ML20006C459

Forwards Info Re Mods to Plant NPDES Permit,Per Plant Environ Protection Plan,App B to License NPF-67

ML20006C459
Person / Time
Site:	Seabrook
Issue date:	01/31/1990
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20006C460	List: ML20006C459 ML20006C463
References
NYN-90029, NUDOCS 9002080065
Download: ML20006C459 (11)

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New Hampshire Ted C. F4 '

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Senior Vice President and I Chief Operating OHicer 2

4 NYN. 90029 -

F, January 31, 1990 United-States Nuclear Regulatory Commission

. Washington, DC 20555-Attentions: Document: Control Desk

References:

-(a) Facility Operating License NPF-67, Docket No. 50-443 (b) NHY Letter.NYE-89056, dated November 6, 1989,

' NPDES Permit Modification," T. C. Feigenbaum to E. K.

McSweeney, USEPA

. c) USEPA Letter dated January 18, 1990, 'Seabrook Station

(

NPDES Permit Modifications,' E. K. McSweeney to T. C. - Feigenbaum-

Subject:

Seabrook Station NPDES Permit Modification

- Gentlemen -

The Seabrook Station Environmental Protection' Plan, Appendix B to

- Facility Operating License NPF-67, requires that the NRC be notified when changes are proposed to the effective NPDES-permit. Due to an

-administrative error, Reference (b) was not provided as required.

A. copy.

of this letter is provided-as Enclosure 1 to this' letter. Additionally, a

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y copy of Reference'(c) is provided as Enclosure 2.

Should-youihave any questions regarding this matter, please call Mr.

James.M. Peschel, Regulatory Compliance Manager, at (603) 474-9521,

' extension 3772.

Very truly yours, 4

f A ligenbaum

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9002080065 900131 1

PDR ALOCK 05000443 g68 P

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New Hampshire Yankee Division of PubP-Service Company of New Hampshire j

' P.O. Box 300

• Seabrook, NH 0387.5

• Telephone (603) 474 9521 l

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~ United States Nuclear. Regulatory Commission January 31, 1990 i

Attentions Document Control Desk Page 2 t-cca Mr. Victor Nerses, Project Manager Project Directorate I-3.

' United States Nuclear Regulatory Commission Division of. Reactor Projects Washington, DC 26555 Mr. Noel Dudley NRC Senior Resident Inspector c

P.O.' Box 1149 p

Seabrook, NH 03874 r,.

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United States Nuclear Regulatory Commission January 31.,1990 Attention: Document Control Desk Page 3 2..'

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. ENCLOSURE 1 TO NYN-90029 Seabrook Station NPLES Permit Modification s

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Ted C. Feigenboum F

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Senior Vice President ond.

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NYE-8 9 0 5 6 -

November-6, 1989 1

1 Mr. Edward K. McSweeneys U. S.' Environmental Protection Agency J. F. Kennedy Building.

i l4 Boston, Massachusetts 02114 References. Seabrook Station NPDES Permit No. NH0020338 t

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Subjects' ' NPDES: Permit Modification a

Dear Mr. McSweeney:

~'In accordance with 40 CFR Part 124, New Hampshire Yankee (NHY) requests that modifications-be made to the NPDES permit issued to Seabrook Station..

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These modifications are minor in nature, and are the result of: technical

! corrections and new information that was-not availsble at the time of permit'

~ issuance. 'Each modification, along with the appropriate justification for the-l '~

change,.is described in Enclosure 1.

A complete NPDES ~ permit: renewal

' application will be submitted by February 23, 1990, at least 180 days prior to the permit expiration.

Should there be any questions.on this material,-or additional'information

required, pleare do.not hesitate to contact Mr.. James M. Peschel,-NHY Regulatory Compliance Manager at (603) 474-9521 extension 3772.

Very truly'yours, fs&lG h =2*b W Ted C..Feigenbaum h<

-Enclosure l

cc: New Hampshire Water Supply &

Pollution Control Division 6 Hazen Drive, P.O. Box 95' I

Concord, NH 03301 L-I' l

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New Hampshire Yankee Division of Public Service Company of New Hampshire P.O. Box 300

• Seabrook, NH 03874

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ENCLOSURE 1 TO NYE-89056

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New Hampshire Yankee November 6, 1989 Outfall 001 Modifications:

Seabrook Station was designed and built with a once-through' cooling water system with the-capacity to handle flow from two power plants and reject a 9

' total of 16 x 10 BTU /hr. to the environment. The 1974 application for Seabrook Station's NPDES permit identified a flow of 1,187 million gallons per day-(mgd) as the required flow for two-unit operation.

The related environmental assessments (316(a) and 316(b) demonstrations] considered the impact of.the flow through the Cooling Water System for a-two-unit operation.

.The conclusions reached were that two-unit flow would have acceptable environmental impacts.

The EPA Region I-Administrator in the June 24, 1975, determination stated that._"The' design, construction and capacity of all components of the cooling water system seaward of the inlets to the main condensers or other heat exchangers,las appropriate, of the Seabrook Station (" cooling water inlet structures'), shall-in all respects be in accordance with the NPDES Permit Application No. NH0020338, as submitted August 1, 1974".

The 1,187 mgd flow presented within the 1974 permit application was also presented within the permit renewal application submitted on January 30, 1981.

1 The EPA Administrator in June 1977, issued a decision affirming the Regional Administrator's earlier decision. He concluded that relevant to 316(a),1 "that the discharge limitations proposed... will assure the protection

'and propagation of a balanced indigenous population of fish, shellfish and wildlife-inand on the receiving waters".

His basis was that Seabrook Station l

" consists of two units, one estimated to begin operation in-1981 and the other in 1983", and that " cold water will flow to the plant at a rate'of 824,000 gallons per minute (gpm)... The quantity-of heated water discharged will' average 1,187,000,000' gallons per day".

Relative to 316(b), the Administrator also concluded-that "the design and location of the intake at the far. site and the diffuser functioning as an intake, reflects the best available technology for minimizing. adverse environmental impact".

As presented on Figure 1, the flow for two-unit operation (6 Circulating Water System Pumps operating) given within the 1974 application for permit was

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780,000 gallons per minute.

The permit application value for the Cooling Water System of-824,000 gpm (1,187 mgd) is obtained by adding the expected two-unit Service Water System flow of 44,000 gpm.

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The original flow estimate utilized in the 1974 permit application, and carried through to the 1981 permit renewal application, was for six Circulating Water System Pump operation at low tide.

Because the flow actually varies throughout the tidal cycle, with the highest flow being realized at high tide, an average flow over the tidal cycle should have been used on the application.

The existing permit allows for this variation by requesting that the average daily flow be reported.

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Further, the actual flow for the Circulating Water System for three Circulating Water System Pump operation has since been determined by Alden Research Laboratories through testing.

These tests revealed that the performance of the system and pumps is better than designed.

The Alden-

-Research Laboratory flow measurement report is provided in Enclosure.2. As

-presented on Figure 1, an actual flow of 469,900 gpm was determined for the Circulating Water System Pumps-during one high tide test. Adding the as-built flow of the Service Water System for one unit (25,700 gpm),_results in a high tide Cooling Water flow of 495,600 gpm (713.7 mgd).

As-specified within 40 CFR 124.5,_an NPDES' permit may be modified at the request oflthe permittee for the reasons specified within 40 CFR 122.62. '40 CFR 122.62, states that when the Director receives any information-he may determine whether or:not one or more of the causes listed within the section exist.

40 CFR 122.62 (a)(2), allows for the modification of an NPDES permits 3

during itsLterm, if information-that was not available at the time of permit

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issuance would-have-justified the' application of different permit conditions _at the time of issuance. The as-built flow information presented here was

-unavailable at the-time of permit issuance'and conforms to the above section.

Furthermore, 40 CFR 122.62 (a)(16) allows for permit modifications to correct technical mistakes. Two technical errors were made in the NPDES permit process:

(1)_the applicant incorrectly used the low tide flows within the original permit application and (2) a modification in the. permit made just

, prior to its issuance in 1985, cut the two-unit flow in half for one unit operation and did not take into account the increased design flow with three pump operation-due-to decreased system resistance.

The present flow limit, therefore, could be exceeded during the normal operating mode'of the plantLwhen three Circulating Water System Pumps are in operation. Reducing the flow through the use of two circulating Water System Pumps, could result in an exceedence of the delta temperature limitation specified within the permit.

A modification of the flow limitation for Outfall 001, from 594 mgd to 720 mgd is necessary to operate Seabrook Station as intended. This value of 720 mgd accounts for the measured as-built flows for a single unit within a system capability originally designed for two unit operation, with'

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consideration for performance during high tide. A flow of 720 mgd is less than the limit specified in the Seabrook Station NPDES permit applications. The 720 mgd flow is also less than the flow provided on the draft permit that was

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issued for-comment and for which the applicant had demonstrated no appreciable harm to the environment. A modification of the flow will not result in an increase in the delta temperature as specified within the NPDES permit.nor increase the heat rejected by the plant.

It is therefore requested that the permit limitation for flow for Outfall 001 be modified to 720 mgd for the following reasons:

The original flow request of 1,187 mgd was shown to be of no appreciable harm to the environment.

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The modification of the flow will not increase-the delta temperature nor increase the heat rejected by:the plant.

The 1985 permit was changed prior to issuance to a-flow limit one-half of the two unit flow. Because of decreased system resistance, the flow for three Circulating Water System Pump operation is greater than one-half of the flow for six Circulating Water System Pump operation.

-The as-built system performance for three Circulating Water _ System Pumps _and two: Service Water System Pumps exceeds the designed system performance (Figure 1)..

The existing permit allows for flow variation as a result of tides.

m-The original application should have used a. design value for-six Circulating Water System Pump. flow at least at the expected mid-tide r

range with a clean unfouled system.

The plant may exceed the delta temperature with two Circulating Water System Pumps operating.

The plant may exceed the flow at outfall 001 with three Circulating Water System Pumps operating.

Outfalls 022. 023. 024 Modifications Secondary-plant: leakage into the oil / water separator vaults includes leakage from equipment whose water chemistry will be maintained with a pH at I

- or above _the current permit limit of 9.0.

These vaults were designed and built to-separate oils from secondary plant leakage prior to discharge. No mechanism to automatically monitor and adjust the pH of the effluents were planned or ' installed. - Because of this, the vault (s) may occasionally be out of the allowable pH range of 6.0 to 9.0.

Each vault discharges to a designated NPDES discharge stream which is monitored for_pH compliance prior to its discharge to the environment-(Figure'2).- Outfall 022 discharges upstream of.0utfall 001 which is monitored routinely for pH, and outfalls 023 and 024 discharge upstream of Outfall 002 1

which is also. monitored for pH prior to discharge to the environment, It is therefore requested that the pH monitoring limitation at each oll/ water separator vault be eliminated from the permit.

Established downstream pH monitoring locatiens ensure that applicable permit discharge limits are maintained, conforming to water quality standards.

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O 50 100 150 200 - 250 300 350 400 450 500 550 600 650 700 750 800 850 900-469.900 1974.2 UN!T PERMIT.

FLOW - X1000 GPM APPLICATION VALUE 1.187 MILLION GALLONS / DAY 1985 PERMIT (7/853 780.800 GPM-CW 594 MILLION GALLONS / DAY

+ 44.000 GPM-SW

= 412,500 GPM

- 21.000 GPM-SM %

780 824.000 GPM

• - 391. 500 GPM-CW 390 SEABROOK STATION - CIRCULATING WATER SYSTEM CHARACTERISTIC CURVES NOTE: FOR INFORMATION ONLY REPLOTTED FROM SPEC.238-4 WITH ALDEN t A8. TEST ADG D 4 DESIGN VALUE CHANGED. FROM 1974 H.C.SHAFFER CM090001 yNSo se/is/89

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e FIGURE 2 SEABROOK STATION DISCHARGE FLOW PATHS pH MONITORING EMERGENCY FEED WATER 1 RECOVERY TEST

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SGBD WASTE PUMPHOUSE DRAINS

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