ML20049J528

Advises That Util Will Propose Sys of Continuous Low Level Chlorination at Cooling Water Intake Structures to Replace Thermal back-flushing Operation for Control of Biofouling. Change Description to Appear in May 1982 Draft EIS

ML20049J528
Person / Time
Site:	Seabrook
Issue date:	03/09/1982
From:	Moebes J ENVIRONMENTAL PROTECTION AGENCY
To:	Backus R BACKUS, MEYER & SOLOMON
References
NUDOCS 8203180310
Download: ML20049J528 (3)

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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REGION I J. F. KENNEDY FEDERAL BUILDING. BOSTON, MASSACHUSETTS 02203 a) l&

March 9, 1982 g

Mr. Robert A. Backus, Esquire F1ECE?"M 116 Lowell Street E

MAR IT NO2*" N P. O. Box 516 9 ngg Mancheste r, NH 03105 mc

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NPDES Permit No. NH0020338 (Cj Public Service Co. of NH, Seabrook Station

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Dear Mr. Backus:

This is in response to your letter to Mr. Robert Leger of this office concerning the chlorination of the cooling water at the point of intake at Seabrook Station.

Originally in the NPDES Permit Application of August 1, 1974, the Company had proposed controlling the biological growth in the intake tunnel through the process of a thermal back-flushing operation and controlling the biological growth in the condensers through the use of shock doses of a sodium hypochlorite solution.

The condensers and service water system were to be chlorinated one at a time for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day for each unit, with a free available chlorine concentration not to exceed 0.2 mg/l as an average or 0.5 mg/l as a maximum at the discharge point of each unit.

The original New Hampshire Water Supply and Pollution Control Commission Final Permit, dated January 23, 1974, states that "the effluent shall contain no more than one-tenth (0.1) mg/l of total residual chlorine".

In our verbal discussions with the Company personnel, they have indicated that they will propose a system of continuous low level chlorination at the cooling water intake structures to control bio-fouling throughout the intake tunnel up to the pump bay and that the condensers and service water system will be chlorinated as previously proposed.

The continuous chlorination would replace the thermal back-flushing operation.

l The Nuclear Regulatory Commission (NRC) has requested the Company, as you know, to describe this proposed change in operational g o ;L procedure with a justification for the change and the expected g

environmental impact of the change.

This description will appear in the Draft Operational Enivronmental Impact Statement which is j c) expected to be issued by NRC in early May 1982.

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Concurrently with the NRC request, EPA has requested that the Company formally amend its NPDES Permit Application to include this new procedure with the justification and environmental impact description presented to NRC.

Upon receipt of this information, EPA will review it and determine if the change satisfies the State 's Water Quality requirements and the new soarce performance standards for the Steam Electric Power Generating Point Source Category (40 C.F.R.

Part 423, as proposed at 45 Fed. Re g. 68328 et seg. on October 14, 1980).

At a minimum, EPA would require tee Company to provide a Chlorine Minimization Program for the entire station's usage of chlorine in accordance with Appendix I of the proposed guidelines in order to reduce the amount of chlorine compounds discharged to the receiving waters.

For Seabrook Station, the Chlorine Minimization Program would have to be submitted and approved in a timely manner so that it could be implemented on the day that chlorine will first be required for bio-fouling protection.

If the proposed chlorination process is found to be acceptable, the existing NPDES permit will be modified to incorporate the I

The change with the required effluent discharge limitations.

proposed change will also be included in the preliminary draft operational UPDC5: permit that will appear in the Draft Operational Environmental Impact Statement from NRC.

In both the permit modification and the issuance of the operational permit, there will be full opportunity for public participation in commenting upon the proposed chlorination process change in accordance with l

l the established public notice and public hearing procedures set forth in 40 C.F.R.

Part 124.

Should you have any questions, please contact Ted Landry, of my l

staff, at 617/223-5033.

Sincerely yours,

/T ohn R.

Moebv_s, Chief Permits Branch cc:

PS Co. of NH, Attn:

Mr. Bruce Beckley NHWS & PCC, Attn:

Mr. Russell Nylander NRC:

Attn:

Mr. Duke Wheeler

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January 27, 1982

' 7, JAN 2 61982 Mr. Robert Leger Environmental Protection Agency Region I, Permits Branch John F. Kennedy Federal Building Boston, MA 02203 RE:

Seabrook

Dear Bob:

I have just learned, via a memorandum of a site visit by the NRC Staff conducted at the Seabrook site on December 1st and 2nd, that Public Service Company is thinking of abandoning the proposed back-flushing to control bio-fouling of the condenser cooling system and going instead to the injection of chlorine at the point of intake.

As you may not know, Public Service testified under

' oath before the New IIampshire Site Evaluation Committee that no chlorine would be used for condenser cooling, because they had chosen to heat kill fouling organisms.

l By the time NIIWSPCC issued its permit, the limit was set at 1 milligram per liter.

I would like to know if your agency has had any ccmmunication from Public Service about this proposed change, and if so what proceedings will be instituted to determine the environmental impact of using chlorine for l

condenser cooling.

Best regards,

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obert A. Backus RAB/sid i

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