ML18219D520
| ML18219D520 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/16/1977 |
| From: | Tillinghast J Indiana Michigan Power Co, (Formerly Indiana & Michigan Power Co) |
| To: | Rusche B Office of Nuclear Reactor Regulation |
| References | |
| Download: ML18219D520 (20) | |
Text
NRC FQBM 1S5 (2 76)
U.S. NUCLEAR REGULATORY Co'SSION 5@I - 3 6/3 i g FILE NUMBER NRC DISTRIBUTION FOR PART 50 DOCI<ET MATERIAL nuI vO TO: Mr, B,C, Rusche FROM: Indiana & Mich Power Co OATE OF DOCUMENT New York, N.Y, 10004 3-16-77 J Tillinghast OATE RECEIVED 3 21-77 9fLETTER KNOTOB IZE O PROP ~ INPUT FORM C NUMBER OF COPIES RECEIVEO RfoRIGIN*L KJ NC LASS IF I E O OCOPY ~
. g. g/ h oEscRIPTIQN Ltr notarized 3-17-77 request for a ENGLosURE Attachment A is a reuised pages'2.2-4 temporary change to tech specs to allow a one dealing with tech spec .shag!m change..'XP time chemical cleaning operati.on of the unit trans v ttachment', '&
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March 16, 1977 j(Py Donald C. Cook Nuclear Plant tt~ t877~
Docket Nos. 50-315 and 50-316 E 'COIIlQ hIcII S (SSIOI~ 7 j
DPR No. 58 and CPPR No. 61 (
i/l~, y Mr. Benard C. Rusche, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Rusche:
This letter is a request for a temporary change to Environmental Technical Specification 2.2.3.2 to allow a one-time chemical cleaning operation of the Unit No. 2 Condensate and Feedwater Systems as described hereafter.
Attachment. A is a revised page 2.2-4 to indicate the change we propose.
As part of the startup operations for Unit No. 2 of the Donald C. Cook Nuclear Plant, it, will be necessary to perform a hot detergent cleaning of the Unit No. 2 Condensate and Feedwater systems. The cleaning operation is a one-time preoperational hot mater flush with a mild alkaline solution to remove small amounts of materials left in the piping internals during construction and is expected to take place during the second quarter of 1977. A similar operation was performed on Unit No. 1, from July 16 through 20, 1973, prior to its startup.
The specific objectives of the preoperational cleaning are:
- 1. .To loosen and remove debris not removed by prior water flushing.
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- 2. To remove from the system piping internals any coatings or preservatives applied prior to or during constr'ctiOn..
- 3. To formaa protective oxide coating on the carbon steel portions of the system prior to initial startup.
The "cleaning" will be done by circulating approximately 300,000 gallons of a 180 1904F. solution of tri- anddi-s'odium phosphate throughout the system for approximately 12-24 hours and then flushing to the on-site absorption field with approximately 600,000 gallons of clean water.
The composition of the cleaning solution will be as follows:
a~ 3,500 ppm Tri-sodium phosphate (Na3PO4) .
- b. 1,500 ppm Di-sodium phosphate (Na2HPO4).
c ~ 300 ppm Surfactant (mixture of nonionic and anionic surfactants Dow Industrial Service proprietary chemical No. FO-57.)
- d. 200 ppm Anti-foaming Agent (silicone base anti-foam emulsion Dow Industrial Service priprietary chemical No. MO-45) .
The cleaning solution and rinse waters will be drained from the Condensate and Feedwater Systems to the turbine room sump and pumped to the on-site absorption field.
Section 2.2.3.2 of the Donald C. Cook Nuclear plant Environmental Technical Specifications places the following limitations on the conduct of the cleaning operation:
"Chemicals used in the plant shall be diluted and. neutralized as required to give a pH in the range of 5.5 to 9 prior to discharge to the onsite absorption field."
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- 2. "No oil or petroleum products shall be discharged to the lake or onsite absoxption field."
- 3. "On those occasions when spent chemical cleaning solutions are to be discharged to the absorption field, samples of the sump waste water shall be collected and analyzed for all chemical species (including heavy metals and hydrocarbons) that potentially could xesult from the cleaning operation."
We request that we be temporarily allowed to exceed these limitations for the following reasons:
Although the cleaning solution will be alkaline (expected pH of about 11.5) the large volumes of rinse water and lower pH water already in the absorption field is expected to xeduce the pH of the mixture to less than 9.0 at the time of discharge into the ground. Thus, we believe it would be unwise to add approximately 10,000 pounds of neutralizing chemicals sulfuric or hydrochloric acid to reduce
'the pH of the cleaning mixture to 9.0 prior to pumpout at the turbine room sump as this would unnecessarily incxease the overall amounts of, chemicals discharged to the environs without a corresponding benefit thereto.
- 2. The cleaning solution will remove any coatings ox preservatives on the internals of the system piping and/or heat transfex surfaces. This is required in preparing the secondary cycle for initial operation.
We expect that any hydrocarbons removed by the operation would be of the order of a few gallons in an emulsified form and essentially undetectable.
h 3 Since the cleaning operation is essentially a hot detergent flush using a solution containing no heavy metal inhibitors 'or other compounds in a system fabricated almost entirely of iron and coppex, we believe that analyzing for heavy metals (other than iron and copper) is not recpxired.
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Mr. B. C. Rusche March 16, 1977 A similar request to the Michigan Water Resources Commission was made by letter dated December 7, 1976 for approval to discharge the cleaning solution and rinse waters to the ground, through the absorption field, without holdup for neutralization as planned. The Michigan Department of Natural Resources, Water Quality Division, by letter of January 13, 1977 did grant approval of this request. Copies of these two letters are attached for your information as Attachment B and C, respectively.
A supplement to Table 2.2-1 is provided, as Attachment D for your information and inclusion in the Environmental Technical Specifications.,
We propose that the change would expire at the time of Unit 2 initial criticality and would not change the intent of the specification, which will still ensure that the discharges to the absorption field are not adversely affecting the quality of the groundwater outside of the immediate vicinity of the field.
Our schedule presently calls for this cleaning operation to begin in the last week in April 1977 and we therefore request your prompt review and approval of this proposed change.
Very truly yours, T ingh Vice Presid JT:mam Attachment cc: Sworn and subscribed to before me this/'7@day of March, 1977 in New, York County, New York
! PmZx Notary Public DAVID G. EGSIH NOTARY PUBLIC, Sate ol New York No. 314608113 Qualified ia New York County Commission Expires March 30, 1979 CC see next page
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Mr. B. C. Rusche March 16, 1977 cc: G. Charnoff R. C. Ca1len P. W. Steketee R. Walsh R. Z. Vollen R. W. Zurgensen Bridgman R. S. Hunter
Attachment A The maximum annual discharges of phosphate and morpholine permitted in the Specification correspond to normal operation 95X of the time of operation and operation at the maximum phosphate content and blowdovn rate for 5Z of the time. The rorpholine concentration is expected to be maintained at 20 ppm in the blovdown at all times. Hydrazine vill be added to the steam system as an oxygen-scavenging corrosion inhibitor'. At the. elevated operating temperature any of this chemical that has not reacted with oxygen vill decompose to nitrogen and ammonia. The maximum annual discharge per-mitted, in the specification is that corresponding to normal operation
. (0.02 ppm hydrazine) for 99X of the time of operation and the maxi~ con-centration (96 ppm) for a maximum of 1X of the operating time for times 5ust before and after shutdown. It is assumed the plant vill operate SOX of the time in calculating maximum permitted releases.
~ Maximum discharge concentrations are calculated on the basis of a cir>>
culating vater discharge rate that is the mean of those for Unit 1 and
,Unit 2.
II No other plant corrosion or deposit inhibitors will be discharged to the plant environs.
2.2;3 OTHER C~ICAL DISCHARGES 2.2.3.1 ~Ob ective The purpose of this specification is to control or limit the release of chemicals, other than cor osion and deposit inhibitors, to the lake or
.the onsite absorption field to preclude or minimize potentially adverse impacts on aquatic or terrestrial biota due to plant operation.
Qe maximum quantities and discharge concentrations of other chemicals used in thc plant which will be discharged to the lake and to the onsite absorption field shall be 11z:ited to the values specified in Table 2.2.1.
Chemicals used in the, plant shal'e diluted and neutralized as required to give a pH in the range of 5.5 to 9 prior to discharge to the onsite absorption field. Excepting chlorine, no toxic chemical, e.g., chromates, mercury ccmpounds, etc.. shall be discharged to the lake or onsite absorp-tion field.'o oil or petroleum products shall be discharged to the lake or to the onsite absorpt'on field. The composition and quantity of detergents (Table 2.2-1) used and discharged to the lake shall be 'reported in the annual Operating Reports.
On those occasions vhen spent chemical cleaning solutions are to be dis-charged to the absorption field, samples of the sump waste vater shall be collected and analyzed for all chemical species (including heavy metals Note: For the one time chemical cleaning of the Unit 2 Condensate,. and Feedwater Systems, to be completed by the, time of Unit 2 initial criticality, the following exceptions to Specification 2.2.3.2 apply-. Neutralization of cleaning solution prior to discharge to the absorption field is not required, small quantities of hydrocarbon coatings or preservatives may be discharged with the cleaning solution flush, of the order of a few gallons, and sampling for heavy metals, other than iron and copper, are not required.
2 2-4
Attachment B December 7, 1976 Robert Courchainc, Chief Engineer Michigan Hater Resources Commission Stevens T. Mason Building Lansing, Michigan 48926
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SUBJECT:
Donald C. Cook Nuclear Plant Bridgm ~m, Michigan Preopcratiorral Cleaning of Unit 2 Condensatc and Feedwater System
Dear Mr. Courchaine:
On July 10, 1974 the Michigan Nater Resources Commission issued a permit to 'the Xndiana 6 Michigan Power Company to dispose of various liquid effluents to the ground at the sito of thc Company'8 Donald C. Cook Nuclear Plant in Bridgman, Michigan (Permit H00064).
This permit requires, among other things, that the Company
"...obtain prior approval of thc Chief Engineer of the Commission before discharging spent cleaning solvents or other chemical wastes, other than spent regenerants, to the ground" (permit "Special Condition" I, page 3).
As part of the startup operations for Unit 2 of the Donald C.
Cook Nuclear Plant it will be neces".:.ry to perform a hot deter-gent cleaning of the Unit 2 condensate and feedwater systems.
The cleaning is a one-timo preoperational hot water flush with a mild alkaline solution to remove material left in the piping internals during construction and is expected to take place during the first quarter of 1977. A similar operation was performed on Unit 1 from July 16 through 20, 1973 prior to its startup.
The specific objectives of the preoperational cleaning are:
- 1. To loosen and remove debris not removed by prior water flushing.
2.. To remove from the system piping any oily materials and any rust preventatives applied during construction.
- 3. To form a protective oxide coating on the carbon steel portions of the system.
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g Robert Courchaine, Chief Engineer
,December 7, 1976 Page two The cleaning will be done by circulating approximately 300,000 gallons of a 180-190oF. solution of tri-phosphate throughout the system for. approximately 12-24 hours and di-sodium anQ then flushing to the absorption pond with approximately 600,000 gallons of clean water.
The composition of the cleaning solution will be as follows:
- a. 3500 ppm Tri-Sodium Phosphate (Na3PO4)g Approx. 8750 poundsy C
- b. 1500 ppm Di-Sodium Phosphate (Na2HPO4),
Approx. 3750 pounds;
- c. 300 ppm Surfactant, Approx 750 pounds~ and
- d. 200 ppm Anti-foaming agent, Approx. 500 pounds.
The cleaning solution and the rinse water will be drained from the condensate and feedwater systems to the turbine room sump anQ then will be pumped to the absorption pond. Although the cleaning solution vill be highly alkaline (expected pH about 11.5),
the large volumes of rinse water and lower pH water already in the absorption pond is expect Q to reduce the pH of the mixture to
'less than 9.0 prior to discharge into the ground. Thus, we believe it would be unwise to add the approximately 10,000 pounds of neutralizing chemicals sulfuric or hydrochloric acid--
necessary to reduce the pH of the cleaning mixture to 9.0 prior to pumpout at the turbine room sump since this would unnecessarily increase the overall'mounts of chemicals discharged to the environ-ment.
Xn accordance with Paragraph I of Hater Resources Commission Permit H00064, we request your approval to discharge tne cleaning solution and rinse waters to the grounQ, through the r..bsorption pond, without holQup for neutralization, as planned.
Very true yours, G. E. Lelfasters Executive Assistant GEL/sdb
'cc: R. W. Jurgensen T. A. Niskimen T. F. Plunkett F. J. Batchelder.
T A. Kreisel
~ J. E. Sherwood'.
E. E. Smarella II. Steinhart J A. Druckomi lier
~ G. W. Pennocke R. W. Reeves L. Storch
Attachment C
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4 STATE OF MICHIGAN NATURAL RESOURCES COMMISSION CARL T. JOHNSON E. M. LAITALA WILLIAM G. MILLIKEN, Governor OEAN FRIOGEON
.HILARY F. SNELL DEPARTMENT OF NATURAL RESOURCES HARRY H. WHITELEY STEVENS T. MASON 8UILOING, LANSING. MICHIGAN 46926 JOAN L WOLFE HOWARO A. TANNER, Olrcctor CHARLES G. YOUNGLOVE January 13, 1977 Mr. G. E. LeMasters Executive Assistant Indiana and Michigan Electric Company 2101 Spy Run Avenue P. 0. Box 60 Fort Wayne, Indiana 46801
SUBJECT:
Donald C. Cook Nuclear Plant
Dear Mr. LeMasters:
This is in'eply to your December 7, 1976, letter regarding preoperational cleaning of Unit 2 Condensate and Feedwater System.
We agree with your. assessment that the addition of neutralizing chemicals are not necessary and are hereby granting approval of your request with
. the following condition:
Residual free oils must be removed from the turbine room sump prior to the
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flushing oper'ation.
Feel free to call us if you have q'uestions regarding this matter. We ask that you notify us as to the exact date and times that the cleaning operation'ill take place, as soon as this has been determined.
Very truly yours, WATER QUALITY DIVISION
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Robert J. Cour aine Division Chief RJC/hb cc: W. Denniston C. Harvey MIC 'l tttt iigjQV
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TABLE - 2.2-1 (cont'd)
OTIIL'R CIIEMICAL DISCIIABGES TO TIIE ENVIRONS Estimated Maximum Annual Estimated Maximum Discharge Use 8c l'stimated Discharge Chemical Dischar e er e r Concentration m Di.". c! mr~eFr~eu en c 'J'o Tri- On site and Di 12,500 lbs. 5q000 Used for Pre" Absorption Sodium operational chemical Pond Phosphate cleaning of the Unit No. 2 Con" densate and Feed water Systems 'i-
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