ML20217P260
| ML20217P260 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/27/1998 |
| From: | Matty R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Oneil S PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 9805060185 | |
| Download: ML20217P260 (7) | |
Text
Envirrnnuntal Aff iraDivillin
' Ak-v PECO ENERGY ns0;=E;"L Po Box B699 Philadelphia, PA 19101-8699 215 841 5030 April 27,1998
)
Mr. Steve J. O'Neil Acting Regional Manager
)
Water Management Department of Environmental Protection Lee Park, Suite 6010 555 North Lane Conshohocken, PA 19428
Dear Mr. O'Neil:
Subject:
Limerick Generating Station NPDES Permit No. PA0051926 This letter is being sent to request that the subject NPDES permit be amended by making the following changes to the monitoring requirements for outfall 001.
We are requesting that the total suspended solids (TSS) monitoring requirement be modified (as detailed below), and that the 24-hour composite sampling requirement for zinc, copper, and phosphorus be changed to a once per week grab sample.
Concerning the TSS request, a letter dated March 5,1998, was sent to your 6ttention by Mr. David B. Everett, Chief Engineer, Delaware River Basin Commission (DRBC). The letter documents PECO Energy's meeting with members of Mr. Everett's staff and our subsequent request concerning this issue. Based on the information presented to DRBC (see attached letter),
Mr. Everett concluded that DRBC regulations do not require that a TSS limit be placed on outfall 001. In addition,25 PA Code Chapter 93 and 40 CFR 423 do not require a TSS limit on cooling tower blowdown.
Recently, a discussion concerning TSS was held with Mr. Sohan Garg, PcDEP Water Management. Mr. Garg indicated that TSS is also an issue due to the facilities use of Betz DTS, Betz DTS is a detoxification agent used in conjunction with Betz Clam-Trol products. Based on our discussion with Mr. Garg and the l
DRBC, we are requesting that the monitoring requirement for TSS be modified to have the sampling requirement coincide with the use of DTS. The permit should 112403
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9005060185 990427 PDR ADOCK 05000352 V
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require that, during the use of Betz DTS, TSS will be monitored by obtaining a composite sample (i.e., grab samples every two hours) when DTS is present in the discharge (typically 10 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />). The cooling Pwer effluent would be required to meet a net TSS limit of 30 mg/l. Attachment No.1 details how the net TSS concentration will be determined.
As you may recall, in August 1997, a meeting was held at Limerick Station to discuss various NPDES issues. One of the topics discussed was time-weighted composite sampling versus flow-weighted composite sampling at outfall 001.
Since that meeting, we have put together date which shows effluent conductivity versus cooling tower blowdown rates (attached). Conductivity was used as an indicator of the total dissolved pollutants in the effluent (i.e., dissolved metals).
The data shows that conductivity stays relatively constant over time. Therefore, the chemical characteristics of the effluent are also constant over time. This is consistent with our previcos discussions in which we indicated that the levels of zinc, copper and phosphorus are closely controlled through the site cooling water chemical additive program. In particular, the limits for zinc and phosphorous are contained in the permit due to the use of corrosion inhibiting chemical additives.
The EPA's Training Manual for NPDES Permit Writers recommends that where the quality and flow of the waste stream being sampled is not likely to vary over time, a grab sample is appropriate.
A copy of this letter (including any attachments or enclosures) is being sgnt to the U.S. Nuclear Regulatory Commission (USNRC) in accordance with the Limerick Generating Station, Units 1 and 2, Environmental Protection Plan, Section 3.2, which stipulates that the USNRC shall receive a copy of any proposed changes to the NPDES permit at the same time that the permitting agency is notified.
If you have any questions or re quire additional information concerning our request, please contact me on (215) 841-5177. If PaDEP would like to arrange a meeting to discuss the issues, please contact me with a time that is convenient.
Sincerely, Robert M. Mattyl, Jr.
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Engineer Environmental Affairs Attachment cc:
U.S. Nuclear Regulatory Commission, Document Control Desk Docket Nos. 50-352 and 50-353 & License Nos. NPF-39 and NPF-85)
H. J. Miller, Administrator, USNRC, Region 1 USNRC Senior Resident inspector, LGS i
(
l Total Suspended Solids Worksheet
- 1. Obtain grab samples every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from Cooling Tower No.1 blowdown during period when Betz DTS is present in discharge. Composite grab samples and analyze for TSS (TSSi).
- 2. Repeat Step 1 for Cooling Tower No. 2 to determine TSS.
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- 3. Calculate the average blowdown rate for Cooling Tower No.1 during the sampling time period (Flowi).
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- 4. Repeat Step 3 for Cooling Tower No. 2 to determins Flow 2
- 5. Use the following formula to calculate the TSS level in the Cooling Towers:
l
[(TSS, x Flowi) + (TSS2 x Flow 2)]
.......................- = C ( 1 )
i (Flowi + Flow 2)
- 6. Obtain grab sample every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from outfall 001. Composite grab samples j
and analyze for TSS (TSS outfall 001)
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