L-2016-153, Response to Request for Additional Information Regarding License Amendment Request for Biological Opinion License Changes

Response to Request for Additional Information Regarding License Amendment Request for Biological Opinion License Changes

ML16238A190
Person / Time
Site:	Saint Lucie
Issue date:	08/11/2016
From:	Costanzo C Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2016-153
Download: ML16238A190 (5)

Text

August 11, 2016 L-2016-153 10 CFR 50.90 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Re*: St. Lucie Units 1 and 2 .

D_oeket Nos. 50-335 and 50~389 Response to Request for Additional Information Regarding License Amendment Request for Biological Opinion License Changes

References:

1. NRC letter dated April 7, 2016: Transmittal of National Marine Fisheries Service's March 24, 2016, Final Biological Opinion for St. Lucie Plant, Units 1 and 2

2. -,_FPL letter L-2016-072 dated April 29, 2016: License Amendment Request to Update Appendix B to the Renewed Facility Operating Licenses to Incorporate the 2016 Biological Opinion

3. NRC email dated june 28, 2016: Request for Additional Information - St. Lucie March 2016 Biological Opinion LAR - MF7661/MF7662 Per Reference 2 above, Florida Power and Light Company (FPL) requested an amendment to the Renewed Facility Operating License (RFOL) for St. Lucie Units 1 and

2. The License Amendment Request (LAR) proposed changes to the Unit 1 and Unit 2 Environmental Protection Plans (EPP) Section 4.2 to incorporate the revised terms arid conditions (T&Cs) of the Incidental Take Statement (ITS) included in the currently applicable Biological Opinion (Reference 1) issued by the National Marine Fisheries Service (NMFS) on March 24, 2016.

By email dated June 28, 2016 (Reference 3), the NRC Staff requested additional information and clarification to complete its review of the LAR. The enclosure to this letter provides the detailed response to the request for additional information.

The information provided in this submittal does not impact the 10 CFR 50.92 evaluation of"No Sig_nificant Hazards Consideration" previously provided in FPL letter L-2016-072.

This letter makes no new commitments or changes to existing commitments.

Florida Power &. Light Company 6501 S. Ocean Drive, Jensen Beach, FL 34957

L-2016-153 10 CFR 50.90 If you should have any questions regarding this application, please contact Michael Snyder, Licensing Manager, at 772-467-7036.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on August If, 2016.

Respectfully submitted,

£b.4'~1L&~

Christopher R. Costanzo Site Vice President St. Lucie Plant CRC/rcs

Enclosure:

St. Lucie 2016 Biological Opinion LAR RAI Response cc: Ms. Cindy Becker, Florida Department of Health USNRC Regional Administrator, Region II NRG Project Manager USNRC Senior Resident Inspector, St. Lucie Units 1 and 2

L-2016-153 10 CFR 50.90 Enclosure Page 1 of 3 Enclosure St. Lucie 2016 Biological Opinion LAR RAI Response Response to Request for Additional Information Regarding License Amendment Request for Biological Opinion License Changes

Background

As part of its National Environmental Policy Act (NEPA) review, the NRG staff must evaluate both the direct and indirect impacts of the proposed amendments. One potential indirect impact of the proposed amendments is that FPL will design, test, construct, and implement turtle excluder devices for the St. Lucie intake pipe velocity caps in accordance with Term and Condition 1 of Reasonable and Prudent Measure 1 of the National Marine Fisheries Service's (NMFS) March 24, 2016, biological opinion (Reference 1: ADAMS Accession No. ML16084A616). The following RAls a*re related to the implementation of the excluder devices in order to assist the NRG staff in assessing the environmental impacts of the proposed amendments:

RAl-MF7661/2-RERP-O1 RAl-MF7661/2-RERP-02 RAl-MF7661 /2-RERP-03 RAl-MF7661 /2-RERP-04

L-2016-153 10 CFR 50.90 Enclosure Page 2 of 3 RAl-MF7661/2-RERP-01:

Describe the potential non-radiological environmental impacts of. testing, constructing, and implementing the excluder devices. Include such potential impacts as those to water resources during testing and constructing, such as any disruption or other impacts to aquatic biota and habitats due to possible sediment disturbance and turbidity, and disruption to land or terrestrial biota and habitat, and the effects of air emissions for construction equipment.

FPL Response:

The excluder devices will be installed within the boundaries of the existing concrete velocity cap structures located approximately 1500 feet offshore. No dredging, sediment disturbance, or construction on the ocean floor in the area around the velocity cap will be required. Some localized cleaning to remove marine growth on the concrete surfaces of the velocity cap may be required for the attachment of the excluder devices to the velocity caps. There is a potential for some turbidity caused by the removal of the marine growth that will be controlled and monitored in accordance with environmental permit requirements. The excluder devices will be prefabricated off-site, and will only require limited construction equipment for the cleaning and attachment of the excluder device to the velocity cap structure. Outside of the minor marine growth removal, there is no anticipated disruption to land or terrestrial biota and habitat.

RAl-MF7661/2-RERP-02:

List and describe any State or Federal permits that will be required to test or construct the excluder devices.

FPL Response:

1. National Marine Fisheries Service (NMFS) biological opinion pursuant to section 7(a)(2) and the conservation review pursuant to section 7(a)(1) of the Endangered Species Act, as amended (ESA; 16 U.S.C. 1536(a)(2)), Dated March 24, 2016.

2. Florida Fish and Wildlife Conservation Commission marine turtle permit (MTP-16-125) includes provision for the ,testing of the excluder device.

3. After the completion of design and testing and prior to construction, additional Federal and State permits will be requested to support installation of the excluder. These are expected to include a US Army Corps of Engineers Nationwide Permit (NWP) Number 3 and Florida Department of Environmental Protection (FDEP) Environmental Resource Permit.

L-2016-153 10 CFR 50.90 Enclosure Page 3 of 3 RAl-MF7661/2-RERP-03:

Will the testing or construction of the excluder devices require any physical changes to systems, structures, or components intended for the prevention of accidents? If so, please describe these changes.

FPL Response:

No. The excluder devices will be attached to the Ocean Intake Velocity Caps which are part of the Ocean Intake Cooling Water System. The velocity caps and associated functions are Not Safety Related (NSR).

RAl-MF7661/2-RERP-04:

Will any aspects of the testing or construction of the excluder devices require NRG approval? If so, please explain.

FPL Response:

The 2016 Biological Opinion (Reference 1) includes a requirement for FPL to consult and coordinate with the NMFS and NRG on the designs and test results before beginning inwater construction. The design for the excluder devices requires NMFS approval before installation at the velocity caps.

Beyond the consultation and coordination required by the 2016 Biological Opinion, it is not anticipated that prior NRG approval will be required for any aspects of the testing or construction of the excluder devices. The proposed plant change to add turtle excluder devices to the Ocean Intake Velocity Caps will be processed in accordance with 10 CFR 50.59 (Changes, tests and experiments) and 10 CFR 72.48 (independent spent fuel storage installation - Changes, tests, and experiments) requirements. If during the completion of the design and testing of the excluder device it is determined that prior NRG approval is required, a license amendment will be requested under 10 CFR 50.90 (Application for amendment of license, construction permit, or early site permit).