ML20135E884

Forwards Comments Re Draft NPDES Permit 31B00016*ED & Antidegredation Rule Application

ML20135E884
Person / Time
Site:	Perry
Issue date:	11/19/1996
From:	Myers L CENTERIOR ENERGY
To:	Spurbeck M OHIO, STATE OF
References
PY-CEI-OEPA-026, PY-CEI-OEPA-26, NUDOCS 9612120173
Download: ML20135E884 (9)

Text

f C:NTERIOR ENERGY PERRY NUCLEAR POWER PLANT Mail Address:

10 CENTER ROAD PERRY, OHIO 44081 P RR , OHIO 44081 (216) 259-5737 November 19, 1996 PY-CEI/OEPA-0260L Attention: Martha D. Spurbeck, Supervisor Permit Processing Unit Division of Surface Water Ohio Environmental Protection Agency P. O. Box 163669 Columbus, Ohio 43216-3669' Re: NPDES Draft Permit No. 31B00016*ED Ohio EPA No. OH0063461 Perry Nuclear Power Plant; The Cleveland Electric Illuminating Co.

10 Center Road, Perry Village, Ohio 44081, Lake County Ladies and Gentlemen:

Attached are the comments pertaining to the draft NPDES permit 31B00016*ED and the Antidegredation Rule Application. The comments are addressed sequentially, for each permitted discharge point, within Attachment 1.

If you have questions or require addition information, please contact Mr. James T. Ratchen, at (216) 280-5601.

Very truly yours, A M}fD Lew W. Myers Vice President - Nuclear JTR:sc Attachments l cc: NRC Region III '

NRC Resident Inspector NRC Project Manager s g ,,)/[

d'

• NRC Document Control Desk (Docket No. 50-440) 9612120173 961119 PDR P ADOCK 05000440 PDR Operceg Compor.es CleveiaN Electrte nominabng loieco Ea soa

Attachment 1 Perry Nucicar Power Plant's Comments on NPDES Draft Permit 3IB00016*ED

,, November 19,1996 PY-CEI / OEPA - 0260L Outfall 3IB00016601.Discharce from the regenerant neutralization nits ne existing permit lists the (low) pH reporting code as 00402. He draft permit lists the (minimum) pH code as 00404. Please clarify if any changes exist as a result of this code change.

He existing permit had no limits for total suspended solids (total nonfilterable residue). He draft permit has a daily limit of 100 mg/L and a 30 day limit of 30 mg/L. We are requesting relief from these values with the followingjustification:

The discharge from the neutralization pits accounts for less than 0.005 percent of the total discharge flow at PNPP. He average monthly value between 1/93 and 9/96 is < 21 mg/L, however, after i removing two anomalies, the highest monthly average was 54 mg/L with a individual maximum value of 125 mg/L. Because the total flow, sul sequent total solids discharge, and historical data from this point are minimal, (the calculated concentration at the discharge tunnel exit is 1.34E-3 mg/L), we are requesting relief from a specified Total Suspended Solids Limit. If this is unacceptable, we are l requesting maximum and monthly limits that would not be exceeded by our historical data. We are recommending a monthly average value of 75 mg/L and a maximum value of 150 mg/L. See Attachment 2 for historical data.

Outfall 3IB00016602. Discharge from the chemical cleaning lagoon No comments.

OutfaII 3IB00016004. discharge from the discharge tunnel entrance structurs ne existing permit does not requhe any phosphorous analysis. He draft permit requires a daily grab sample and total phosphorous analysis without specified limits. He phosphorous contents in this discharge is a result of the cooling tower blowdown which contains HEDP and organic phosphate as a scale inhibitor.

The phosphate levels in the circulating water system are carefully controlled (<2 ppm) and the blowdown is then diluted, generally by a factor of > 4 to 1. We are therefore requesting relief from this analysis. If thu is unacceptable, we are requesting a weekly sample frequency versus the stated daily frequency. If an analysis is required, PNPP requests that the new permit does not become effective for 60 days to allow for procedural development and technician training. In addition, please incorporate the accepted methods of analyses for phosphate.

He double asterisk " for chlorine analysis states " Analyses are to be performed by amperometric titration." We are requesting that this be changed to state:" Analyses are to be perfomied by amperometric titration, Orion residual chlorine electrode, or other EPA approved methods."

We are also requesting a triple asterisk '" for chlorine sampling that states: " sampling to be done only during chlerination."

ne existing permit lists the latitude and longitude as 4140' 30",8108' 45". The draft permit lists the latitude and longitude as 4148' 10",8108' 33". Verification of the actual latitude and longitude point, through the site survey calcualtions, are 4148' 33",8108' 50". Please change the values accordingly.

OutfalI 3IB00016800. Intake No comments.

Page I

Attachment 1 Perry Nuclear Power Plant's Comments on NPDES Draft Permit 3IB00016*ED '

November 19,1996 PY-CEI / OEPA - 0260L Outfalls 3f B00016005. 006. 007. Maior Stream. NW. & Minor Impoundments (Storm Drains)

The draft permit states:" General Storm Water Requirements are applicable. See parts IV and VI." PNPP interprets the draft permit as requiring only parts IV and VI requirements. We are requesting wTitten

clarification within the permit as to whether the entire " General Storm Water Permit" requirements are applicable or if only parts IV and VI are applicable.

The draft permit states that these outfalls are limited to storm water runoff only. As provided in section IV.D.3.g "Non-S:orm Water Discharges", the Perry Nuclear Power Plant will develop a storm Water Pollution Prevention Plan, within 6 months of the effective date of this permit, that identifies potential significant sources of non-storm water with test and/or evaluation data. The Perry Nuclear Power Plant currently utilizes or plans to utilize the stonn drain system for the following "non-storm water" discharges:

Fire fighting water, hydrant flushing Drainage of potable water systems Drainage of non-treated lake water. systems Drainage of uncontaminated ground water (from excavations etc.)

Air conditioning condensate Lawn watering External Building washdowns (no detergents)

Pavement washdowns (no detergents and no toxic or hazardous materials present)

Basement sumps from ground water, footing drains, foundation (non-contaminated)

We are requesting clarification as to the acceptability of these "non storm water" discharges and a change to the text in the draft permit to eliminate the terms " limited to storm water runofronly".

I I

/

I Page 2

j . .

i ,

Attachmsnt 2

' Perry Nuclear Power Plant's Comments on NPDES Draft Permit 31800016*ED 3

November 19,1996 PY-CEI / OEPA - 0260L l Outfall- 004 601 6.01E+02 601 601 004 1

Dis. Tunnel Neut. Pit Neut. Pit Neut. Pit Neut. Pit Calc. Avg.

j Comments Total Flow Total Flow % of Total Flow SS mg/l. SS mg/L SS Discharge Mo.f Yr MG MG Avg. Max mg/L

, Sep-96 2527.5 0.102 4.04E-03 17.5 23 7.06E-04 j Aug-96 2572 0.097 3.77E-03 13 17 4.90E-04

! Jul-96 2331.7 0.11 4.72E-03 9.5 13 4.48E-04 I Jun-96 2461.3 0.085 3.45E-03 9 11 3.11E-04

May-96 2735.8 0.083 3.03E 03 9.33 14 2.83E-04 i Apr-96 2360.4 0.116 4.91E-03 13.67 16 6.72E-04

! Mar-96 1413.2 0.123 8.70E-03 12.6 21 1.10E-03

Feb-96 757.6 0.127 1.68E-02 6 7 1.01E-03

. Jan-96 3040.2 0.0967 3.18E-03 5 7 1.59E-04 l Dec-95 2701 0.125 4.63E-03 14 17 6.48E-04

] Nov-95 2857.3 0.1078 )

3.77E-03 11 21 4.15E-04 j Oct-95 2839.1 0.1 3.52E 03 7 11 2.47E-04

Sep-95 3008.9 0.1091 3.63E-03 20 26 7.25E-04 Aug-95 2971.2 0.1153 3.88E-03 16 22 6.21E-04 Jul-95 2635.5 0.1219 4.63E-03 18 23 8.33E-04 5 Jun-95 2250.5 0.0995 4.42E-03 15 27 6.63E-04 May-95 2547.7 0.1333 5.23E-03 39 61 2.04E 03

! Apr-95 2221.2 0.1012 4.56E-03 37 56 1.69E-03 I Mar-95 2247 0.1263 5.62E-03 25 63 1.41E-03 Feb-95 1901.8 0.1013 5.33E-03 33 57 1.76E-03

Jan-95 2125.1 0.0727 3.42E-03 17 36 5.82E-04 Dec-94 2717.9 0.0317 1.17E-03 54 d 565 6.30E-04 Actual avg 298, set @ 54 Nov-94 2599 0.0151 5.81E-04 20 20 1.16E-04

, Oct-94 2781.6 0.0518 1.86E-03 9 13 1.68E-04 1 Sep-94 2638.2 0.0509 1.93E-03 11 11 2.12E-04 i Aug-94 3307.2 0.1339 4.05E-03 13 20 5.26E-04 Jul-94 3887.2 0.1509 3.8SE-03 16 44 )

6.21E-04 '

Jun-94 3123.8 0.1693 5.42E-03 16 38 8.67E-04 May-94 768.3 0.1463 1.90E-02 45 125 8.57E-03 Apr-94 441.9 0.1602 3.63E 02 10 12 3.63E-03 Mar 94 936.7 0.1664 1.78E-02 ' 19 33 3.38E-03 Feb-94 2209 0.169 7.65E-03 30 35 2.30E 03 Jan-94 2217.5 0.1502 6.77E 03 36 49 2.44E-03 Dec-93 2363.8 0.1747 7.39E-03 45 76 3.33E-03 Nov-93 2738.3 0.1662 6.07E-03 30 45 1.82E 03 Oct-93 3315.8 0.1038 3.13E-03 19 32 5.95E-04 Sep-93 3029.7 0.1265 4.18E-03 13 16 5.43E 04 Aug-93 3051.6 0.0921 3.02E-03 11 17 3.32E-04 Jul-93 3460.2 0.1142 3.30E-03 32 49 1.06E-03 Jun-93 2718 0.0909 3.34E-03 16 21 5.35E-04 May-93 2398.7 0.1099 4.58E-03 16 26 7.33E-04 Apr-93 699.5 0.0585 8.36E-03 54 1277 4.52E-03 Actual avg 1277, set @ 54 Mar-93 2132.1 0.2149 1.01E-02 54 124 5.44E-03 Feb 2060.6 0.0884 4.29E-03 8 10 3.43E-04 Jan-93 2767.4 0.1161 4.20E43 15 44 6.29E-04 Average: 2419.3 0.1134 4.69E-03 20.88 1.34E 03 Page 1

e i

i e Page 1 1

Ohio EPA DIVISION OF SURFACE WATER l

Antidegradation Addendum l

In accordance with Ohio Administrative Code 3745-1-05, additional information may be required to complete your application for a permit to install or NPDES. For any application for which there might be an increase in the level of pollutants being discharged (NPDES and/or PTI)or for which there might be some activity taking place within i the stream bed the processing of the permit may have to go through various  !

procedures as outlined by the above stated rule. The rule outlines various procedures for public participation as well as those pertaining to levels of review necessary i depending on the degradation being considered / requested. The rule also outlines l various exclusions from portions o'f the application and review requirements and waivers that the Director may grant as specified in Section 3745-1-05(D) of the rule. Please complete the following questions. The answers provided will allow the Ohio EPA to determine if additional information is needed. All oroiects that reouire both an i

NPDES and PTI should submit both anolications simultaneousiv to avoid coina throuah the antidearadation crocess seoaratelv for each nermit.

A. Applicants Percq &&m 8< f%t Facility Owners be bed d CmM bIed h 1benOng (c.

Application or Plans Prepared By: t me( T. Cdr b q Project Namen;/A NPDES Permit Number (if applicable): 31bbOOb bh B. Antidegradation Applicability Is the application for? (check as many as apply) :

Renewal NPDES application or PTI application with no requested increase in currently permitted pollutants. (Complete Section E).

A/ A PTI and NPDES application for a new wa.,tewater treatment works that will discharge to a surface water. (Complete sections C and E)

A/A An expansion / modification of an existing wastewater treatment works discharging to a surface water that will result in any of the following (PTI and NPDES) : (Complete Section C and E) addition of any pollutant not currently in the discharge, or an increase in mass or concentration of any pollutant currently in the discharge, or an increase in any current pollutant limitation in terms of mass or concentration.

i Page 2

//

PTI that involves placement of fill or installation of any portion of a sewerage system (i.e., sanitary sewers, pump stations, WWTP, j 4 etc.)within 300 feet of a stream bed. Please provide information on i an attached sheet (i.e., number of stream crossings, fill placement, etc.) and complete section E.  !

I A/d Initial NPDES permit for an existing treatment works with a wastewater discharge. (Complete Sections C, D and E)

//A Renewal NPDES permit or modification to an effective NPDES permit that will result in any of the following: (Complete Section C and E) I a new permit limitation for a pollutant that previously had no I limitation, or l an increase in any mass or concentration limitation of any

, pollutant that currently has a limitation. '

A/A Other projects With no direct surface water discharge (i.e., on-site disposal, extensions of sanitary sewers, spray irrigation, indirect j discharger to POTW, etc.). (Complete Section E)  !

C. Antidegradation Information l

1. Does the PTI and/or NPDES permit application meet an exclusion as outlined by OAC 3745-1-05 (D) (1) of the Antidegradation rule?

i Yes (Complete Question C.2) s No (Complete Questions C.3 and C.4)

2. For applications that meet exclusions provide the following information 1 requested.

' l

a. Provide justification of the exclusion being met.

2

b. Identify the substances to be discharged, including the amount of regulated pollutants to be discharged in terms of mass and concentration,

c. A description of any construction work, fill or other structures to occur or be placed in or near the stream bed.

3. Are you requesting a waiver as outlined by OAC 3 74 5-1-05 (D) (2-7) of the Antidegradation rule?

No Yes If you wish to pursue one of the waivers, please identify the waiver and submit the necessary information in support of such request. Depending on the waiver requested, the information required under question C.4 is still required to complete the application.

Page 3 4.

All applications that do n9.1 meet an exclusion must submit a report evaluating the preferred design alternative, non-degradation alternatives, minimal degradation alternatives, and mitigative techniques for the design and operation of the activity. The information outlined below should be addressed in this report. If a waiver is requested, this section is still required,

a. Describe the availability, cost effectiveness and technical feasibility of central or regional sewage collection and treatment facilities, including long range plans outlined in state or local water quality management planning documents and applicable facility planning documents.

b.

List and describe all government and/or privately sponsored conservacion projects that may have specifically targeted to improve water quality or enhance recreational opportunities on the effected water resource.

c. Provide a brief description below of all alternatives evaluated for this application. (If additional space is needed please attach to the end of this addendum).

Preferred design alternative:

Non-degradation alternative (s)s:

Minimal degradation alternative (s) -

Mitigative technique (s) :

As a minimum, the following information must be included in the report for each alternative evaluated,

d. Outline of the treatment system equipment evalukted, including the costs associated with the equipment, installation, and continued operation and maintenance.

e. Identify the substances to be discharged, including the amount of regulated pollutants to be discharged in terms of mass and concentration,

f. Describe the reliability of the treatment works, including but not limited to the possibility of recurring operation and maintenance difficulties that would lead to increased degradation.

=

Page 4 9 Describe any impacts on human health and the overall quality and value of the water resource,

h. Describe and provide an estimate of the important social and economic benefits to be realized through this proposed degradation.

Include the number and types of jobs created and tax revenues generated.

I.

Describe environmental benefits to be realized through this proposed degradation.

j.

Describe and provide an estimate of the social and economic benefits that may be lost.as a result of this proposed degradation.

Include the effect on commercial and recreational use of the water resource.

k.

Describe the environmental benefits lost as a result of this proposed degradation. Include the effects on the aquatic life, wildlife, threatened or endangered species.

1. A description of any construction work, fill or other structures to occur or be placed in or near the stream bed.

m.

Provide any other information that may be necessary in evaluating this application.

D. Discharge Information

1. For treatment works constructed pursuant to a previously issued Ohio EPA PTI, provide the following information:

PTI Number -

PTI Issuance Date Initial Date of Discharge

2. Has an NPDES permit application 2C or 2E form been submitted including representative effluent data?

Yan No If no, submit the information as applicable under a OR b as follows:

a. For entities discharging process wastewater attach a completed 2C form.

b. For entities discharging wastewater of domestic origin attach the results of at least one chemical analysis of the wastestream for all pollutants for which the discharge is being requested and a measurement of the daily volume (gallons per day) of wastewaters being discharged, j

e Page S E.

Based on my inquiry of the person or persons who manage the system or those i persons directly responsible for gathering the information, the information is, !

to the best of my knowledge and belief, true, accurate and complete.

Signature b3 (h; M

~

Date lll'1 \ C1(e i i A \Antiforin.all 10/1/96  ;

l 9

i

!