3F1017-03, Al-571, Sea Turtle Rescue and Handling Guidelines

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Al-571, Sea Turtle Rescue and Handling Guidelines
ML17297B881
Person / Time
Site: Crystal River  Duke Energy icon.png
Issue date: 10/24/2017
From: Dixon P
Duke Energy Florida
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
3F1017-03, AI-571
Download: ML17297B881 (15)
v • d • e


Text

~'-> DUKE Crystal River Nuclear Plant 15760 W. Power Line Street

~ ENERGY Crystal River, FL 34428 Docket 50-302 Docket 72-1035 Operating License No. DPR-72 POTS, Appendix B - Part II, 4.2.3(a)

October 24, 2017 3F1017-03 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Division of Spent Fuel Management, Office of Nuclear Material Safety and Safeguards, Washington, DC 20555-0001

Subject:

Crystal River Unit 3- Al-571, Sea Turtle Rescue and Handling Guidelines

Dear Sir:

In accordance with POTS Appendix B - Part II, 4.2.3(a) Duke Energy Florida, LLC (DEF) has provided revision 14 of Al-571, Sea Turtle Rescue and Handling Guidelines, to NOAA Marine Fisheries Service (NMFS) and the Florida Fish and Wildlife Conservation Commission (FWC) for their review. A copy of the revised guidelines is provided in Enclosure 1.

No new regulatory commitments have been made in this letter.

If you have any questions regarding this submittal, please contact Mr. Mark Van Sicklen, Licensing Lead, Nuclear Regulatory Affairs, at (352) 563-4795.

Sincerely, fJ-fA~

Phyllis Dixon Manager Technical Support- SAFSTOR PAD/mvs : Revision 14 of Al-571, Sea Turtle Rescue and Handling Guidelines xc: NMSS Project Manager Regional Administrator, Region I

U. S. Nuclear Regulatory Commission Enclosure 1 3F1017-03 DUKE ENERGY FLORIDA, LLC DOCKET NUMBERS 50 - 302 / 72-1035 LICENSE NUMBER DPR - 72 ENCLOSURE 1 REVISION 14 OF AI-571, SEA TURTLE RESCUE AND HANDLING GUIDELINES

I Information Use CRYSTAL RIVER UNIT 3 ADMINISTRATIVE PROCEDURE PLANT OPERATING MANUAL AI-571 Sea Turtle Rescue and Handling Guidance AI-571 Rev. 14 Page 1 of 13

TABLE OF CONTENTS Section Page 1.0 PURPOSE .......................................................................................................................3

2.0 REFERENCES

................................................................................................................3 2.1 Developmental References ...................................................................................3 3.0 PERSONNEL INDOCTRINATION ...................................................................................3 3.1 Description ............................................................................................................3 3.2 Definitions .............................................................................................................4 3.3 Responsibilities .....................................................................................................5 3.4 Limits and Precautions ..........................................................................................6 4.0 INSTRUCTIONS ..............................................................................................................7 4.1 Observation and Rescue .......................................................................................7 4.1.1 Observation Schedule ................................................................................7 4.1.2 Rescue Notifications ...................................................................................7 4.2 Turtle Rescue and Handling Guidance .................................................................8 4.2.1 Sea Turtle Rescue & Evaluation .................................................................8 4.2.2 Healthy Turtles ...........................................................................................8 4.2.3 Sick or Injured Turtles.................................................................................9 4.2.4 Comatose Turtles .......................................................................................9 4.2.5 Dead Turtles ............................................................................................. 10 4.3 Notifications......................................................................................................... 11 4.3.1 EHS or Site Environmental Specialist....................................................... 11 4.3.2 Healthy Turtles ......................................................................................... 11 4.3.3 Injured Turtles .......................................................................................... 11 4.3.4 Dead Turtles ............................................................................................. 11 4.3.5 5-Day Notifications to NOAA Fisheries ..................................................... 11 4.4 Reports (NOCS 62836) ....................................................................................... 12 4.4.1 Procedure Revisions and Reviews ........................................................... 12 4.4.2 Annual Report .......................................................................................... 12 4.4.3 30-Day Written Report .............................................................................. 12 4.5 Documentation .................................................................................................... 12 4.6 Re-initiation of Consultation ................................................................................ 12 5.0 Records ......................................................................................................................... 12 Summary of Changes ............................................................................................................... 13 AI-571 Rev. 14 Page 2 of 13

1.0 PURPOSE This procedure provides instructions for sea turtle observation, rescue, handling, and notifications at the Crystal River Energy Complex (CREC).

2.0 REFERENCES

2.1 Developmental References

1. IA-EN-ALL-0001, Environmental Services Department Interface Agreement
2. CP-151, External Reporting Requirements
3. Duke Energy Health and Safety Handbook
4. CR-3 Operating License, Appendix B, Environmental Protection Plan (Non-Radiological)
5. National Marine Fisheries Biological Opinion (BO)
6. AI-151, Reporting Requirement Program
7. FWC, Marine Turtle Permit
8. NOCS 62836 3.0 PERSONNEL INDOCTRINATION 3.1 Description
1. Sea Turtle Characteristics Sea turtles are graceful saltwater reptiles, well adapted to life in the marine environment. They are able to swim long distances in a relatively short time due to their streamlined bodies and flipper-like limbs. Sea turtles are air-breathing, and when they are active they must swim to the water surface for breathing purposes every few minutes. Turtles have been observed swimming underwater for periods of up to 20 minutes, and when resting some have been observed to remain underwater for as long as 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without breathing. The sea turtle influxes, which occurred in March-May 1998, led to the development of this procedure.
2. Sea Turtle Protection Sea turtles are an endangered species protected under the Endangered Species Act. The National Marine Fisheries Service (NOAA Fisheries), in conjunction with the Florida Fish and Wildlife Conservation Commission (FWC), enforce protection of sea turtles.
3. National Marine Fisheries Service (NOAA Fisheries)

The NOAA Fisheries issued a Biological Opinion (BO) on the potential jeopardy to sea turtles species at the intake area of the Crystal River Energy Complex. The Biological Opinion concluded that there was no jeopardy to any of the sea turtle species, and established terms and conditions governing reporting thresholds and rescue of sea turtles.

AI-571 Rev. 14 Page 3 of 13

3.0 PERSONNEL INDOCTRINATION (Cont'd)

4. NRC Requirements License Amendment No. 190 incorporated the NOAA Fisheries non-discretionary terms and conditions into the CR-3 Operating License, Appendix B, Environmental Protection Plan, Endangered or Threatened Sea Turtles. This procedure implements the NOAA Fisheries non-discretionary terms and conditions.
5. Turtle Rescue ERC or EHS will rescue turtles and may need assistance from other plant personnel due to the size or condition of the turtle. Other personnel may rescue turtles when acting under the direction of ERC or EHS.

3.2 Definitions

1. Annual Period From January 1, 2002 through December 31, 2002, and each calendar year thereafter.
2. Clearwater Marine Aquarium An FWC authorized facility for the treatment of sick or injured sea turtles.
3. Florida Fish and Wildlife Conservation Commission (FWC)

The State Agency responsible for controlling activities related to protected species.

4. National Marine Fisheries Service (NOAA Fisheries)

A branch of the National Oceanic and Atmospheric Administration responsible for controlling activities related to endangered sea turtles.

5. Nuclear Regulatory Commission (NRC)

The Federal Agency responsible for ensuring the health and safety of the general public relative to the actions and activities of the Crystal River Unit 3 nuclear plant.

6. Take For the purposes of this procedure, take is defined as the capture of endangered species sea turtles, including stranded, healthy, sick, or deceased turtles.

AI-571 Rev. 14 Page 4 of 13

3.3 Responsibilities

1. Environmental Specialist The Site Environmental Specialist is responsible for:
  • Managing and coordinating the sea turtle program
  • Establishing the appropriate observation/surveillance schedule
  • Making required notifications and submitting reports
  • Submitting any revisions of this procedure pertaining to turtle rescue and handling to the NOAA Fisheries and FWC for their review (post issuance)
  • Assuring CR3 Shift Supervisor is notified to determine reportability IAW CP-151, External Reporting Requirements.
2. Environmental Health & Safety (EHS)

EHS staff is responsible for:

  • Training of observation and rescue personnel
  • Notifying the CR3 Shift Supervisor of all dead or injured sea turtles
  • Sea turtle evaluations and care
  • Tagging and release or disposition
  • Determining the causation of mortality, and for requesting FWC to verify the determination
  • Making required notifications and submitting reports
  • Preparing records required by NOAA Fisheries and submitting these records to the Environmental Specialist
  • Maintaining a sea turtle stranding log
  • Rescue of sea turtles
3. Crystal River Energy Complex (CREC)

CREC Staff is responsible for:

  • Performing intake canal observations,
  • Bar rack inspections,
  • Making internal notifications to facilitate sea turtle rescues,
  • Assisting in sea turtle rescues.
4. CR-3 Shift Supervisor CR-3 Shift Supervisor is responsible for ensuring that any Mariculture Center or EHS notification or notification of an injured or deceased sea turtle is noted in the Electronic Narrative Logs Program and a NCR is created.
5. Site Emergency Response Coordinators (ERC)

Emergency Response Coordinators provide support for rescue of sea turtles from the CREC intake areas, although other site personnel may also assist with rescue of the sea turtles or rescue under the direction of EHS or ERC. Notify the Mariculture Center of any take of a sea turtle.

AI-571 Rev. 14 Page 5 of 13

3.4 Limits and Precautions

1. Sea turtles have powerful crushing jaws. They will bite when handled and can cause significant bodily harm. Keep clear of the turtle's head whenever possible.
2. Sea turtles may have claws on their front flippers. Keep clear of the front flippers whenever possible. Gloves should be worn when handling sea turtles.
3. Sea turtles should be handled with the rescue nets. Only if necessary, handle the turtle by the front and back of the shell. They should not be picked up by the flippers, head, or tail.
4. All safety procedures should be observed when working at the waterfront. Personal flotation devices or harnesses must be worn when working on the catwalk at the waterfront, as required by established safety practices.
5. Reasonable precautions should be taken to avoid contact with sea turtle blood secretions, or other bodily fluids.
6. Equipment used for the rescue or recovery of sea turtles exhibiting fibropapilloma tumor should be disinfected with a mild bleach solution (~ 10 ppm) following each use in an effort to prevent transmission of the disease to other turtles. Mariculture Center staff can assist with proper disinfection.
7. NOAA Fisheries anticipates that no more than 75 live sea turtle takes and 3 causally related sea turtle mortalities will occur annually. If takes reach one of these levels, the NRC must request re-initiation of formal consultation
8. NOAA Fisheries reporting thresholds summary (see sections 4.3 & 4.4 of this procedure for details):
  • The 70th non-lethal take occurs in the annual period
  • The 2nd causally related mortality occurs in the annual period
  • The 8th non-causally related mortality occurs in the annual period
  • Any injury or death in the intake canal or the bar racks causally related to CREC operations. Unlike the three notifications above, which are 5 day notifications, this 30 day notification is required any time there is an injury or death causally related to CREC operations, regardless of count.
9. The CR3 Shift Supervisor must be notified of all injured or dead sea turtles AI-571 Rev. 14 Page 6 of 13

4.0 INSTRUCTIONS 4.1 Observation and Rescue 4.1.1 Observation Schedule

1. The Site Environmental Specialist in conjunction with EHS will determine the appropriate observation schedule based on the frequency of turtle sightings or takes. The following guidance will be used by energy complex staff in the absence of specific instructions requiring more frequent observations:
a. During normal periods with low numbers of sea turtle strandings, or infrequent observations, or absence of sea turtles, a routine turtle observation schedule is established. This program will normally consist of the following:
  • CREC personnel will perform a sea turtle watch by:
  • Inspecting CREC bar racks daily (except when responding to a non-routine emergent conditions).
  • Making observations of the intake basin during inspections of bar racks to determine presence of sea turtles.
  • When requested by the Environmental Specialist, qualified individuals will inspect the bar racks for underwater strandings using the trash rake.
b. Increased turtle watch observations will be conducted during periods of high turtle population observations and/or strandings on the bar racks, as determined by the Site Environmental Specialist. During this period, it is likely that supplemental staff will be used to perform observations and make rescue notifications.

4.1.2 Rescue Notifications

1. CREC Staff perform turtle watches and records turtle observations so that the presence/absence of turtles is known.
2. When a turtle is found stranded against the bar racks CREC Staff will notify designated recovery personnel.
3. CREC Staff may provide support personnel to help with the turtle rescue and transport.
4. Supplemental staff may be used for turtle watch, and to perform rescue notifications.
5. CREC Staff will notify the ERC when ERC is needed for rescue or recovery. ERC will notify the Mariculture Center of all takes of sea turtles.

AI-571 Rev. 14 Page 7 of 13

4.2 Turtle Rescue and Handling Guidance 4.2.1 Sea Turtle Rescue & Evaluation NOTE: All steps possible should be taken to minimize stress and prevent harassment to sea turtles.

1. Sea turtles stranded on the bar racks should be rescued using a dip net or other equipment provided (do not release turtle back to the intake canal since the turtle may become stranded again).
2. Sea turtles that have been stranded against the intake bar racks should be held for identification and evaluation by the EHS staff.
3. Turtle recovery personnel should try to make a preliminary evaluation of the physical condition of sea turtle in order to determine whether the turtle appears sick or injured, and therefore needs immediate attention by the EHS staff.
4. EHS staff must make a sea turtle evaluation which includes general health, species, size, and date and time of stranding, and disposition.

4.2.2 Healthy Turtles

1. Turtle recovery personnel should transport the turtle to the designated sea turtle holding tank at the Mariculture Center.
2. Observe the turtles behavior for several minutes before leaving to assure the turtle appears healthy.
3. If the turtle appears weak (e.g. is not strong enough to lift its head), an EHS staff member should be called out (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day) to evaluate the turtle and provide appropriate care. Otherwise, notify EHS staff of the turtle rescue 7 days a week, during the first hours of day shift.
4. EHS will inform the FWC of the rescue of a stranded healthy turtle.
5. EHS will also notify the Site Environmental Specialist during normal work hours of any rescued sea turtle.
6. EHS or the Environmental Specialist will determine whether a live take meets the notification thresholds of Section 4.3.

AI-571 Rev. 14 Page 8 of 13

4.2 Turtle Rescue and Handling Guidance (Cont'd) 4.2.3 Sick or Injured Turtles NOTE: Do not place turtle on any hot or abrasive surface.

1. Place turtle on a wet towel in a cool, quiet area out of direct sunlight. Cover turtle shell with wet towel to prevent desiccation, and leave head exposed so turtle can breathe freely.
2. Turtle recovery personnel immediately (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day) notify EHS regarding condition of turtle.

NOTE: The Clearwater Marine Aquarium is an authorized facility for the treatment of sick or injured turtles.

3. EHS will notify the FWC or the Clearwater Marine Aquarium and make arrangements for the care of the sick or injured turtle.
4. EHS will determine whether the turtle injury was causally related to CREC operations.
5. If the sea turtle injury was causally related to CREC operations, EHS or the Site Environmental Specialist will immediately notify Unit 3 Shift Supervisor of the intent to make a notification to NOAA Fisheries.
6. EHS will also notify the Environmental Specialist during normal work hours of any injured sea turtle causally related to CREC operations.

4.2.4 Comatose Turtles NOTE: Sea turtles can remain motionless and appear dead for up to several hours.

1. Place the turtle on its belly.
2. Elevate the hind quarters several inches.
3. Place turtle on a wet towel in a cool, quiet area out of direct sunlight.
4. Attend to sea turtle until the EHS staff responds to the call out.
5. The EHS staff will perform advanced resuscitation techniques if appropriate.
6. IF the turtle revives, THEN follow the appropriate instructions in Section 4.2.3 for injured or sick turtles.
7. IF the turtle expires, THEN follow the appropriate instructions in Section 4.2.5 for dead turtles AI-571 Rev. 14 Page 9 of 13

4.2 Turtle Rescue and Handling Guidance (Cont'd)

NOTE: If a necropsy is done to aid in the determination of causality care must be taken not to exceed the NOAA Fisheries 30 day reporting requirement. CP-151, External Reporting Requirements, has information concerning reportability requirements.

4.2.5 Dead Turtles

1. Turtle recovery personnel will notify the EHS staff 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days a week, to arrange for dead turtle pick-up and disposal per FWC instructions.
2. IF EHS is unable to respond in a timely manner, THEN recovery personnel should place dead turtles in a container or bag with ice to prevent decomposition, until EHS is able to respond.
3. EHS Section will determine if the mortality was causally related to plant operations.

EHS staff will notify the FWC and request verification of the determination of causation. In some cases, a necropsy or other analysis will be done to help assess the cause of death.

4. IF the sea turtle mortality was found to be causally related to CREC operations, THEN EHS, or Site Environmental Specialist, will immediately notify Unit 3 Shift Supervisor that a report to the National Marine Fisheries Services is required.

Refer to CP-151, External Reporting Requirements, for applicability.

5. EHS will also notify the Site Environmental Specialist of any dead sea turtle.

AI-571 Rev. 14 Page 10 of 13

4.3 Notifications 4.3.1 EHS or Site Environmental Specialist Upon determination that a recovered turtle is a protected species and that a report or notification to NOAA Fisheries is required to be made, EHS or the Site Environmental Specialist will notify CR3 Shift Supervisor as soon as possible.

4.3.2 Healthy Turtles EHS or CR-3 Environmental Specialist informs the FWC of the turtle stranding and rescue.

4.3.3 Injured Turtles For injured sea turtles, EHS staff notifies (depending on the sea turtle's condition) the FWC and/or Clearwater Marine Aquarium rehabilitation facility. A follow-up report to NOAA Fisheries is required within 30 days of the incident if the injury was causally related to CREC operations. The Mariculture Center is the interim facility to hold sea turtles prior to pick-up for rehabilitation.

EHS staff will also notify CR-3 Shift Supervisor of any injured sea turtle.

4.3.4 Dead Turtles For dead sea turtles, the EHS staff notifies the FWC within the next working day to request independent confirmation of Duke Energys determination of causation. A follow-up report to NOAA Fisheries is required within 30 days of the incident for any mortality which was causally related to CREC operations.

If it appears likely that cause of death cannot be determined within 30 days of the incident, and causality cannot be ruled out, then report the mortality as if it were caused by site operations. EHS staff will also notify CR-3 Shift Supervisor of any dead sea turtle. Once it is determined that a report of the incident will be submitted to NOAA Fisheries, then immediately notify CR-3 Shift Supervisor as soon as possible, and inform them of the need to evaluate for reportability IAW CP-151.

4.3.5 5-Day Notifications to NOAA Fisheries

1. The Environmental Specialist or EHS staff notifies NOAA Fisheries within 5 days whenever:
  • The 70th non-lethal take occurs in the annual period, or
  • The 2nd causally related mortality occurs in the annual period, or
  • The 8th non-causally related mortality occurs in the annual period.
2. EHS Staff will also notify CR3 Shift Supervisor that a report or notification to the NOAA Fisheries is required to be made. CR3 Shift Supervisor refers to CP-151, External Reporting Requirements, for applicability.
3. Turtle takes beyond these threshold values do not require NOAA Fisheries notification within 5 days.

AI-571 Rev. 14 Page 11 of 13

4.4 Reports (NOCS 62836) 4.4.1 Procedure Revisions and Reviews The Environmental Specialist must submit revisions (updates) to this procedure that pertain to rescue and handling of sea turtles to NOAA Fisheries and FWC (post issuance) for review.

4.4.2 Annual Report The Site Environmental Specialist assures that a report on sea turtle strandings is submitted to NOAA Fisheries and FWC annually, by March 1 of each following year. The report shall include species, size, and date and time of stranding, location, condition, and disposition. A copy of this report is also provided to the NRC within 30 days of its submittal to NOAA Fisheries.

4.4.3 30-Day Written Report The Environmental Specialist assures that a written report is submitted to NOAA Fisheries within 30 days of any causally related injured or dead sea turtle in the intake canal or the bar racks. The report must summarize the incident. An NRC report is also required, in accordance with Section 4.1 of the Environmental Protection Plan, if the sea turtle mortality was due to CREC operations.

4.5 Documentation

1. Turtle recovery personnel should provide date, time, and location of stranding to the Environmental Specialist and EHS.
2. EHS Environmental Specialists maintain a turtle log, which will be used as a tool to track the dates and types (i.e. live, causal death, or non-causal death) of each take. The turtle log cannot be maintained up to date at all times because of takes that occur after hours and on weekends. It should be used in conjunction with Operations logs and condition reports to determine the numbers of each type of stranding. The turtle log should include: date, time, size, species, location found, disposition, causal or non-causal, condition (live, dead, injured, sick, appearance).

The log should only track protected species. The log should also provide a running total of each type of take and the date and time of the last update.

4.6 Re-initiation of Consultation The Environmental Specialist will ensure that a re-initiation of formal consultation occurs if the annual take reaches 75 live sea turtles or 3 sea turtles killed as a result of CREC operations.

5.0 RECORDS Completed copies of the report prepared in Step 4.4.2, Annual Report, is a lifetime QA Record and shall be transmitted to Document Control & Records Management (DCRM) per RDC-0001, CR3 Records Management Program. Licensing is responsible for submitting this report to Document Services on an annual basis.

AI-571 Rev. 14 Page 12 of 13

Summary of Changes PRR 02157688 Section/Step Changes Throughout Changed the responsibility from specific sites to Crystal River Energy Complex Staff, which includes the new Combined Cycle plants, along with the existing power plants.

Throughout Due to the permanent shutdown of Crystal River Unit 3 (CR-3), changed all of the titles to CR-3 Shift Supervisor, a position that is now responsible for all aspects that were previously assigned to CR-3.

2.1.1 Replaced superseded reference "NGGM-IA-0001, Environmental Responsibilities Agreement for the Progress Energy Nuclear Generation Sites" with "IA-EN-ALL-0001, Environmental Services Department Interface Agreement".

2.1.4 Replaced the CR-3 safety manual with the correct reference to Duke Energy Health and Safety Handbook.

3.3.2, 1st bullet Added "and".

4.1.1 Changed the sea turtle watch/observation responsibility to CREC Staff and updated the observation guidance based on the shutdown of the Crystal River Nuclear Plant and significantly reduced intake canal water flow, which has resulted in significantly reduced turtle strandings for the past 7 years. Also changed the frequency of monitoring based on the reduced flow due to the permanent shutdown of the nuclear plant with the approval of the Site Environmental Specialist and EHS.

4.2.5.3 On the third statement, changed "If some cases," to "In some cases,"

5.0 - Replaced "Procedure & Document Support Services (PDSS)" with "Document Control & Records Management (DCRM)".

- Deleted "and Regulatory Programs".

AI-571 Rev. 14 Page 13 of 13

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