ML20009C905

Application for Amend of Licenses DPR-29 & DPR-30,submitted as Proposed Revisions to App B Tech Specs to Correspond W/Encl NPDES Permit IL0005037

ML20009C905
Person / Time
Site:	Quad Cities
Issue date:	07/16/1981
From:	Rausch T COMMONWEALTH EDISON CO.
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20009C906	List: ML20009C905 ML20009C907 ML20009C909
References
NUDOCS 8107220120
Download: ML20009C905 (9)

Text

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77 Commonwealth Edison

[ - ) One First Nation 21 Plata, Chicago Illinois

' ( C ' Address Reply to: Post Office Box 767

,/ Chicago, Illinois 60690 9 \JD July 16, 1981  %

Director of Nuclear Reactor Regulation ;sfOi$lf[(C d

U.S. Nuclear Regulatory Commission Washington, DC 20555 [ s.QkQg llSg7

/

Subject:

Quad Cities Station Units 1 and 2b Proposed Amendment to Appendix B @

Technical Specifications for Operating p C -

Licenses DPR-29 and DPR-30 to Correspond with NPDES Permit Limits NRC Docket Nos. 50-254 and 50-265-

Dear Sir:

Pursuant to 10 CFR 50.59, Commonwealth Edison proposes to amend Appendix B to Operating Licenses DPR-29 and DPR-30. This proposed amendment would allow the Appendix B non-radiological limits to correspond to those required by the National Pollutant Discharge Elimination System (NPDES) Permit No. IL0005037.

The proposed changes would eliminate sampling and monitoring which is c'urrently required over and above NPDES requirements by the existing Technical Specifications.

Specifically, chlorine and temperature monitoring requirements are reduced, and chemical effluents are addressed by maintaining a range of pH and by sampling for total dissolved solids. Existing Appendix B Technical Specifications directly specify limits for cumulative annual discharges of certain corrosion inhibitors and other chemicals used in the facility.

Commonwealth Edison has performed an extensive review of this proposed change, and has determined that use of the NPDES limits will provide more realistic environmental monitoring, witu little if any change in the actual chemical and thermal discharges l

' now being made to the Mississippi River in conjunction with station operation. A detailed item by-item disca.sion of the rationale for the proposed change is provided in Attachment 1. A summary comparison of current Technical Specification requirements with NPDES' permit requirements for Quad Cities Station is also provided in Attachment 2.

Additionally, in order to facilitate your review, five (5) copies of NPDES Permit No. IL0005037 are provided with this f h0s0 Ih

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transmittal. Although this permit has expired, we currently operate under its provisions. We applied for renewal prior to permit expiration, and are currently awaiting action by the State of Illinois, should any changes be made in the permit it should be noted that Section E.3 (Reporting Requirements) of this proposed amendment requires the NRC to be notified of any such changes.

Attachments 3 and 4 contain complete proposed Appendix B Technical Specifications for Quad Cities Units 1 and 2. The entire Appendix B section with bases is being submitted for clarity purposes, however no change is proposed to Section El.3/2.3, Fish Impingement.

These proposed changes have received On-Site and Off-Site review and approval with the conclusion that these changes are not safety related. In addition, since discharge limitations and associated surveillance of the NPDES permit will be observed, implementing this change will have minimal impact on the environment.

Pursuant to 10 CFR 170, Commonwealth Edison has determined t h"a t the proposed changes are a combined Class I and Class III amendment. 'As such, a fee remittance in the amount of $4,400.'00 is enclosed.

Please address any questions you may have concerning this matter to this office.

Three (3) signed originals and thirty-seven (37) copies of this letter are provided for your use.

Very truly yours,

$,,&w/$auuf Thomas J. Rausch Nuclear Licensing Administrator Boiling Water Reactors Attachments cc: .RIII Inspector - Quad Cities SUBSCRIBED'and SWORN to bef or e me th i s /[ r:i[]

day of Ot/ru , 1981 0dA -

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21 Notary Public 2291N

ATTACHMENT 1 Commonwealth Edison Company Rationale for the Request for Modification of Quad-Cities Station Appendix B, Nonradiological Technical Specifications El.1/2.1 Chlorine Effluent Quad Cities Station is presently required under Appendix B, Nonradiological Technical Specifications, to periodically conduct monitoring during chlorination as follows:

1. Periodically during chlorination, but at least four times per calendar month, the total chlorine content of the water in the discharge bay shall be analyzed in order to characterize the condenser effluent prior to discha ge into the Mississippi River.

Representative samples snall also be analyzed when not chlorinating to ascertain _ background conditions.

2. Periodically during chlorination, but at least four times per calendar month, the total chlorine content of the water downstream of the diffuser pipes shall be analyzed in order to judge the impact of condenser effluent after discharge into the Mississippi River.

Representative samples shall-also be analyzed when not chlorinating to ascertain backgcound condition.

The monitoring program, conducted by Commonwealth Edison Company (CECO.) sir.ce the chlorine surveillance requirement was enacted in 1974, has examined chlorine concentrations both in the intake forebay, discharge bay, spray canal and in the Mississippi River.

Commonwealth Edison Comany, for reasons stated below, requests that this ~onitoring and the applicable environmental protection monitoring conditions be reouced to chose specified in the Quad Cities S'tation NPDES permit. A comparison of NRC environmental Technical Specifications and NPDES permit requirements is presented in Attachment 2.

The chlorine monitoring program required by Appendix B exceeds that required in the Quad Cities Station NPDES Permit No. IL 005037. The NPDES permit program calls for samples to be collected weekly in the discharge bay during chlorination and tested for Total Residual Chlorine. The current Appendix B program, for which additional samples are collected above, at and downstream of the blowdown diffuser and the diffuser pipes in the river, in the intake forebay, and in the spray canal in addition to sampling for background chlorine. levels when not chlorinating, requires onnually an expenditure of abour $20,000 in addition to that required to conduct

the NPDES permit monitoring. Since the program began in 1974 and extended through 1980, CECO. has spent about $170,000 conducting the additional chlorine sampling.

Total residual chlorine has never been detected either in the Mississippi River upstream of the Quad-Cities Station or downstream of the point of discharge to the river, near the estern shore, 600 feet below the diffuser p.ipe and just below the blowdown pipe, or in the intake forebay since this surveillance began in 1974 (Industrial Bio-Test, 1974, 1975a and b; NALC0 Environmental Sciences, 1976a and b; 1977a and b, 1978a and b, Hazelton Environmental Sciences 1979, Environmental Research and Technology, 1980).

The purpose of the NPDES permit and Appendix B El.1 is to limit the amount of Total Chlorine being discharged to the river. However, the NPDES permit demands that the analyses be performed on a representative sample at the point of discharge to the river, not the dischrge bay as required by Appendix B E.1.1. Measuring Total Chlorine in the discharge bay is not representative of the effluent Total Chlorine accordiag to the NPDES permit.

In conclusion, we believe that it is appropriate to monitor and report chlorine discharge in accordance with NPDES permit requirements.

El.2/2.2 Temperature Limitations The Quad Cities water tempe ature monitoring system has been in operation since 1972, and was installed to assure compliance with Appendix B, Nonradiological Technical Specifications that were formulated from the applicable Illinois and lowa Water Quality Standards relating to water temperature.

Ambient river water and discharge temperatures are monitored using temperature sensors which define the temperature regime upstream anc downstream of the plant. Four temperature sensors are located approximately 60C *eet downstream of the diffuser pipes, one sensce is located in the ischaroe bay, one temperature sensor is located upstream of the intake area to record ambient river temperature. In addition, a sensor is' located on the return side (cold end) of the spray canal. Measurements from the sensors are telemetered into the station control roen and recorded on strip chart recorders.

Location of the sensors are indicated in Figure 1, which has been updated to reflect modifications associated with the spray canal.

The cold end sensor, as ordered by the NPDES, is used for determining the degree the station can use open cycle cooling.

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Commonwealth Edison Company requests that this monitoring be modified and the applicable environmental monitoring protection conditions be changed to those required in the Quad Cities Station NPDES Permit.

The Illinois Water Quality Standards require the f ollowing: (1)

There shall be no aloormal temperature changes that may adversely affect aquatic life unless caused by natural conditions; (2) The normal daily and seasonal temperture fluctuations that existed before the addition of heat due to other than natural causes shall be maintained; (3) The maximum temperature rise above natural temperatures shall not exceed SOF; (4) in addition, the water temperature at representative locations in the river shall not exceed monthly maximum temperatures during more than 1% of the hours in the twelve month period ending in any month. At no time shall the water' temperature at 0

such locat ion s ' exceed the monthly maximum limits by more than 3 F. The monthly maximums are: Jan. 450F, Feb. 450F, Mar. 570F, Apr. 680F, May 78 0 F,. June 850F, Jul.

860F, Aug. 860F, Sept. 850F, Oct. 750F, Nov. 650F, and Dec. 520F (IPCB, March 1977 as amended July 1979). Temperature criteria specified above apply outside a mixing zone of 26 acres (area of a circle .ith a radius of 600 ft.). Since all four sensors are located 600 ft. downstream of the condenser cooling water diffuser pipe discharge and are spaced approximately 400 ft. apart on a line perpendicular to the current flow, to indicate whether a temperature vsolation occurred, all four temperature sensors would have to measure an applicable temperature increase or change.

A search of temperature monitoring data portion of the NRC semi-annual environmental monitoring reports form February, 1976 through July, 1980 showed at no time did all four sensors record excursions at the same time. In the case of the 50F differential temperatm a limit, excursions were never detected at more than one sensor ,er occurrence. Excursions of the 20F/ hour criteria were never detected at more than two sensors at the same time.

Excursions det;cted simultaneously at two sensors occurred on a total of six occasions. It is therefore, apparent that the sensors have never detected a noncompliant situation.

At the time the temperature system was installed in 1972, the design was adequate to comply with the applicable Illinois and water quality criteria. It was believed that this was the best system that would demonstrate thermal compliance based on then known .

information concerning river hydrology and performance of the multiport diffuser system. However, based on later studies conaucted by Parr and Sayre (IIHR, 1977), it can be concluded that the present temperature monitoring system is incapable of determ'ning whether or not the station is in compliance with Illinois and Iowa standards because'of two reasons: (1) the fixed position of the sensors-in the river; and (2) placement of the sensors in the water column.

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It can be concluded from Parr and Sayre's study that the thermal plume is not always a rectangle which would be required for adequate monitoring by the four fixed position sensors. The shape of the plume varies according to changes in river discharge and diffuser pipe discharge. Since the shape of the plume does not always conform to the boundaries set by the sensors, then all four sensort will not always be able to monitor its presence.

Parr and Sayre's study also indicated that highest excess temperatures tend to occur near the water surface except in the winter months when ambient river temperature falls below 39 0F and the highest temperature rises are near the bottom of the river.

Since the thermal plume is typically found near the water surface and sensors in the river are positioned two to four feet above the botton, the sensors often are under the thermal plume. Because of commerical barge traific, it is not possible to position sensors at or near the water surface. Consequently, it is not feasible to develop a continous institu monitoring system that would adequately document river temperature excursions.

The Quad Cities Sta* ion NPDES Permit No.IL0005037 requires only the monitoring of daily average temperatures of the spray canal return prior to mixing with river water, river intake water, combined river and canal streams and seasonal (quarterly) plume measurements of the discharge in the Mississippi River. These quarterly field surveys which are performed by the University of Iowa institute of Hydraulic Research in acccrdance with the NPDES permit, Atacnment G. Paragraph 4b, have indicated no violations of thermal criteria. These field surveys are more accurcte than the temperature monitoring system because the temperatures are measured at various depths in the river during these surveys.

Finally the operation of this system imposes a maintenance burden upon Commonwealth Edison Company. Because of the difficulty in maintaining sensors located in the river off of station property, the system requires full time personnel to calibrate and replace individual sensors and cables on a weekly and sometimes daily basis.

The current Appendix B program which is a requirement in addition to that required to conduct NPDES permit monitoring has resulted in expenditures per year.

which have been significant ranging as high as $100,000 Therefore, we believe that these factors adeque ely justify this request for modification of the present Append x B thermal dischcrge surveillance requirement to that specified by tne NPDES permit.

El.3/2.3 Fish Impingement No change is proposed to teiis section.

E.1.4/2/4 Chemical Effluent The objective of sectin EI.14 of Appendix s is to avoid degradation of the river by int.'. biting the discharge of certain chemic-Is into the circulating water. As of October 1, 1978 all the sources for hose chemicals listed in section E.1.4 were interf aced with the waste water treatment plant where, if they were preseert, they would b r. treated. The NPDES permit has no requirement to measure for or limit usage of these chemicals. However, the NPDES permit requires that the circulating water discharge tothe river meet the requirement of having a pli of 6 to 9 and a Total Dissolved Solids of less than 750 T.3/1 over natural river backgroured. These two parameters would include the effect of the chemicals listed in section E.1.4. The station has shown little effect on the values of effluent stream pH and total dissolved solids. It is requested that the monitoring requirements for chemical effluents be changed to ref lec t the requirements of the NPUES permit.

E3.0 Reporting Requirements The reporting requirements have been reformited for increased clarity, and to highlight the EPA requirement for i 30 day report anytime an Appendix B LC0 is exceeded. The annual reporting requirement remains uncitanged, and the Directorate of Licensing (NRR) is now requ' red to be notified ci any changes in the monitoring requirements in the NPCES permit.

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I ATTACILMENT 2 Comparison of NRC Environnental Technical Specification and NPDES Permit Rer;uirements for Quad Cities Station T r--e ter 1% C ETS - NPDES Permit

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6tonitoring l onitoring Limit Requircraent ilmit Require-ent

.:perature 5'F T nLove anbient; Fo2r temperature sen- 5'F T abcVe aabient; Daily averaga te=per-2*F/hr rate of change sors 600 feet down- water temperature at 4 ture of canal at in-except durin. changes strean of th? diffuser representatives loca- take prior to .ixing in made of c + denser pipes, one sensor in tions in the main with river, cooling, dise'srge bay, two river not to exceed Daily averaga tempo:-

sensors in intake area the naximun limits ature of int ske river to deternine anbient specified by IPCS ustar.

temperaenre (contin- March,1977 as amended Daily avera;e temper-uous recording). July, 1979, nore than ature of ec thined one percent of the river and einal streams hours in the 12 conth period ending vith any Countour of 3'C iso-conth. Water tespers- thern on quarterly ture at these loca- basis downs trew of tions shall not exceed disc'targe at 1.0*C caxinun linits speci- intervals.

fled abote by more than 3*F. Water tanp-eratures and differen-tials specified in Iowa Water quality Standards shall be cat.

?, r.< te te r NRC ETS FTDES Pennit

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Monitoring Monitoring ,

Limit Requireme nt Limit Requirc.m_c nt Chlorine (total) Number of Maximum Av- Four times per nonth 0.2 ppa daily average Diffuser, spray Ope rating erage C12 total chlorinn neas- 0.3 ppm daily maximum canal blowdown dis-Circulat- Conc. (ppm) ured in the discharge chlorine injection cha rge. Once weekly ing 'Jater During bay before and during not to exceed 160 during chierination Pumps Chlorination chlorine cycle; before, ninutes a day. cycle monitoring Prior to at and dernstream of frequency during dis-Discharge the diffuser pipes charge.

to River during the chlorine 2 1.50 cycle when the sta-3 1.00 tion is operating 4 ./5 open or partial 5 .60 closed cycle; before

, 6 y,50 and downstream of spray canal blow-down line during closed cycle opera-tion.

Chemical Effluent 1000 lb/yr. Total amount of No requirement to ceasure or limit usage of nan 02 1000 '5/yr. chenicals used will chemicals. Required to monitor and uaintain a NaS03 pH in the circulating water discharge to the NaOH 1000 ib/yr. be recorded and re-Na3F04 1000 lb/yr. ported in the annual river of 6 to 9 and a Total Dissolved Solids Moropholine 500 od/yr. repo rt. (TLS) concentration of 750 mg/l over natural H3SO4 120,000 gal /yr river background TDS and pH are monitored at a NaOH 120,000 gal /yr frequency of 5 times per week.

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