ML20153B711
| ML20153B711 | |
| Person / Time | |
|---|---|
| Site: | Farley |
| Issue date: | 08/22/1988 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NT-88-0407, NT-88-407, NUDOCS 8808310063 | |
| Download: ML20153B711 (3) | |
Text
m
_NT 88-0407 Alabuna Power Company 600 Nor1h 18th Street Post Office Box 2641 Birmingham, Alabama 35291&OO i/-
Telephone 2052501837 W. G. Hairstort. HI Senior % President Nuclear Cooratims '
AlabamaIbwer the sotthern esectrc system August 22, 1988 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Comission Attention: Document Control Desk' washington, D. C. 20555
Subject:
Joseph M. Farley Nuclear Plant NPDES Permit Gentlemen:
A copy of the attached correspondence is provided in accordance with the Joseph M. Tarley Nuclear Plant Technical Specifications, Appendix B, Section 3.2.
Should you have questions or coments, please advise.
Yours very truly, d.
b W. G. Hairston, III NGWJAM:emb Attachment cc:
Mr. L. B. Long (w/ attachment)
Dr. J. N. Grace (w/ attachment)
Mr. E. A. Reeves (w/ attachment)
Mr. G. F. Maxwell (w/ attachment) l l
8808310063 880822 "
DR ADOCK O 3 B' I
i
p
.o
, Alibema Powtr Company
'e' 600 North 18th strnt Post Offcs Box 2641 Birmingham. At bams 35291 Telephone 2o5 2501000
~
L Alabama Power v.. mn,-,,wm August 15, 1988 Farley Nuclear Plant NPDES Permit No. AL0024619 Mr. James M. Moore, III Alabama Department of r
Environmental Management 1751 Federal Drive Montgomery, AL 36130
Dear Mr. Moore:
As discussed with Mr. Mike Godfrey of this office, we are forwarding information supporting two requests associated with the approved service water chlorination program for the above referenced facility.
Both reqbests involve discharges which occur from the cooling of chlorine d(DSN005 - DSN008).
The first request concerns the time tower system ischarge associated with cooling tower blowdown. A continuous corrosion control program, approved by ADEM, has been utilized for several years for both units' cooling tower systems.
The l
programs typically require a blowdown of one to three hours daily, however a blowdown of five hours is necessary on occasion.
Typically blowdown is held until chlorine is less than detectable and l
only then,is it released to the environment.
When a unit is being treated for Corbicula control (continuous chlorination of the service l
water system) the blowdown even if held as normally occurs, may continue to contain a small amount of chlorine resulting from the Corbicula control program, since chlorinated service water is used for cooling tower make-up.
In 40 CFR 423.13 i
l permittingauthoritymayapproveaddition[d?[2]itstatestheNPDES a
time of chlorinated l
cooling tower blowdown discharge if the permittee demonstrates they l
cannot operate at the two hour level. As such, we are requesting the L
two hour time limit be waived based on the situation which occurs at l
the above referenced facility and the insignificent effect which such i
j a change would have on the environment.
The second request concerns when monitoring should occur for i
the cooling tower blowdown. We are requesting the monitoring of cooling tower blowdown be performed in such a manner as to represent the overall "chlorination" which occurs when the Corbicula control program is being performed.
The t described in the above paragraph. ypical release of blowdown was During the Corbicula control I
program the cooling tower system becomes a side stream to the service water system since the chlorine monitoring point is located at the l
Mr. James H. Moore, !!!
Page 2 August 15, 1988 river dischar Thus, even though "normal cooling tower chlorinattoa"ge.may not occur, the possibility exists for detectable amounts of chlorine to be present from the Corbicula control program continuous chlorination of the service water system.
This could be nterpreted to require us to sample blowdown every t irty minutes due to the addition of chlorinated water from the service water system.
Further, this implies that if the chlorinated service water systems effluent goes directly to the river, one set of monitoring conditions exist, but if a portion of this water is diverted through the cooling tower system monitoring must be performed every thirty minutes.
Should chlorinated service water pass through the cooling tower system, the total amount of chlorinated water would not be affected since the 0.2 ppm limit at the river is the controlling factor. As a while moving through the cooling tower system there is matter of fact,he actual concentratica uf chlorine could decreas a possibility t but in no case would either the concentration or total amount of chlor n increase at the river discharge point.
1 We therefore request chlorine monitoring of the cooling tower blowdown be waived durin periods when the service water system is being chlorinated for Co bicula control and that this waiver be 4
incorporated as a part of the requirements for the Corbicula control program. We understand should chlorine be introduced into the cooling tower system, except as a result of the service water chlorination regram, this waiver would not be applicable.
We feel this request is ustified, based on the fact that the total amount of chlorine released to the environment will not increase and that the requested changes in chlorine monitoring will continue to provide protection for i
the environment, i
Should you have any questions, please contact Mr. Godfrey at 1
Sincerely, 4
i Af" John D. Grogan, Hhnager Environmental Compliance JMG:dy t
i 1
I
.