BECO-LTR-97-081, Requests Permission to Permanently Substitute Daily Grab Sampling in Place of Continuous Chlorination Monitoring for PNPS Ssws.Change Should Be Reflected in Renewed NPDES Permit.Epa Ltr Authorizing Permanent Substitution,Requested

Requests Permission to Permanently Substitute Daily Grab Sampling in Place of Continuous Chlorination Monitoring for PNPS Ssws.Change Should Be Reflected in Renewed NPDES Permit.Epa Ltr Authorizing Permanent Substitution,Requested

ML20211M359
Person / Time
Site:	Pilgrim
Issue date:	10/03/1997
From:	Boulette E BOSTON EDISON CO.
To:	Downing J ENVIRONMENTAL PROTECTION AGENCY
References
BECO-LTR-97-081, BECO-LTR-97-81, NUDOCS 9710140155
Download: ML20211M359 (2)

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o a um um Pilgten Nuclear Power staten Rocky Hill Road Ptymouth. Massachusetts 02360 October 3, 1997 E. T. Boulette, PhD BECo Ltr. 97 081 Senior Vice President - Nuclear Ms. Jane Downing Director, Office of Ecosystem Protection U.S. Environmental Protection Agency JFK Federal Building Boston, MA 02203

Dear Ms,

Downing:

Boston Edison Company (BECo) requests permission to permanently substitute daily grab sampling in place of continuous chlorination monitoring for Pilgrim Nuclear Power Station's (PNPS) salt service water system (SSWS). Currently, daily grab sampling is allowed by PNPS's NPDES Permit #0003557 as a substitute when the continuous chlorination monitoring system is out of-service. We request that this change be reflected in PNPS's NPDES Permit when it is renewed.

Until then, we request an EPA letter authorizing the permanent substitution.

Our reasons for this request are as follows:

. Use of continuous flow from the SSWS piping to supply the continuous chlorination monitoring system was noted as a seismic integrity safety concem identifieo during SSWS self-inspection in accordance with the guidelines of USNRC Generic Letter #89-13. That concern has been addressed by cutting and capping the pipes constituting the SSWS/ continuous chlorine monitor interface.

Measurements or samples for permit compliance are taken in the SSWS prior to mixing with other streams. The system is not chlorinated unless at least 1 circulating water system 4 (CWS) pump (approx.15:1 dilution factor) is running; most often,2 CWS pumps (approx.

30:1 dilution factor) are operating. Upon mixing with the substantial CWS flow, the chlorine released to Cape Cod Bay is negligible.

. We have detected no known chlorine-related environmentalimpacts from the SSWS at PNPS during its 25 year operating history.

We would appreciate your written approval for use of daily grab samples in the SSWS as the means of monitoring chlorine at PNPS Please contact Mr. Robert D. Anderson at (508) 830-7935 should you need further information regarding this matter.

b b E. T. Boulette, PhD RDA/dmc/radmisc!patc1. doc  ! [C0g 9710140155 DR 971003 -

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g' g. 4 cc: . Mr. Paul Hogan Office of Watershed Management 40 Institute Road North Grafton, MA 01536 Mr. Nicholas Prodany U.S. Environmental Protection Agency JFK Federal Building Boston, MA 02203 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Senior Resident inspector Pilgrim Nuclear Power Station

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