L-21-121, Draft NPDES Permit No. PA0025615

Draft NPDES Permit No. PA0025615

ML21123A166
Person / Time
Site:	Beaver Valley
Issue date:	04/05/2021
From:	Enos M Energy Harbor Nuclear Corp
To:	Decker R Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection
References
L-21-121, PA0025615
Download: ML21123A166 (2)

Text

• e~er gy Beaver Valley Power Statwn Route 168 .

.P.O.Box4 harbo*r Shippingport, PA 15077-0004 April5,2021 L-2_1-121 .

Ryan Decker,, P.E.

• *Department of Environmental Protection, Clean Water Prog*ram Southwest Region.al Office . .

400 Waterfront Drive Pittsburgh, .PA 15222-

SUBJECT:

Beaver Valley Power Station (BVPS) Draft NPDES Permit No. PA0025615

Dear Mr. Decker,

In response to several potential ch~llenges associated with the new permit, the BVPs* is .

• requesting the followi.ng modifications to the implementatio"n of the new permit:

1". The plant requests a-two-year extension to *make the ~odifications n~ary to manage and treat low volume waste stre~ms at internal monitoring po!nts (IMP) 601 and 701. These IMPs were created to monitor low volume waste streams, as part of the new draft permit pub~ish~d M~rch 27, 2021: * *

• As you might.recall from our previous discussions, IMP 601 is a small sump with an estimated flow of <0.001 MGD. _IMP -701 is intended to capture various sources of equipment drainage and leakage that is di~chargecf_ to tne cooling tower blowdown line (Outfall 001). These internal monitoring points will be monitored for low volume*

waste parameters pH, TSS, and Oil & Gre~se.

• BVPS ~as ide~tified thi:it sampling ~nd potentially treating wastewater at these new.

IMPs will be a-challenge due to limited ~ump .and *storage capacity and limited space*

inside the p!ant. Additionally,* we may periodically be challenged with meeting pH and TSS limits at these. IMPs depending on plant conditions and _Ohio River conditions. Per prior. ~iscussions with PADEP staff, BVPS is .exploring *several options *including operational and equipment *modifications to meet'. the new requiremel"!ts. BVPS has *identified pot~ntial solutions. for water management both .

onli~e and during outages; however, these solutions are not' easily or quickly. -

implemented due to the complex process for ma~ng changes at *a nuclear facility.

The time required to develop the engineering design .changes, allocate funding, plan the work,** and implement. these changes wiil take longer than the available time

~fore the permit renew~I is anticipated to be.issued.

• Beaver-Valiey Power Station, Unit Nos. 1 and 2 L-21-121 . .

Page 2_

n,erefore,

• a two-year extend.ed _.implementation period at. lMPs 601 and 701 will provide addit,onal time n~ed to make the modifications -neces~ry to manage snd treat these low vofume waste streams. The* pH ..limit at final outfall 091 is not e~(;lcho be challenged at any time by the flow contrit;>Utio~s of the 601/701 waste

- s~ms based on our operating experience and sampling history. *

2. The plant requests a tw<ry~r delayed implementation of the mercury iimits being established in this permit* renewal. During th~ time, we propose to continue to *_

• sample at all required outlets as a rep_ort-o(liy parameter. Based on our very limited sampling history with this parameter, there *is some uncertainty* as to whether we will

~ challe,:iged to meet these limits all year With changing *seasons and river -

conditions. We* would like some more time t~ ~tablish a comprehensive sample

• history so that'we can understand what correlation, jf any, there may be between our in~ke water mercury ~rJcentrations and our discharge water.* *

3. The plant requests a twp-y~r delayed implementation of the stormwater iron *

• benchmark limits established in this permit* renewal. Severi *new sformwater outfalls have been established with th.is permit* with which We have very limited sample -

• history. The_re is some uncertainty as to whether we will be challengeq to meet benchmarks. We would like some more time to establish a comprehensivErsample these history so that we can understand what cnalleng8$ we might have with managing stormwater* iron. During this time, we will coritini.J_e to sample *a_nd report results from these outfalls,-implement pest management practices, and pursue any necessary corrective actions associated with elevated storrilwater contaminants. .

4. BVPS i~ also requestihg a period *of ninety (90) *days to i:9.mply with the final permit

• following issuance to a_llow the site sufficient tim~ to align the current procedures and business practices with the new permit requireme~ts.

• _We-appreciate your consideration of 01.:1r concerns a*nd would like an opportunity to talk about the issyes discussed in this letter. Should you _have any questions please contact Amy Savag~ at aesavage@energyharbor.com or 7~4-68_2-7359.-

• Sincerely, J. Enos*

ral :Plant Man*ager

• cc: mtfeMiireiSU@G>fitiilijfll!)e'_sRlt!J;SIN~~w- US NRC commitments_*ar~ contair,ed in this letter.)