ML20236V945

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Forwards Commonwealth of PA Dept of Environ Protection Responding to Licensee 980427 Request for Amend to NPDES Permit PA 0051926 to Reflect Changes to Monitoring & Sampling Requirements for Suspended Solids at Outfall 001
ML20236V945
Person / Time
Site: Limerick  
Issue date: 07/28/1998
From: Geoffrey Edwards
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9808040301
Download: ML20236V945 (4)


Text

_. _ _ _ _ _,

Station Support Depirtment EPP 3.2 v

PECO NUCLEAR eeco se ov comnem, 9% chesterbrook Boutevard A Unit of PECO Energy Wayne, PA 19087-W91 July 28,1998 Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 NPDES Permit No. PA0051926 1

1 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 j

Subject:

Limerick Generating Station, Units 1 and 2 Changes to National Pollutant Discharge 1

Elimination Sctem Permit i

Dear Sir / Madam.

This letter is being submitted in accordance with the Limerick Generating Station (LGS), Units 1 and 2, Environmental Protection Plan (EPP) Gection 3.2, which stipulates that the NRC shall be notified within 30 days following the date of approval of a change to the National Pollutant Discharge Elimination System (NPDES) permit.

By letter dated April 27,1998, PECO Energy requested changes to LGS NPDES Permit No.

PA0051926 concerning erfluent monitoring requirements for Outfall 001. By letter dated May 19, 1998, the Pennsylvania Department of Environmental Protection (PA DEP) approved our request and amended NPDES Permit No. PA0051926 to reflect changes to the monitoring and sampling requirements for total suspended solids (TSS), phosphorus, copper, and zinc at the Outfall 001. The subject amendment to the NPDES permit became effective on June 1,1998.

The NRC was previously notified of our request to revise the NPDES permit in our letter to the PA DEP dated April 27,1998. A copy of the PA DEP letter amending the LGS NPDES permit is attached.

Accordingly, this !etter provides the required notification of the changes to the LGS NPDES permit. However, this notification was not submitted within 30 days of the permitting agency's approval, as required by the LGS EPP, due to an administrative oversight. We apologize for any inconvenience this may have caused.

If you have any questions or require additional information, please do not hesitate to contsct us.

Ve truly yours, I

Garrett D. Edwards Director-Licensing dr?vda Attachment cc:

H. J. Miller, Administrator, Region I, USNRC (w/ attachment) v A. L. Burritt, USNRC Senior Resident Inspector, LGS, (w/ attachment) 9008040301 980728 i

PDR ADOCK 050003S2 p

PDR l

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Pennsylvania Department of Environmental Protection Lee Park, Suite 6010 555 North Lane Conshohocken, PA 19428 May 19,1998 Southeast Regional Office 610-832-6130 Fax 610-832 6133 Mr. Robert M. Matty, Jr., Engineer Environmental Affairs PECO Energy Company 2301 Market Street - S21-2 P.O. Box 8699 Philadelphia, PA 19101-8699 Re:

IW NPDES Permit No. PA 0051926 Limerick Generating Station Limerick Township Montgomery County i

l

Dear Mr. Matty:

This is in r::sponse to your April 27,1998 letter requesting an amendment of the subject NPDES permit to reflect changes to the monitoring and sampling requirements for total suspended solids (TSS),

phosphorus, copper and zine at the Outfall 001.

We have completed our review of the additional information submitted by you related to the concentration of TSS at Outfall 001 during the periods of use of DTS in the cooling towers. We hereby approve your request as follows:

The total suspended solids shall be monitored during the periods of use of DTS in the cooling towers by obtaining a representative composite sample at Outfall 001. The TSS shall meet a net limit of 30 mg/l as an average monthly,60 mg/l maximum daily and 75 mg/l as instantaneous maximum at Outfall 001. The net limits shall be calculated using the enclosed worksheet.

These changes will be effective June 1,1998 and will be incorporated in the NPDES permit upon next permit renewal.

The other issue you raised was related to a representative sampling at Outfall 001 for phosphorus, copper and zinc. The conductivity of a sample is an indicator of the total dissolved solids present in the sample. It does not give information on the total concentration of the individual pollutants present in the sample. Therefore, even if the conductivity stays relatively constant overtime, the total concentration of l

the individual pollutant can vary. Based on this, the 24-hour composite sampling requirement for these i

pollutants shall remain. However, you may conduct a study to demonstrate the long term relationship by collecting composite and grab samples at Outfall 001 and analyzing each at the same time to compare An Eqd OpporwngAMrmaw Adion Employs tinphww dey se pa us Pnmed m %Mapn L __ _ _____-

Mr. Robert M. Matty, Jr. May 19,1998 r m its g ab versus composite samples. The report may be submitted next year with the permit If you have any questions, please contact Mr. Sohan Garg of our staff.

Sincerely, h

. 0l Steve O'Neil Acting Regional Manager Water Management

Enclosure:

Worksheet cc:

Mr. Newbold Mr. Bauer DRBC Re 30 (jd98)132-8 1

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DETERMINATION OF TOTAL SUSPENDED SOLIDS (NET) WORKSHEET Rev.~5/98

1. Prepare a composite representative sample by collecting grab samples every two hours from the Cooling Tower No.1 during the period when the chemical additive DTS is in use. Analyze this composite representative sample for TSS. Call it TSS1.
2. Repeat step 1 for the Cooling Tower No. 2 and analyze for total suspended solids.

Call it TSS2.

3. Calculate the average blow down rate for Cooling Tower 1 during the sampling time period. Callit Q1.

1 4.

Repeat step 3 for the Cooling Tower No. 2 to determine the average blow down rate for the Cooling Tower No. 2 during the sampling time period. Call it Q2.

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5. Use the following equation to calculate the total suspended solid level in the Cooling Towers:

l l

[TSS1 x Q1

+

TSS2 x Q2 ) /

[Q1 + Q2]

= C1 l

6. Prepare a composite representative sample by collecting grab samples at Outfall 001. Analyze for total suspended solid. Callit TSS.
7. Calculate Net TSS using the following equation:

Net TSS

=

TSS C1 l

NOTE:

For computing averages for DMR reporting and for determining permit compliance, all "less than zero" results must be counted as zero values.

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