3F0584-09, Forwards Recent Correspondence W/Epa,Per Tech Specs App B, Part Ii,Section 3.2 Re Sample Gathering for 316 Study & Denial of Relief from Delta T Limitations Requested on 840424

Forwards Recent Correspondence W/Epa,Per Tech Specs App B, Part Ii,Section 3.2 Re Sample Gathering for 316 Study & Denial of Relief from Delta T Limitations Requested on 840424

ML20091B845
Person / Time
Site:	Crystal River
Issue date:	05/23/1984
From:	Baynard P FLORIDA POWER CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
3F0584-09, 3F584-9, NUDOCS 8405300412
Download: ML20091B845 (18)

Text

.. .

a coca

$ e

[3 cOQp-)OGa

. t eoeo Florida Po. ..w. .e._r May 23,1984 3F0584-09 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Environmental Protection Agency Reporting

Dear Sir:

Florida Power Corporation hereby transmits a copy of recent correspondence with the Environmental Protection Agency, in accordance with Crystal River Unit 3 Technical Specifications, Appendix B, Part II, Section 3.2. The attached letters involve the sample gathering for the 316 Study and the denial of relief from delta-T limitations requested on April 24,1984.

If there are any questions concerning this information, please contact this office.

Sincerely, J&

k fiQ

\

P. Y{B'ayna)d Assistant to Vice President Nuclear Operations DVH/feb Attachments cc: Mr. 3. P. O'Reilly, Regional Administrator Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30303 f

yV 0405300412 840523 PDa ADOCK 05000302 PDR g

p GENERAL OFFICE 3201 Thirty fourth Street South e P.O. Box 14042, St. Petersburg, Florida 33733 e 813-866-5151

y-/(, - B1 f . . e,,,

Ai

!g i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

+rw# REGION IV W l'2 1983 lrEUoroUEIE[es REF: 4WM-FP N John A. Hancock, Vice President Fossil Operations P. O. Box 14042 St. Petersburg, Florida 33733

Dear Mr. Hancock:

Staff members of Florida Power Corporation, EPA and the State of Florida have discussed the magnitude and potential problems associated with the missing themograph data for the period of July-September,1984. Temperature data recovery averaged only slightly more than 76 percent for the 72 themographs during this period of critically high temperatures. Twenty-six of the sta-tions have 1/3 of the data missing and of these eight are missing 1/2 and two are missing 2/3 of the data. Serious consideration has been given by this Agency as to whether this loss of data will be critical to review of the 316 study results anc whether all 72 thermographs should be redeployed for the "fifth quarter" of the study.

Our evaluation indicates that the data loss from some of these recorders is excessive and that additional themograph data during the summer of 1985 is manditory. However, rather than deploy all 72 units at the existing stations, we feel that installation of bottom thermographs at the 40 benthic stations will provide more useful data to complete the study objectives. Continuous data from these stations during the summer periods of maximum temperatures will assist in comparisons of the fauna at the benthic stations and in quantifying the area of themal impact (major objectives of the 316 study) as well as providing data necessary to complete the thermograph record for the 72-station assessment.

Should you have any questions or feel that deployment of themographs at the benthic stations is not acceptable, feel free to contact us. .

Sincerely yours, W IL aul J. Traina, Director Water Management Division cc: Mr. William S. O'Brien, FPC Dr. J. P Subramani l

Mr. Delbert Hicks l Dr. Lawrence Olson, FDER Mr. Douglas Ferrel Tampa FDEP.

l . .

l 8e4/AS l l pa naa,,

5 g i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

• % w# REGION IV 345 COURTLAND STREET ATLANTA. GEORGIA 30385 APR 13 W REF: 47M-PP John A. Hancock, Vice President Pbssil Operations P. O. Box 14042 St. Petersburg, Florida 33733 RE: Crystal River 316 Study NPDIE Permit FID000159

Dear Mr. Ihncock:

A letter was sent to you on April 12, 1984, discusssing thermograph data at the referenced facility, but was incorrectly dated April 12, 1983.

< Within the body of that letter, two additional erroneous year designations were included.

! Please replace that letter with the attached letter dated April 12, 1984.

Sincerely yours, g//fte J =

ul J. Traina, Direc(or Water Management Division cc: Mr. William S. O'Brien, FPC

! Dr. J. P. 31bramani, FDM j Mr. Delbert Hicks, EPA Dr. Inwrence Olson, FDER ,

Mr. Douglas Ferrell, 'JBIppa FDM

{

l l

i

April 12, 1984-Esta eM-rP Jot +n A. Namcoct, itte FriesIdefit Ftmail (peret teme F. C. ros 14042 St. Pwterr142rw flottos H7U sesr Hr. P.aror,ck itati mentaars ei Florica imer Mrporat1on, EP A a n u *La t.t 2: e et r1ortce have ciscupomJ t.:,e Papittuce end pratee.tial freeles's associater, with t1

• n tra te.g tt.= rsgerp:. cate tot tre got t e.* af  % 1y- 4t tuter : t.J.

Waperature c.ta r=ce.very a*. cased i.ely sitetty enore ti er, M parcert t r,r ti.e 72 themwraphs curtas Inte feriod et critic.sily Myn texpirett.cnv.

• wenty-sta or, t!.s statlof.a vase 1/3 OL ti.e data miselag *E of t +ce, sight are stavip; ifI <rd tso are mtss try 2/3 of the eata. tArticus constGPr=> leu has inn give u/ taa s Agsts:y as to whettwr tt.ic less of data et11 to stit4eal to revtee of the ?le st.udy reewits sr.d whetter all 72 therwwratre abould le recceric)W for the 'f ttth quarter

• of the 1.tudy.

l Our evalustle.n trif t ates t'.at tre stata 1cas f rem stime of ti.ese recerfors ta excesente er41 t!.ut a< kit tonal theanograph data eurtrq tt,e s&sesor 't 1984 la wars:itory. Is.wur, retter ttaa t.eploy all 72 ut.it a et tr e ex t stirn stattous, we feel t!.4t t r.t,t ellation M tottoa tternograp+,a at tre de c+nts tc etstints, st11 prcvide more usetti data te cumplate Ue t.tt cy c

cb;erctives.

soot.trer us .Jata troen Llese st.astione c #rir.o tFv scw'er [.arte<):

of rutrte temperatures will es41st in et w arincs.a eg t!.4 fusta at ris tenttic rtatios.a anc in iguar.tifying the ares cf

• h. pts.e l t orp.v.t (a.ajor ot;utives e,t 'to 118, st ucyl as well es pre.v14 irs esta t et.ts ra ry to i

craerlete ttw therncur aph rscord for tts 72-stat tea adws:,esent.

! ti.oute yco haw auy St.eett<xa rir feel tNit utplupr.t et tieru.gratte et the bienthic stattema is r.ot, ecc.$ tabl*, reel free to cuntact vs.

l j tiaerely yr .rs, s I

c l

1s.i1.i. 'ir sina, Ettwtor h te.r t!a4 v g s m t L.t s t ,1w 4.ca Mr. Utlitosi1:. f'ilr!+c, IN

[ t r . s' . i'. :;..#r m r.1, rm

[ Nf. Nit ert I:1d r, itA Dr. : 46erou G 4.csi, TULN j  :

Ja. 1.oty la s Fvs tell , t u.<a t.:8.h bec: Mr. Paul J. Behrens, ITC Mr. Ieter McChery, LPA

I i

ft18ter

/A i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY b% # REGION IV MAY 1 o 19M 34. coumA=o stmr ATLANrA. GEORGIA 30345 1

Mr. Paul Behrens i '

Florida Power Corporation P. O. Box 14042 j St. Petersburg, Florida 33733 Re: Crystal River 316 Study NPDES Pemit No. FL0000159-l

Dear Mr. Behrens:

Reference is made to infomation presented in the second and third quarterly reports and to discussions at subsequent meetings. Additional infomation is requested to be made available at this time and/or in the

316 Demonstration as applicable. Availability of portions of this infomation now will assist in our continuing assessment and dialog with

! FPC staff. To the extent that requested material is not readily available or

{ can not be provided with a reasonable level of effort, please call me so that 4

we can discuss alternative approaches.

1 1. Weekly STD Surveys (a) Time of high or low tide, times of sample collection (tide i

window), tide amplitude and average wind speed and direction should be added to the tabulation of data. Where data points i

are significantly outside the tide window, sampling times should be noted and applicable data points marked as not being representative of the tide condition sampled. This is especially applicable to Stations 4-30.

t (b) Map (s) providing benthic and themograph station locations within the area of benthic Stations 4-30 and a grid of designated size (possibly by overlay) at a scale larger (approximately

.l three times) than Figure 2-9 of the January ll,1984, study plan 1

suma ry. A map showing only bathymetry, oyster bars and station

' locations would be desirable. Expeditious receipt of this material would be helpful in plotting selected STD data.

(c) Tabulation of depths for benthic stations and also for

themograph stations.

2. Intensive Surve.ys I

(a) Map (s)withspecificlocationsofthestationssampledata scale consistent withFigures in Section 4.5 of the third quarterly report. Map (s) of the same size or overlays showing location of benthic and themograph stations and inclusion of a j linear scale and grid of designated size would be appreciated.-

f (b) Listing of individual data points and times of sampling.

. .. =

(c) Infomation similar to item 1. (a) above.

3. Rant Operating Data Hourly data logs for Crystal River Units 1, 2, and 3 for all intensive and weekly STD surveys during August 1983 and January 1984 including load (MW), intake temperature, delta temperature by unit and POD temperature. Data listing should start about six to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before start of the survey. With the exception of August 13, requested data for August,1983 was provided at the May 3,1984, meeting. This infomation is requested to assist in assessment of data in the second and third quarterly reports. Future discussions will include data requirements and presentation in the 316 Demonstration.

Should you have any questions please feel free to contact me. Your assistance in this matter is greatly appreciated.

Sincerely yours, Charles H. Kaplan, PE Coordinator, Thermal Analysis cc: Subramani Olson Ferrell

-. m nu u, l

. bec: J. A. Hancock - ASA W. S. Wilgus - A5C '

H. A. Evertz - ASD M. B. Foley - H8 G. R. Westafer w/ attachment - H3 R. E. Parnelle D. K. Voigts M

P. .o..w. .e. . .r.

May 1, 1984 Mr. Paul J. Traina, Director Water Management Division U. S. Environmental Protection Agency 345 Courtland Street NE Atlanta, GA 30365

Subject:

Crystal River 316 Study

Dear Mr. Traina:

We have received your letter of April 17, 1984, and thank you for approving previously requested modifications to the subject study.

There was a lengthy discussion of the need for " typical curves" at the Second Quarterly Progress Meeting and it was agreed that one set would be developed for review. However, discussions between Messrs. Behrens and Hicks subsequent to the meeting indicated these plots would not be necessary if other data were provided. This change is recorded in the Notes of Conference from the Second Quarterly Progress Meeting transmitted to Mr..

Kaplan on March 5, 1984. A copy is enclosed for your information with the appropriate section highlighted. We had assumed this matter resolved. If this is not the case, it should be discussed at the upcoming May 3, 1984 meeting.

In the third paragraph of your letter you state that FPC has not "specifically indicated the alternative thermal limitations" which it is

, seeking. This is correct. We are not proposing any alternate thermal

limitations at this time nor do we think any should be proposed until after

the 316 Study is completed. The scientific facts and analyses the study l yields should logically play a large role in the final outcome of Crystal River. Establishing positions at this time could jeopardize that final resolution.

Sin h y, L

I J A. Hancock -

ice President, Fossil Operations JAH:lb Enclosure cc: Ms. V. J. Tschinkel, FDER w/Enci General Office 320 Thirty-iourm street soum . P O. Som ido42, Si. Petersburg. Florida 33733 813-866-5151

R....e....

...

March 5, 1984 Mr. Charles H. Kaplan Water Management Division Permits Section U. S. Environmental Protection Agency 345 Courtland Street Atlanta, Georgia 30365

Subject:

Crystal River 316 Study

Dear Mr. Kaplan:

Enclosed is a copy of the Notes of Conference from our Second Quarterly Progress Meeting, held on February 2, 1984. Should you have any comments or questions regarding these notes, call me in St. Petersburg at (813) 866-5521.

Sincerely, pg. 4,L~

Paul J. Behrens PJ8/gr Enclosure General Office a:oi n=ny sounn s, souin . P o. som tsosa, si P.iersourg. Fiones 33 ras . ais--ass-sis

j NOTES OF CONFERENCE , J.O.No. 14498 FLORIDA POWER ' CORP _0 RATION Held in the Of fices of Present for:

Florida Power Corporation St. Pe te rs bu rg , FL Florida Power Corporation (FPC)

February 2, 1984 David Voigts Paul Behrens I

U.S. Environmental Protection Agency (EPA)

Charles Kaplan Delbert Hicks Florida Department of Envirorunental Resources (DER)

Lawrence Olsen Doug Farrell U.S. Fish and Wildlife Service (FWS)

Jack Gallagher Mote Marine Laboratory (MML)

Kumar Mahadevan Stone & Webster Engineering Corporation (SWEC) i Tom Biffar David McDougall Tom Folger PURPOSE The meeting cons tituted the Second Quarterly Progress Meeting fo r the Crystal River NPDES 316(a) and (b) studies.

DISCUSSION Attachments 1 and 2 provide the meeting agenda and the attendance list.

Mr. Behrens opened the meeting, noting that a summary plan of study had been produced as requested at the first quarterly progress meeting and distri-buted to interested parties.

l Dr. Bif far reported that Station L, a grassbed station for plankton sampling, was relocated on October 24 as the grassbed no longer existed. It was suggested that sampling continue at the new location but that re-establishment of the grassbed be monitored. Should the grass reach B4-14498-59

l l

2 previous de ns ities, supplemental sampling at the original site will be considered. In the course of the discussion Dr. Mahadevan noted that i Stations L and M were not intended to be comparable and do have dif ferent dominant macrophytes. It was also noted that the crab tagging program began in September and was completed in early January. Dr. Farrell expressed some concerns that female movements as influenced by the intake spoil dike would not be adequately monitored without further sampling, howeve r, it was pointed out that the program had been designed and previously approved to run from September through December. DNR's longer term return information could be used to supplement the site-specific data. Dr. Farrell is parti- ,

cularly interested in total catch, male ve rsus female ratio and catch by station.

D r. Mahadevan reviewed the s tatus of field collections and labo ratory analyses as summarized in Tables 3-1 and 3-2. No exceptions were take n i regarding any of the biological tasks. Mr. Kaplan inquired about the ground trutt.iua question raised at the first caecinh and was told that cacrophytes at locations other than specific station locations are also investigated and recorded. Mr. Kaplan questioned the lack of available aerial photographs and asked if EPA Las Vegas had been contacted for help. MML had done this and got no new suggestions. Mr. Hicks indicated that experience in the present program is about what he would expect considering meteorological and water quality conditions. Dr. Voigts noted the desirability of hand-held, amateur photographs in lieu of no photographs. Changes in gear types as described in the first quarterly meeting are working well.

1 Mr. Kaplan was concerned that references in Table 3-1 to stations missed 1

during low-tide, photometry sampling do not always correspcud to data presented in the data tables. Table 3-1 will be reviewed and corrected as necessary for future reports, but it was noted that the table is not intended to be as precise as the data. Mr. Kaplan also referred to several apparently incorrect teniperature records in the monthly temperature tables.

Most numbe rs questioned were correct when compared to field logs but two values were input errors. An additional check will be put into the system l to a) evaluate field data for " reasonableness" before input and b) evaluate l variations within and between stations. Relative to the weekly temperature l

data, Mr. Kaplan stated that EPA documented by le tter (April 22) their desire for plums plote"ame screegs determinations for each survey. Af ter an extended discussion of the need for such an ef fort, it was suggested that only plots of worst case temperature under high and low tide conditions, approximately each six weeks (the benthis core schedule) might be suf fi-cient. Dr. TWigte asked 31SC *to develop one set of plots for Mr. Kaplan's review. Discussion betuses Mr. Behrens sad..Mr. Nicks subsequent to the meeting suggested that plots of weekly data would not be needed if these data are to be correlated directly with the biological data (see Attach-ment 3). Plant heat output data is needed to correlate with the measured -

t empe ratu re.

Dr. Mahadevan reported be t ter thermograph recove ry since marke rs we re changed. Mr. Kaplan noted that EPA has been r2 viewing thermograph data recovery especially for July, Augus t and September. They expect to make a decision on adequacy in the near future. If the data are judged inadequate, B4-14498-59

3 EPA may request an extension of the collections to cover June, July and August, 1984. Mr. Behrens questioned the level considered adequate and the need for an extension since recovery may be no better in 1984. He stated that if more data were requested, collecting at fewer stations should be cons ide red. Mr. Hicks agreed that 75 percent recovery was reasonable and stated that his prime interest was in " bottom" units and only Stations 17B and 45B appear to have real problems. DER is interested in having adequate l data for a mixing zone determination and would be concerned with gaps in the temperature data.

Adequacy of tide height data was briefly discussed. Boundary stations are most important but even loss of data at some of these stations can be compensated for, although with dif ficulty. Latest information from MML is that data enhancement efforts have been successful and good recovery of bounda ry information will result, Exact status will be known in two weeks and EPA will be notified.

It was agreed that, if necessary, scheduled photometry and retc.ted water quality sampling would be altered to ensure sampling correlated with storms and barge traffic the necessary number of times.

Meteorology data from FPC has been obtained to compensate for the August gap in data from MML's facility. Data from overlapping periods will be compared to define the relationship between the two sets of data.

Replication adequacy is ~ing reviewed for benthic samples. Several para-meters such as saturation curves, density changes, Shannon-Weaver and Mo risita's index are being used. The results should be available in about two weeks. Dr. Farrell is interested in the Shannon-Weaver results.

Oyster reef data is being af fected by sediment at certain stations. As sedimentation occurs, cages are being lif ted but not relocated. It was agreed that this was appropriate.

Mr. Kaplan noted several open items from the earlier meeting. In parti-cular, the definition of ambient temperature remains open. EPA does need any revision of the MML Quality Assurance Manual / Standard Operating Pro-cedures. The need for additional entrainment sampling was discussed at le ng th. Since it was estimated that complete mixing requires auch of the discharge canal and that set tlement of plankton in the canal is unlikely given ambient currents, S tation C in its present location will suf fice.

J Mr. Kaplan stated that the quality assurance program in place is acceptable; DER has no definitive problem. Mr. Kaplan also reiterated program changes made since June, 1983 and requested and received formal approvals. The changes were: moving.. S tations B, I, K and L; inclus ion of only Stations 4-30 in the 90 minute window; deletion of fish stomach analysis and changing the crab tagging program. The movement of Station L should be ducumented by letter to EPA. While no new entrainment sampling station is needed. Station C should be sampled at an appropriate interval af ter Sta-tions D and E. 'Ihe Technical Specification Summary submitted previously is 84-14498-59

- - - , _ , _ . _ - , , n-

. . 1

. l l

t 4 a ccep tab le. Extending themograph data collection for three months is stiL L under consideration.

Mr. McDougalL reported the status of modeling. Model setup and testing with mock data has been successful; the site grid and a model velocity output were displayed. The computer programs and procedures to handle data on t ide s , currents, water quality and meteorological conditions have been completed and the August data vill soon be prepared for use as model input; data from Station 5 were displayed. The last of the August data should be received within the week. Returns are better than previously thought, but in either case should be suf ficient for the modeling ef fort. The January surveys have been completed and data from the in situ me ters should be available in about a me . The near-field model has not yet been selected.

Mr. Kaplan reite rated concern with multilayer plume conditions; this phenomenon wiLL be hand led in the near-field but is not modeled in the far-field.

, Dr. Biffar passed out some explanatory notes concerning the data presenta-j tions and data tables as follows: replacement salt marsh (Spartina) tables,

, new oyster mortality table s for November, replaceme nt impingement tab le s ,

j replacement drop net biomass tables, and a new crab tagging table.

Mr. Hicks would like to see species lists by family. Input on desired analyses are requested for the next meeting. A summary of anticipated analyses will be included in the next report as a starting point for the discussion.

l i l

i TBiffar:PBF 1

1 54-14498-59

A T T A c.R M E wr s 1

i

, AGENDA SECOND QUARTERLY PROGRESS MEETING CRYSTAL RIVER NPDES STUDIES 4

1. Introduction - P. Behrens

2. Program Changes - T. Biffar

3. Field Work and Laboratory Analysis - S. Mahadevan i

4. Hydrodynamic and Hydrothermal Modeling - D. McDougall l 5. Data Tables and Data Analysis - T. Biffar

6. Discussion 4

9 l

1 I

- - - - - y . . , _ , , - ~ . 3 ,,-. - . _ _ . m ,r - , y_ -

\

nTTAc.asue4r s_.

hw n_ 3 a# d w3 ne ~,, p 4

-ree n mi-re* >h s u A& s )

Ku ma m. m a w nw.v a*J M.V %i Me

~7"*homa s A, foly er S btre / Webrl*r Eny. C.rp.

" ' ' 'l h vicl $ { D O U ctl

%% e>+ 8. . n ch EPA -

cm. s : 8 n.n '. -

JAuc & AL L. MHe R J1Fws v D a.v; d bi 3t.s FPC Deog %ns.O F o e A. "

Lwrea; d.(Isa,  ;;bER s buJ 3amars FPC.

l l

l

I Attachment 3e Dr. S. Mahadevan has prepared the following response regarding the use of weekly temperature data (collected in conjunction with light, conduc-tivity and pH measurements) in the assessment of thermal impact on the benthic infaunal community in the vicinity of Florida Power Corporation's Crystal River Power Plant.

In the original Plan of Study bottom temperature at the benthic stations was proposed to be collected monthly in conjunction with the infaunal samp-ling program. In MML's review of the Plan of Study, such a sampling fre-quency was considered inadequate and MML recommended that weekly sampling of temperature and other parameters be conducted at the infaunal stations in order to statistically delineate temperature differences at the stations.

It is anticipated that this information will be used as follows:

1. Confirming the validity of northern and southern control stations in terms of temperature regime.

2. In terms of temperature, classify the stations in thermal area according to the gradation of delta T's as determined from 6 weeks or quarterly averaged data and comparing the thermal stations with paired control stations.

4

3. Identify in terms of infaunal benthic community characteristics, the gradation of stations that are different or under stress.

Utilizing the information obtained in Item #2 (above), along with similar information from other physical parameters, identify the thermally altered stations and thereby the area of thermal impact.

Therefore, all the analyses of temperature data will be on an inter and intra station basis with emphasis on bottom temperature and not_ vertical profiles. The utility of extrapolated plots or isotheras (as suggested l 1

hy the Environmental Protection Agency) will be limited for purposes of .

1 the benthic community impact assessment.

l

l FA CTL

,,.. . ,g SK )

ia3 ,

! UNITED STATES ENVIRONMENTAL PROTECTION AGENCY b e REGION IV AT NTA GEORGIA 30345 APR 171984 REF: 4WM-FP John A. Hancock, Vice President Fossil Operations Florida Power Corporation P. O. Box 14042 St. Petersburg, Florida 33733 Re: Crystal River, 316 Study NPDES Pemit No. FL0000159

Dear Mr. Hancock:

Modifications to the referenced study as discussed at the Second Quarterly Progress Meeting and included in the meeting notes transmitted by Paul J.

Behrens on March 5,1984, are hereby approved. These include relocation of Stations B. I, K, and L; inclusion of Stations 4-30 within the 90-minute sampling window; deletion of fish stomach analysis; and changes to the crab tagging program.

One major area still remains unresolved at this time. EPA has maintained throughout the study plan development and approval (specifically see my letter of April 20,1983) that plots of each individual field survey are necessary in the final report and should show delta temperature isothems, isohalines, and ambient temperature, with multi-depth plots provided as i

necessary to present thennal/ salinity stratification. FPC staff have been i of the opinion that only " typical curves" are necessary. At the Second Quarterly iteeting, an alternate suggestion was briefly discussed. Wmely, l that the highest temperatures at each station and thermograph during a 6-week period be utilized to develop worst case plots. One set of such plots was to be developed to allow further evaluation; however, it has not been provided.

At this time although FPC is now collecting field data to support a 316(a)

Demonstration, you have not specifically indicated the alternative thennal l limitations which you are seeking. It is requested that you provide us with l

l l l

)

4 this information prior to the May 3,1984, meeting. Resolution of the number and complexity of the plots of the STD data needed, as well as, the mathematical modeling runs to be conducted will hinge, at least in part, on the alternative thermal limitations being requested.

Should you ,have any questions, do not hesitate to contact me or my staff.

Sn r'ly yours, r

Pi

. Traina, Director Water Management Division cc: Dr. J. P. Subramani, FDER '

Dr. Lawrence Olson, FDER Mr. Douglas Farrell, FDER (Tampa)

Mr. William S. O'Brien, FPC l

i

)

1

l l

f**

• th,,

$g? h UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Qe REGloN IV 34s counTLAwo stnes?

A ATLANT A. GEOn CIA 30345 MAY 10 1984 REF: 4M -FP Mr. W. S. Wilgus

, Vice President, Nuclear Operations Florida Power Corporation P. O. Box 14042 St. Petersburg, Florida 33733 RE: Crystal River Unit 3 NPDES PWmit No. FI4000159 Condenser delta-T - Your Intter of April 24, 1984 Dear Mr. Wilgus We have reviewed your request for relief from delta-T limitations as stated in your letter dated April 24, 1984. It is my decision that such relief cannot be granted at this time.

The pomit has expired. A'lthough its provisions still are in effect under the Adninistrative Procedures Act, the expiration means that the posit may not be modified. In addition, the themel studies required under Section 316 of the Clean Water Act have not been empleted. Until such time as those studies are ca91ete and deteminations regarding i

necessary thorral limitations are mode, the posit will not be reissued.

Sin ly, f If 0dLFA (PaurJ. Mna, Director ~

Water Management Division cct FDER 4 b i

C.9.a,.@j

.c . ;; -

<3 j l Ug.. .. a 'J k $

l i'i h'. ggy14Nuctoar W $

l

! s s

.; Operations s

[9

/PfT'T$'D

.