ML20215M584

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Forwards Proposed Changes to Plant NPDES Permit,Per Section 3.2 of App B to License DPR-20.Change Will Reduce Cooling Water Temp to Condenser,Resulting in Greater Turbine Generator Efficiency
ML20215M584
Person / Time
Site: Palisades 
Issue date: 10/21/1986
From: Johnson B
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8611030040
Download: ML20215M584 (13)


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Smar5 PRAERE55 No General offices: 1946 West Parnell Road, Jackson, MI 49201 * (517) 788-0550 FILE A October 21, 1986 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

PROPOSED NPDES PERffIT CHANGES INFORMATION SUBMITTAL In accordance with Section 3.2 of Appendix B to Provisional Operating License No. DPR-20, Docket 50-255 for the Palisades Plant, a copy of the proposed changes to the Palisades Plant NPDES Permit is submitted by way of attachment to this letter.

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Brian D Johnson Staff Licensing Engineer CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection & Enforcement NRC Resident Inspector - Palisades Attachment P

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ATTACHMENT

. Consumers Power Company l

Palisades Plant Docket 50-255 i

PROPOSED NPDES PERMIT CHANGES October 21, 1986 e

II Pages IC1086-0171-NLO2

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Consumers Power powrams MKMGAW5 Mt0GREKE General offices: 212 West Michigan Avenue, Jackson, MI 49201 *(517) 788-055o October 20, 1986 21EP10.1 DCC-950-70*20kO2*03 Mr William McCracken Michigan Department of Natural Resources PO Box 30028 Lansing, MI 48909 Dear Mr McCracken The Company plans to modify the operating mode of the existing condenser cooling water system at the Palisades Plant to achieve increased electrical output. Modified operations are currently scheduled to commence January 1, 1987.

The Company, therefore, requests that the Plant's NPDES Permit be modified to reflect this changed mode of operation.

This information is submitted pursuant to Section 8(b) of the Michigan Water Resources Act and Part II(A)(2) of the Palisades Plant NPDES Permit, which requires notice to the permit issuer of facility expansions, production increases, and process modifications which will result in new, different or increased discharges of pollutants.

Enclosed is a detailed description of the modification of the operation of the cooling water system. The change in operations will reduce cooling water temperature to the condenser, thus resulting in greater turbine generator efficiency.

Electrical output from the plant is estimated to be increased by 2,000 kW with an attendant estimated annual savings of $300,000.

Plant operations following the modification will result in an increased heat load discharged to the lake.

Total water use and discharge, however, will remain the same.

Only some internal waste stream flows will change.

Although the modification in operations will shift a small portion of the heat normally dissipated through the cooling towers to the lake, preliminary assessments indicate that compliance with State water quality standards and the thermal mixing zone limitations stipulated in the existing plant NPDES Permit will be maintained.

In order to support the scheduled January 1, 1987 change in plant operations, Staff concurrence is requested by November 15, 1986.

With Staff concurrence by this date, the Company would request an expedited permit revision process to accommodate the scheduled January 1, 1987 changeover in operations.

OC0986-35RLF-EN03

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If there are any questions concerning this matter, please let me know.

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Yours very truly i

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[c, Ronald L. Fobes Senior Environmental Advisor 1

CC: FMorley, MDNR-Pla!.nwell i

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'e CONSUMERS POWER COMPANY PALISADES PLANT PROPOSED OPERATIONS MODIFICATION CONDENSER COOLING WATER SYSTEM OCTOBER 1986 Present operation of the condenser cooling water system is depicted in Figure 1.

The cooling system is operated essentially as a closed loop with a blowdown (50,000 gpm) for dissolved solids control and makeup from the house service water and cooling water intake systems.

As depicted, the dilution water pumps-introduce 50,000 gpm of cold Lake Michigan water into the condenser cooling water system via the tower fill line. An identical amount of water is blown down from the cold side of the cooling tower via the blowdown line.

This cooling tower blowdown is routed to the mixing basin for discharge to the lake via four discharge pipes. The number of discharge pipes was previously reduced from eight to four to in-crease discharge jet velocity to enhance the thermal mixing dynamics (Figure 3).

Under the proposed modification in operations (Figure 2), a three percent increase in blowdown flow to the lake would occur due to increased overflow (3,100 to 49,700 gpm) out of the cooling tower makeup basins, ie from the warmer side of the closed cycle cooling system. Concurrent with the increased flow out of the makeup basins, the existing blowdown line would be throttled back to approximately 5,000 gpm.

By blowing down through the cooling tower makeup basin overflow, the temperature of the water returning to the plant's condenser can be lowered approximately 1*F.

This temperature depression, in turn, reduces turbine exhaust pressure allowing the turbine to operate more efficiently, thus increasing plant electrical output by 2,000 kW.

Water from the house service water system would still be used to makeup evaporation losses from the cooling towers.

Tota?. discharge flow to the lake will remain essentially the same and withdrawal from the lake would also remain the same.

Specifically, the Company is requesting MDNR approval for the flexibility to operate the plant's closed cycle cooling system in either the existing mode (majority of the blowdown from the cooling system to the mixing basin via the existing blowdown line as in Figure 1) or in the proposed mode where the majority of the blowdown is routed to the mixing basin through the cooling tower makeup basin overflow as in Figure 2.

In either case, the amount of blowdown is essentially the same; only the route of discharge to the mixing basin is changed.

The estimatgd average increase in heat released to the lake on a monthly basis is 143 x 10 Btu /hr, or an 11% increase over the currently permitted 1300 x 6

10 Btu /hr (Table 1).

On an average basis, three months of the year (August, October and November) would not be expected to be greater than the currently permitted value. On a monthly basis, the mean of the estimated maximum 6

increase in heat released to the lake is 279 x 10 Btu /hr, or a 22% increase MIO886-08RLF-EN03

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over that~ currently permitted (Table 1).

The maximum heat addition expected during any month would occur during6the month of March with an estimated increased heat addition of 604 x 10 Ctu/hr, or a 46% increase over that currently permitted. Even under expected maximum heat additions, the heat discharged to the lake would still not be expected to be greater than that currently permitted for the months of October and November.

Based on the flow balance of cooling water to and from the cooling towers as depicted in Figures 1 and 2, the increased heat released to the lake would reduce by about 14% the heat normally rejected to the atmosphere by the cooling towers.

Under the changed mode of cooling system operation, compliance with the plant's NPDES Permit requirement of the 3 F - 72 acre thermal mixing zone criteria (as measured at the 1 M depth) will be maintained based on prelimi-nary calculations (Table 2).

The expected maximum thermal plume size of approximately four acres is well within the 72 acres allowed L/ the permit and represents only about 6% of the thermal mixing zone permitted. During 1981, spring and summer thermal plume surveys were conducted under near maximum Plant operation. The resulting thermal plumes at the 3*F above ambient isotherm as measured at a 1 M depth ranged in size from 0.3 to 2.7 acres. The final report of these surveys was submitted to the Executive Secretary of the MWRC, Mr Robert Courchaine, on January 25, 1982. Table 2 presents the areas of the 3*F plume which would be expected under the average and maximum heat additions resulting from the proposed changes in operation of the cooling water system. The average and maximum percent increase in expected heat releases to the lake (Table 1) were used to calculate the expected plume size from the plumes surveyed in 1981. As indicated in Table 2, under the proposed mode of operation, the 3*F plume size would be expected 'to range from 0.3 to 3.9 acres in size, well within the 72 acre limit authorized under the plant's NPDES permit.

Accordingly, if necessary, the Company requests that the Plant's NPDES permit be revised to address the increased flexibility in operations. Specifically, we recommend that Page 2 of 9 of the permit be revised as follows:

1) the authorized maximum discharge flows for internal outfalls 00A, 00B and 00C should be revised to reflect operations under either algernate flowpgth, 2) the heat discharge rate should be revised from 1.3 x 10 to 2.1 x 10 Btu /hr.

These suggested changes are shown in Exhibit A, a marked up copy of Page 2 of 9 of the permit. The individual monitoring requirements for internal outfalls 00A, 00B and 00C (page 4 of 9 of the permit) would remain the same. All other permit language would also remain the same.

In summary, several benefits will result from increasing the flexibility in operating the plant's closed cycle condenser cooling water system. First, the proposed changes will result in a 2,000 kW increase in electrical output or an additional annual output of 12,200,000 kWh. This will result in an annual savings of $300,000 to our customers based on normal plant availability and normal weather conditions.

The additional heat rejected to the lake will still result in a minimal (0.3 to 3.9 acre) 3*F T thermal plume at the 1 meter depth which is less than 6% of the 72 acres authorized by the Michigan water quality standards and in the plant's NPDES permit.

The increased flexibility of being able to utilize either of the two cooling water blowdown MIO886-08RLF-EN03

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5 modes will allow the plant to effectively manage any system imbalances or upsets which may occur during plant transients of start-up or shutdown.

RLFobes/10-20-86 MIO886-08RLF-EN03

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l TAA!21 Cha@ARISON CT OJRRrNTt? PERPt1TTED AND PROPOSED IEAT REllASES T91AKE MICHICAN Paltsades Plant. Covert, Michigan Estlasted Necesaary Estimated hecessary Estimated Average Increase in Permittew Estimated Mulass increase in Permitted liest Release Rates lleat ketease Rate Meet Release Rate Heat Release Rate Currently Permitted utth Proposed Under Average Percent of Currently utt% Proposed Under Maalaus Percent of Qarrent".)

Mastm a Hegt Release Rate operatignal Qianges Operating Conditisms Pers:tted Mestane Operettgnal Changes Operattgg Conditions Pera:tted N utate Nath (10 Bte/Mr)

(10 Ben /Mr)

(10 Bru/Mr) heat Releasa Rate (IC Stu/Mr)

(10 Stu/Hr)

Heat delease hte January 1300 1545 245 119 16a.2 382 129 February 1300 1742 M2 134 1879 579 145 March 1300 1767 47 136 1904 6M 146 April 1300 1701 401 131 1838 538 la?

Ny 1300 1575 275 121 1712 412 132 June 1300 1433 133 110 1570 270 121 July 1300 1444 144 111 1581 281 122 August 1300 1228

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94 1365 65 105 September IJ00 1316 16 101 1452 152 112 October 1300 1000 (220)*

83 1217 (83)*

94 November 1300 1127 (173)*

87 1264 (36)*

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g Mean of Estimated Heat Release Rate Mean of Estimated Heat Release Rate lacreases Under Average Conditions 142 111 Increases bader Maataan Canditions 279 122

  • ( ) Value be1<w currently peraatted maatam heat release rate.

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TABLE 2 EXPECTED THERMAL PLUME SIZES AT THE 1 METER DEPTH Palisades Plant, Covert, Michigan Greatest Estimated Greatest Estimated Average Heat Maximum Heat Release R2te Release Rate I

2 3* FAT Increase - 136%

Increase - 146%

Date (Acrea)

(Acres)

(Acres) 4-30-81 2.7 3.7 3.9 6-01-81 1.2 1.6 1.8 8-18-81 0.5 0.7 0.7 8-19-81 0.3 0.4 0.4 NOTE:

3* FAT thermal plume authorized under the plant's NPDES permit is 72 acres.

1 From Table 1 for the month of March, the 136% represents the greatest estimated percentage of the currently permitted maximum heat release rate under estimated average heat release conditions.

2 From Table 1 for the month of March, the 146% represent the greatest estimated percentage of the currently permitted maximum heat release rate under estimated maximum heat release conditions.

R L Fobes 10/86 MIO986-34RLF-ENr;

EXHIBI T-A Pemit No. MI 0001457 Page 2 of 9

PART I

^ }. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

'1.

Final Effluent Limitations - Outfall 001 (mixing basin discharge)

During the period beginning on the effective date of this permit and lasting until the expiration of this permit, the permittee is authorized to discharge a maximum of one hundred thirty-five million two hundred thousand (135,200,000)* gallons per day of treated wastewater through the mixing basin outfall 001 to Lake Michigan consisting of the combination of the following defined individual discharges:

Internal Outfall Descriptions

- Maximum 71ow (MGD)*

00A - South cooling tower suction basin overflow 25.9 ( U, 7) 008 - North cooling tower suction basin overflow 23.8 [5df, g) 00C - Cooling tower blowdown 86.0 ( /Jf,0)

/ 000 - Radwaste wastewater 0.1 00E - Neutralizer tank wastewater 0.1 n..

00F - Turbine sump oil separator including 0.1 Volume Reduction System-

  • This flow is not to be considered as a limitation on either the quantity or rate over time of discharge. pZoWS /N PMEA/7pStS PgMeseA/TALTehHtMfloW l

JHM PeMTi#fa The discharge shall be limited and monitored by the permittee as specified below:

Discharge Limitations kg/ day (lbs/ day)

Other Limitations Monitoring Requirements Effluent Monthly Daily Monthly Daily Measurement Sample Characteristic Average Maximum Average Maximum Frecuency Type 3

Flow, M / Day (MGD)

Daily Temperature (C )

F Intake Daily Continuous **

Discharge 47 Daily Continuous **

9 Heat Discharge Rate E x 10 BTU /hr Daily Calculation In addition to the Heat Discharge Rate jimitations specified above, the discharge shall not" increase the temperature of Lak.e Michigan at.the edge of a mixing. zone equivalent to 72 acres.

(a defined area equivalent to that of a circle of radius of 1,000 feet) more than 30 above

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the e,xisting natural temperature or above the following monthly maximum temperature:

JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 45 45 45 55 60 70 80 80 80 65 60 50 Outfall Observation ***

Daily Visual

    • 0nce per shift (3 times daily) grab sample measurement is pennissible when either the continuous monitor or recorder is out of service for calibration or repair.
      • Any unusual characteristics of the discharge (i.e., unnatural turbidity, color, oil film, floating solids, foams, settleable solids, or deposits) shall be reported immediately to the District Office of the Surface Water Ouality Division followed with a written report within 5 days detailing the findings of the investigation and the steos taken to correct the condition.

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