .2 mg/1. The test method was  ;

developed by Betz, and they fee 7 t hat the analysis for this detection  ;

level is unreliable. We are requesting that you review this information ,

and recons! der the limitation.

10. Discharge of Coeling Tower hater to Storm Water Outf all 021  ;

outfall 021 has been identified as possibly recalving cooling tower -

water from two sources. The first is overspray at the cooling tower base (drift loss). .The cooling tceers, by design, will lose a certain percentage of cooling water by this method. It is clear that the  ;

overspray could reach the Schuylkill River via outfall 021, but the  ;

amount is not determinable.

The second method is from a preventative maintenance practice of washing the cooling tower acceens. The screens are removed from the basin and placed on the ground to be washed. Debris-from the screens is collected and disposed of properly. While-the water docs not discharge directly.

to the outfall, the potential does exiet.  ;

Wo .are- requesting that outf all 021 be permitted to receive cooling tower

• water on the basin just described. S!nce 021 dischargeu to the Schaylkill River and oucfall 001 is permitted for cooling tower water,

, we feel that -this minor addition will not impact the river.

We would. like to arrange- a meeting among PADER, Limerick Station, and ,

, Environmental Af faire personnel. to' discuss the enclosed information or any questions you might have on this submittal. If you concur, please contact Robert

~ Hatty at 841-5177- so that a time can be set up-for the meeting as well as a site tour, it. desired.

Very truly yours,.

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Geo ge M. Mori Ha ager Environmenul Affairs

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