ML20151W324

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Annual Environ Protection Plan Operating Rept,1987
ML20151W324
Person / Time
Site: Millstone Dominion icon.png
Issue date: 12/31/1987
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NORTHEAST UTILITIES
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NUDOCS 8805030360
Download: ML20151W324 (8)


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Annual Environmental Protection Plan Operating Report January 1 - December 31,1987 Millstone Unit 3 Environmental Protection Plan I

prepared by Northeast Utilitics Service Company P.O. Box 270 Hartford, Connecticut 06141-0270 April 1988

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Annual Environmental Protection Plan Operating Report - 1987  !

1. Introduction This report covers the period January 1 - December 31, 1987. During 1987, Unit 3 vas shut down from mid-March to mid-April, for maintenance and snubber inspection, and a refueling outage began on October 31 (completed l in February 1988). Except for occasional down-powers, Unit 3 vas at j nominal full power for the rest of 1987, operating at an annual capv-fty factor of 67.3% (the overall first-cycle capacity factor was 82%).

As required by Hillstone Unit 3 EPP, this Annual Environmental Protection Plan Operating Report (AEPPOR) includes:

1) summaries and analyses of the results of environmental protection activities, 1
2) a list of EPP noncompliance:., I l 3) a list of all changes in station de:;ign or operation which involved l I

a potentially significant unreviewed environmental question, and l

4) a list of non-routine reports, describing events that could result l l in significant environmental impact.
2. Environmental Protection Activities i

2.1 Annual NPDES Report of Ecological Monitoring (EPP Section 4.2)

Paragraph 5 of the referenced NPDES permit requires continuation (

of biological studies of HNPS supplying and receiving waters, l entrainment studies, and intake impingement monitoring. These i studies include analyses of intertidal and subtidal benthic l communities, finfish communities, entrained plankton, lobster I populations, and vinter flounder populations. Paragraph 13 of the permit requires an annual report of these studies to the Commissioner of Environmental Protection. The report that fulfills these requirenients for 1987, Monitoring the Marine Environment of Long Islarj Sound at Millstone Nuclear Power Station, Vaterford, Conn' cticut - Annual Report, 1987, presents results from studies performed during 3-unit operation, and compares them to those f rom 2-unit operation. The added cooling water flov for Unit 3 arfects impingement and entrainment, causes sediment scouring near the MNPS discharges, and alters the characteristics of the thermal ef fluent plu.ne. The biological effects of these changes are discussed in the above-named report (Attachment 1).

2.2 Effluent Vater Quality Monitoring Paragraph 6 of the referenced NPDES permit requires monitoring and recording of many water quality parameters at HNPS intakes and at 37 discharge points within the plant, including outfalls of each unit to the effluent quarry, and outfall of the quarry to Long

Island Sound. Paragraph 11 of the permit requires a monthly report of this monitoring to the Commissioner of Environmental Protection. The report that fulfills these requirements, Monthly Discharge Monitoring Report, includes data from all three Hillstone units. Those data that pertain to Unit 3 are summarized in Table 1. The only exception to NPDES permit limits was an oil and grease sample, collected from Discharge Serial No. 006 (combined Unit 2 and Unit 3 non-contaminated floor drains) in January 1987. The reported oil and grease concentration of 20.1 mg/l exceeded the permitted maximum of 20.0 mg/1. This incident vill be discussed in further detail in Section 5, Non-Routine Reports.

Sampling for hydrazine (N 9H3), biological oxygen demand (BOD), and chemical oxygen demand (COD) is required only when discharging vastevater containing hydrazine; these discharges are summarized in Table 2. The major hydrazine discharges at Unit 3 are releases following vet lay-up of steam generators; these occurred in April and November 1987. Some of the values for hydrazine concentration exceeded the administrative target of 125 mg/1, but all vere below the NPDES permit level of 200 mg/l. The tests for BOD and C0D are unreliable in seavater and it is felt that the reported values for these parameters are not representative of MNPS effluent water quality. NU is investigating the possibility of requesting that CT-DEP eliminate the NPDES monitoring requirements for BOD and C0D at HNPS discharges.

3. Environmental Protection Plan Noncompliances During 1987, no EPP noncompliances were identified for Unit 3. Northeast Utilities has established an Environmental Reviev Board (ERB), to provide an independent nonrad'ological environmental review of corporate nuclear activities. The ERB responsibilities include an annual audit to assure compliance with the EPP; the reporting deadline for this audit is May 31.

If the ERB determines that an audit item constitutes a noncompliance, a supplement to this Annual Environmental Protection Plan Operating Report vill be submitted, with a format similar to that of the August 11, 1987 letter, from NNECo to NRC, Supplement to 1986 Annual Environmental Operating Report for Hillstone Nuclear Power Station, Unit No. 3. - This l letter identifies the failure of NNECo to inform NRC vithin 30 days of the approval for NPDES permit modifications, granted on September 19, 1986, as a 1986 EPP noncompliance. To ensure that similar errors vill not occur in the future, procedural changes have been implemented so that copies of all l NPDES modification correspondence are sent directly to NRC.

4. Environmentally Signif! cant Changes to Station Design or Operation During 1987, no Unit 3 Plant Design Change Records (PDCRs) met the acceptance criteria for inclusion in this report, i.e., required an environmental reviev and received Plant Operation Review Committee (PORC) approval for implementation in 1987. Of the 68 PDCRs initiated during 1987, 37 received PORC approval; none of these involved unreviewed environmental issues. An additional 53 PDCRs, that had been initiated in past years, received PORC approval in 1987; none of these involved

unreviewed environmental issues, either.

Unit 3 has 166 General Operating or System Operating Procedures; of these, 70 were added or revised during 1987. Only 1 required an environmental review OP 3328B, Chlorination of Circulating Vater System. This procedure deals with the injecticn of sodium hypochlorite solution into the circulating vater bays to control microfouling of the condensers; the environmental review and environmental evaluation are attached (Attachment 2). Since the possible need for chlorination was anticipated in the Unit 3 Environmental Report, and provisions to allov it vere incorporated into the NPDES permit, it was determined that no unreviewed environmental impact occurred.

5. Non-Routine Reports of Environmentally Significant Events During 1987, no events occurred at Unit 3 that met the acceptance criteria for inclusion in this report, i.e., required submittal of a Licensee Event Report (LER) from Unit 3, and involved a situation that could result in a significant environmental impact. Of the 51 events that constituted reportable occurrences, none vere determined to cause a significant environmental impact. The annual ERB audit vill also include review of LERs; if the ERB determines that an utreviewed impact did occur, a supplement to this Annual Environmental Protection Plan Operating Report vill be submitted, along with an assessment of the impact.

Although not of sufficient magnitude to require issuance of an LER, two environmentally related incidents occurred during 1987. On January 22, an oil film was noticed near the Unit 3 intakes, and traced to vater in the vest condenser pit that was pumped ont through an oil-vater separator at a rate which caused carry-over through the separator. On September 30, a similar sheen was traced to oil found in the Unit 3 turbine building sump.

In both cases, the U.S. Coast Guard was notified, as per 10 CPR 50.72 (b)(2)(vi), and on-site materials vere used to contain and absorb the )

j spills. No adverse environmental impact occurred.

Table 1. Stillstone IJnit 3 NPDl!S Data Summary, Jan. I - Dec. 31, 1987'.

discharge discharge discharge discharge avg mat mat settle, flo$ range p!Irange temp. range temp. (avg) Ap FAC TRC sohds

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(10 gpm) (*F) (* F) (* F) (rpm) (ppm) (mg/1) <

J an. 790 942 7.67.9 41.0-65.7 58.8 18.0 <0.05 < 0.05 < 0.05 Feb. 790-948 7.2 -8.0 51.4 57.9 54.8 18.0 <0.05 <0.05 < 0.05 M ar. 21 942 6.9-8.1 37. A.59.9 45.8 6.8 <0.05 <0.05 < 0.05  !

A pr.30-942 6.98.0 41.2-69.4 55.3 11.4 <0.05 <0.05 < 0.05 May 486-942 7.88.0 47.1-75.7 66 0 15.1 0.07 <0.05 < 0.05 June 638 912 7.77.9 55.8 82.0 72.3 13.5 <0.05 0.08 < 0.05 July 790-942 7.6-7.9 77.7 87.4 82.6 17.9 0.10 0.10 < 0.05 A ug. 790-9.t A 7.38.2 82.0-89.6 85.1 17.7 0.0A <0.05 <0.05 Sep. 790 9it 7.7-7.9 65.5-87.1 82.4 16.7 <0.05 0.08 < 0.05 Oct. 790.942 7.7-7.9 55.9 82.6 76.4 16.7 0.10 < 0.05 <0.05 N ov. 15 790 7.47.8 44.2 5A.5 51.7 0.0 <0.05 <0.05 <0.05 Dec. 182-638 7.77.8 33.849.6 44.6 0.0 <0.05 <0.05 <0.05

w. s p. 2 2 2 b" "' A No. of pil 8m FAC TRC bl. M. Retf t rim hylrartar eM ce=4ert. hewas r'e s**

!!"'T . . . . . . T . . . . . ,

1 Parameters are measured at iJnit 3 discharge, except for TRC and setticable solids, which are measured at MNPS discharge (quarry cuts). I 1

Sampling for 110D, COD, and hydrazine required only when discharging wastewater containing hydrazine; data for these events are presented in Table 2.

~1 Some parameters are measured at more than one point within (1 nit 3 or only under certain operating conditions. Values represent number of NPDl!S cxceptions for all discharge points.

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Table 2. Summary of hydrazine discharges from Unit 3 steam generators, Jan.1 Dec. 31,1987.

Date Sample pt. N2 il4 IlOD COD (all mg/l) 15 Star 87 S/G #2 49.0 4.5 5.0 15 Mar 87 S/G #3 45.0 7.5 10.0 1 Apr 87 S/G #1 62.5 10.8 34.0 i Apr 87 S/G #2 161.5 15.6 104.0 2 Apr 87 S/G #3 167.0 15.6 121.0 2 Nov 87 S/G #1 137.0 132.0 165.0 2 Nov 87 S/G #4 144.0 126.0 97.1 2 Nov 87 S/G #2 149.0 150.0 77.7 1 3 Nov 87 S/G #3 163.0 132.0 < 20.0 l

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Attachment 2 1 I

Environmental Reviev 1

OP 3328B j OP 3328B adds a 12.5% sodium hypochlorite (Na0Cl) solution at the suction l side of each circulating vater pump, one at a time, at a flow rate not to exceed 2.6 gpm. The solution vill be added at each pump by lifting the deck plate located immediately at the suction side of the pumps and inserting a hose just below the water surface in the intake bay to be treated.

The expected result of the circulating vater system (CVS) sodium hypochlorite treatment is that microfouling of the condenser tubes vill be reduced. As a result of this tube cleaning process, an improvement in heat transfer capability of the condenser should be observed. The improved heat transfer capability would result in increases in both discharge temperature and temperature difference between intake and discharge. However, the increases only would be to the point of restoring the parameters closer to the original design values. Therefore, the effect on temperatures resulting from the performance of this OP vill not ,

change the water temperatures as regulated by the NPDES permit. Chlorine  !

discharges from Hillstone are regulated by the station NPDES permit and EPA guidelines (40 CFR 423.13). The NPDES permit limits Unit 3 to a maximum daily concentration of 0.25 ppm free available chlorine (FAC) in the circulating vater discharge and the combined effluent from the station cannot exceed 0.10 ppm total residual chlorine (TRC) at the quarry cut.

The federal guidelines prohibit discharge of residual chlorine for more ,

than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per unit per day unless a longer discharge period is demonstrated to be needed for macroinvertebrate (e.g., mussel) control. .

I The latter provision allows continuous chlorination of the service water system but does not allow it for the circulating water system. f To ensure that discharge concentrations are below permit limits, the procedure limits the sodium hypochlorite injection rate to the calculated j flow rate (2.6 gpm) to achieve an input concentration of 1.5 ppm FAC in the bay being treated (Reference memo dated August 6, 1987, from J.

Foertch to S. Scace, J. Stetz, J. Keenan and C. Clement). By specifying that only one intake bay at a time may be treated and all 6 circulating vater pumps must be operating, the dilution factor alone from the other 5 bays vill reduce the FAC level to 0.25 ppm. The calculation is conservative in that it assumed no chlorine demand and no formation of combined residual chlorine. Further, the OP specifies that chlorine cannot be discharged from the circulating water system for greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in an 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period to ensure the 40 CFR limit is not exceeded.

As additional assurance that the NPDES limits vill not be exceeded, the results of IST 3-87-018 vere reviewed. This IST injected sodium hypochlorite into the circulating vater system at various controlled flow rates while monitoring FAC and TRC concentrations at the Unit 3 discharge and at the quarry cut to Long Island Sound. The results of the IST verify

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l that a flow rate not to exceed 2.6 gpm vill ensure that FAC and TRC concentrations vill remain below the NPDES permit limits.

Based on the preceding discussion, this procedure vill not affect the thermal component of the plant discharge or the rate or quantity of radioactive or hazardous materials discharged beyond the limits specified by the NPDES permit. Further, this procedure has no effect on the emissions of air pollutants regulated by the Department of Environmental Protect'in. Therefore, the implementation of OP 3328B vill not constitute an adverse environmental impact.

ENVIR O N M E NT AL EVALU ATIO N SU M M AR Y (Reference N E O 514)

Y es No

/ 1. Vill this change affect the water quality characteristics regulated by the N P D ES permit.

/ 2. Will new discharges regulated by the NP D ES permi neroduced by this change.

[ 3 Will this change introduce a new source or change in the amount or type of fossil fuel burned which would result in a variation of emission of air pollutants under the Regulations of the Connecticut Department of Environmental Protection.

[ 4. Will this change cause other adverse environmental Impact not currently regulated by NP D ES or air pollution regulation (i.e.,

intake water velocity, wildlife habitat, disruption by construction, e t c.)

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