L-75-374, Environmental Technical Specification Change
| ML18088A949 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 07/28/1975 |
| From: | Robert E. Uhrig Florida Power & Light Co |
| To: | Anthony Giambusso Office of Nuclear Reactor Regulation |
| References | |
| L-75-374 | |
| Download: ML18088A949 (10) | |
Text
NRC DISTRIBUTION FOR PART 50 DOCKET MATERIAL (TEMPORARY FORM)
CONTROL NO: >>>>
FILE FROM. Florida Power & Light Co Miami, Fla obert TO:
Mr, Angelo Giambusso CLASS UNCLASS PROPINFO DESC R IPTI ON DATE OF DOC ORIG signed INPUT DATE R EC'D CC OTHER NO CYS REC'D ENCLOSURES.:
LTR TWX RPT SENT NRC P DR SENT LOCAL PDR DOCKET NO:
50-335 OTHER Ltr notarized 7-28-75
~ ~.trans the following:
'ACKNOWJ ~>~~0 339 Jg~c'p ~p<glOyg PLANT NAME:
St ~ Lucie 81 Revision, P4 toithe Proposed=Environmental
.Tech-Specs,furn comments on sections 2.2,1, 2.4,2,c, Table 2,4-1, Table 2,4-3 and 2,4-4,$ oc 3sl;Bgf and,Table 3.2-1
( 40 cys enc'1 rec'd)
FOR ACTION/INFORMAT 7-28-75 JGB BUTLER (L)
W/ Copies
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CLARK (L)
/ Copies ARR (L)
W/(Copies KNIBL(L)
W/ Copies SCHWENCER (L)
W/ Copies STOLZ (L)
W/ Copies VASSALLO (L)
W/ Copies PURPLE (L)
W/ Copies ZIEIVIANN (L)
W/ Copies DICKER (E)
W/ Copies KNIGHTON (E)
W/ Copies YOUNGBLOOD (E)
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. BOX 013100, IIIIIAMI,FLORIDA 33101
.-.==,@8 F!Je Cy.
FLORIDA POWER 8t LIGHT COMPANY July 28, 1975 L-75-374-Mr. Angelo Giambusso, Director Division of Reactor Licensing Office of Nuclear Reactor Regulation U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555 C]EEET JUL3( 1975~
U. S;- WCLEAR REGUIAEOEEI COmiSSeEE AkilSocial~
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Dear Mr. Giambusso:
Re:
St. Lucie Unit No.
1 Docket No. 50-335 EnVir6nmental'Technical'S ecification Chan e
Florida Powex & Light'Company hereby submits for your review three signed originals and 40 copies of xevision 4,,dated 7/28/75, to the proposed St.
Lucie Unit No.
1 Environmental Technical Specifications (ETS).
I wish to take this opportunity to comment upon the following sections of the enclosed document:
Section 2.2.1 During discussions between representatives of 'FPL and members of your staff on July 21, 1975, it was stated that FPL's spec-ification on chlorine would comply with the NPDES permit limit fox St.
Lucie Unit No.
1 of 0.1 mg/1.
Upon consideration, it was decided that this" limit should be specified as 0.2 mg/1 in the ETS.
This remains consistent with the limit proposed in Atta'chment 1 of Mr. William H.
Regan's letter to Dx. Robert E. Uhrig, dated'uly 7, 1975.
In addition, We maintain that a total residual chlorine level of 0.2 mg/1 is an acceptable level as determined by the Environmental Protection Agency, and as promulgated in the Final Effluent Limitation Guidelines of October 8, 1974.
These are not merely guidelines, but have the sanction of law and must thexefore be complied with.
The limit of O.l mg/1 in the St. Lucie No.
1 NPDES permit was imposed prior to development of the guidelines.
We propose to initiate a change in oux NPDES permit upon its expiration or possibly before, which would allow the chlorine residual limitations as determined by EPA, and not more stringent limits than those the Guidelines'call for.
Section 2;4:2.c This section has been modified from that which Mr.
William H. Regan's letter of July 9, 1975, transmitted to us.
The justification for this modification is based upon St. Lucie Plant Chemistry Department Letter of Instruction CC-04 Revision 0. Per H 8 L PING 8U I LD FLO R I DA
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Mr. Angelo Giambusso July 28, 1975 agreement with members of your staff on July 21, 1975, this LOI, plus its tank yecirculation data sheet, are attached as Enclosure 1.
Table 2.4-1 This table has been modified from that which Mr. William H. Regan's letter of July 9, 1975, transmitted to us.
Item B, Primary
- Coolant, and its related footnote, have been deleted because the required sampling is addressed in the St. Lucie Unit No.
1 Appendix A technical specifications.
Tables 2.4-3 and 2.4-4 These tables have been modified from those which Mr. William H. Regan's letter of July 9, 1975, transmitted to us.
The mod-ifications have been made to xeflect the'omenclature used and the actual systems and monitors installed in St. Lucie Unit No. 1.
Primary Coolant System (liquid) and Reactor Containmenh Building (gaseous) monitoring have been deleted'ecause the required sampling is addressed in the St.
Lucie Unit No.
1 Appendix A technical specifications.
A number of the other systems have been'eleted from the tables because no provision for their monitoring, as indicated'n the tables, has been made.
Although it is recognized that, requirements may change over the period of design and construction of a nuclear plant, nonetheless, St. Lucie Unit No.
1 has undergone thorough Staff xeview'fits safety, The findings of the Staff with regard to Process and Effluent Radiological Monitoring axe
'ound in Sections 11.5.2 and 11.5.3 of the Staff's Safety Evaluation Report for St. Lucie Unit No. 1, dated November 8, 1974.
There the Staff states that "(b)ased on the plant design and on the continuous monitoring locations.
and intermittent sampling locations, we have concluded that all normal and potential release
- pathways, excluding those in the turbine building, will be monitored.
Due to the high potential for exfiltration from the turbine building which is a relatively open structure, we do not consider it to be practicable to monitor the potential gaseous releases from the turbine building...;
We have also determined that the sampling and monitoring provisions will be adequate for detecting radioactive material leakage to normally uncontaminated systems and monitoring plant processes which aHect radioactivity xeleases.
On this basis we consider'he monitoring and sampling provisions to meet the requirements of AEC General Design Criteria 13, 60 and 64 and the guidelines of Regulatory Guide 1.21....
Based on the fore-going evaluation, we conclude that the proposed provisions for monitoring process and effluent streams are acceptable."
Accordingly, FPL believes it would be justified in excluding such monitoring provisions from the ETS.
Section 3.1.B.f Discussion with members of your staH on July 21, 1975, indicated their desire. to include in the ETS the condition relating to monitoring of turtle hatchlings found on page v of the St. Lucie Unit No.
1 Final Environmental Statement.
FPL has chosen to delete the words "number of turtle hatchlings" from the ETS because this phase of the life cycle of, the turtle is not aHected by the thermal plume emanating from the plant during its operation.
It is felt that the collection of such data" is
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Mr. Angelo Giambusso
,July 28, 1975 irrelevant since it could not effectively be related to existence of the plant's thermal plume.
Table 3.2-1 Sampling location H40, the Florida Milk Shed, is our control location for milk sampling.
The sample consists of a monthly composite from several locations in southeastFlorida.
It is, therefore, less'likely to be biased by the Cs-,137 anomaly frequently observed in this" area of the state.
Yours v
- truly, Robert E; Uhrig Vice President
/
REU nch
'nclosures'c:
Jack R.,Newman, Esquire
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STATE OF FLORIDA
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COUNTY OF DADE ROBERT E.
UHRIG, being first duly sworn, deposes and says:
That he is a Vice President of Florida Power
& Light Company, the Applicant herein; That he has executed the foregoing instrument; that the statements made in this said instrument are true and correct to the best of his knowledge, information and belief"; and that he is atuhroized to execute the instrument on behalf of said Applicant.
Robert E.
Uhrz.g Subscribed and sworn to before me this ~&~ay of
'965 No ary Public in; and,for the County of Dade, State of Florida NOTAIF>>i"" MATHOF FI.ORIDA AT IAIII'(
MY CohVhISSIOH EXPIRES JAN, Qg f/)
My COmmiSSiOn eXPireS '@HDEO THku GEN".AI, INSVRAiuCE uP4O:KWKIfES
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