ML18018A604

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Forwards Comments on Des.Requests Clarification of Section Re Chemical Impacts of Blowdown Discharge on Reservoir. Statement Acceptable
ML18018A604
Person / Time
Site: Harris  Duke Energy icon.png
Issue date: 07/01/1983
From: Scott Moore
ENVIRONMENTAL PROTECTION AGENCY
To: Kadambi P
Office of Nuclear Reactor Regulation
References
NUDOCS 8307110258
Download: ML18018A604 (4)


Text

pe S)4p g h, UNITED STATES ENVIRONMENTALPROTECTION AGENCY REGION IV 345 COURTLANDSTREET ATLANTA.GEORGIA 30365 JUL Ol l983 4PM-EA/JM Dr. Prasad Kadambi Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Dr. Kadambi:

We have reviewed the Draft Environmental Impact Statement (DEIS) related to the operation of the Shearon Harris Nuclear Power Plant Unit 1 and 2 in Wake and Chatham Counties, North Carolina.

Our review suggest that the plant as designed should be capable of operating under normal conditions in such a manner as to,meet EPA's "Environmental Radiation Protection Standards for Nuclear Power Operations" (40 CFR 190).

In our review of the DEIS in respect to our responsibilities under the National Pollutant Discharge Elimination System (NPDES),

we suggest that the Section of the DEIS on Chemical Impacts of Blowdown Discharge on the Reservoir (Section 5.3.1.2.2) need to be clarified.

In this regard, our attached technical comments discuss those areas where changes or an expanded discussion is needed in the Final EIS.

In conclusion, we have rated the DEIS L0-2, i.e.,

we do not believe the normal operation of the nuclear facility will have a significant environmental impact but we are requesting change in the FEIS as reflected in our attached technical comments.

Sincerely yours, Sheppa N. Moore, Chief Environmental Review Section Environmental Assessment Branch Attachment 8307ii0258 83070i PDR AOaCX OSO00eoO 0

PDR gpdA r/I

Technical Comments 1.

Page 5-4, first complete paragraph.

EPA staff concurs with the NRC staff that a level of 0.2 mg/1 of Total Residual Chlorine (TRC) in the cooling tower blowdown should be utilized by the applicant as an operational control instead of the 0.2 mg/1 of Free Available Chlorine (FAC) limit in the NPDES permit.

In this regard we believe levels on the order of 0.1 mg/1 should be achievable by hold-up blowdown for periods of two to three hours before starting release.

2.

Page 5-4, last paragraph.

Practicable field detection for residual chlorine is stated to be as about O.l mg/1.

Our experience suggest that the amphometric tritration method for chlorine analysis as required for NPDES monitoring purposes (especially in relatively pure water as expected at the Harris site) should result in a routine field detection limit below 0.05 mg/1.

Detection of levels of 0.02 to 0.03 are typically presented in NPDES monitoring data.

Sensitivity of approved monitoring equipment is reported to be on the order of 0.01 mg/1 for portable instruments and 0.001 mg/1 for fixed, contin-uous monitors.

Accordingly the detection limits needs to be refined in the Final EIS.

3.

Page 5-4, last paragraph.

Available data indicates that unless coaling tower blowdown is discontinued after chlorine is introduced into the cooling system (allowing some chlorine decay) there is a high potential for TRL to be discharged above detectable limits for more than two hours per day.

This point, in concert with Comment No. 2, needs to be clarified in the Final EIS.

4.

Page 5-5, first complete paragraph, effluent guidelines.

40 CFR Parts 423.12(8) and 422.13(d)(1) and (2) as promulgated on November 19, 1982 (47FR 52290), limit the discharge of FAC or TRC in cooling tower blowdown to a maximum of two hours per day per unit and ~rohibit simultaneous discharge at a multi-unit plant.

This should be coriected in the Final EIS.

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