ML20215M414

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Forwards Requests for Mods to NPDES Permit IL0048313, Allowing Use of zinc-based Anticorrodant & Addition of Sodium Bromide for Biofouling Control in Facility Circulating Water Sys
ML20215M414
Person / Time
Site: Byron  Constellation icon.png
Issue date: 05/07/1987
From: Ainger K
COMMONWEALTH EDISON CO.
To: Davis A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
3056K, NUDOCS 8705130225
Download: ML20215M414 (3)


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s May 7, 1987 (1L Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Byron Station Units 1 and 2 NPDES Permit NRC Docket Nos. 50-454 and 50-455

Dear Mr. Davis:

Commonwealth Edison is the holder of National Pollutant Discharge Elimination System (NPDES) Permit No. ILOO48313 for Byron Station. The enclosed letter requests modifications to the aforementioned permit and is being submitted to you in accordance with Section 3.2 of Appendix B of Facility Operating Licenses NPF-37 and NPF-66.

Please direct any questions regarding this matter to this office.

Very truly yours, K. A. Ainger Nuclear Licensing Administrator Enclosure es

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' Cheago,Imnoes 60690 0767 April 7, 1987 CERTIFIED MRIL Mr. Thomas G. McSwiggin, P.E.

Manager, Permit Section-Illinois Environmental Protection Agency 2200 Churchill Road Springfield, IL 62'106

Subject:

Proposed Modification of NPDES Permit No. IL0048313 Byron Station

Dear Mr. McSwiggin:

Commonwealth Edison. requests that the subject permit be modified to allow the use of a zinc-based anticorrodant and the addition of sodium L-bromide for biofouling control in the station's circulating water system.

We also request that Special Condition 3, regarding chlorination duration, be reworded to make it less ambiguous and more reflective of the intent of the Steam Electric Guidelines.

We are currently testing the use of a zine polymer on the Essential service water System. Should the polymer prove effective in reducing corrosion rates, we wish to' expand its use to the entire circulating water system. The polymer in question contains 5% zine and is projected to be fed initially to tihe circulating water system at 'l parts per million. This feed rate will be adjusted inversely with cycles of concentration to maintain an average zinc concentration of 0.*l5 - 0.90 mg/l in the cooling water.

The station has experienced problems with biofouling, both in the main condensers and in the cooling tower system. -we wish to modify the permit to allow the use of sodium bromide to augment the sodium hypochlorite. Such a modification would allow us to increase the effectiveness of our biofouling control system while at the same time significantly reducing the amount of chemicals needed to be added to control fouling. While feed rates have yet to be determined, our guiding principle in setting them will be to remain in compliance with the permitted limits of 0.2 mg/l average and 0.5 mg/l maximum set for free available halogen measured as free available chlorine.

Finally, the first sentence of Special Condition 3 states:

"Neither free available chlorine nor total residual chlorine may be discharged from any unit for more than two hours in any one day and not more than one unit'in any plant may discharge free available or total residual

, a chlorine at any one time." This sentence was intended to limit chlorine application to two hours per unit per day and to prohibit multi-unit simultaneous chlorination. However, while meeting this criteria, we have been able to measure total residual chlorine in the tower basin up to four hours after discontinuing chlorination. This water containing total residual chlorine is circulated through the plant and discharged from the unit, thus leaving us in technical violation of the permit even though we are meeting the intent of the condition and have no control over this phenomenon.

We, therefore, request that this sentence be changed to reflect its original intent and to prevent the possibility of these technical violations.

If you have any questions concerning this letter, please feel free to contact Mr. Gerald Erjavec of my staff at 312/294-4452.

Sincerely yours, 1

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Thomas E. Hemminger Director of Water Quality 1421e GME:TEH:pp bec R. E. Querio P. F. Floeter Nuclear Licensing Administration File: 06-PER-H4 b