ML17345B274

Forwards Comparative Summary for Radiological Environ Monitoring Program Per NUREG-0472 & Pages to Revised Radiological Effluent Tech Specs,Per 830829 Meeting Commitment

ML17345B274
Person / Time
Site:	Turkey Point
Issue date:	09/26/1983
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML17345B275	List: ML17345B274 ML17345B276
References
RTR-NUREG-0472, RTR-NUREG-472 L-83-499, NUDOCS 8309300134
Download: ML17345B274 (26)

Text

REGULATOR'/FORMATION DISTRIBUTION -M ('RIBS)

AGCESSlON NBR; 8309300134 DOC ~ DA'TE 83/09/26 NOTARIZED ~ NO DOCKET FACIL'50 250 Turkey Point Pl ant r Uni t 3P F or'i de 'Power'nd Li'ght IC 1 05000250 50-251 Turkey Point Plantr Unit 4r Florida Power and Light C -05000251 AUTH',NAHE- AUTHOR AF F ILIATION UHRIGg R E~ ~ Flor ida 'Power L Light Co.

'RECIP NAME

~ RECIPIENT AFFILIATION EISENHUTrDBG ~ Division of Licensing

SUBJECT:

Forwards comparative summary for -I adiological environ moni.tor ing program;per NUREG, 0472 8 pages to revised radiological effluent Tech Specs<per 830'829=- meeting commitment, DISTRIBUTION 'CODE: A0090 COPIES 'RECEIVED:LTR .J ENCL r SIZEI IAp(.~.

TITLE: OR/Licensing Submi'ttal:'Appendix I NOTES:

RECIPIENT <<COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAHE- LTLTR ENCL NRR ORB1 BC 01 ~ 7 7 INTERNALS ELD/HDS4 1 0 NRR/DL/DRAB 1 0 I/AEB 19'RR/DS 1 0 / ETB 08

'04 1 1 NRR/DSI/RAB 10 1 1 EG L 1 1 iRGN2 1 1 EXTERNAL:'CRS 11 6 6 L'PDR 03 1 1 NRC .PDR 02" 1 1 NSIC 05 1 1 NTIS 1 1 TOTAL NUMBER OF COPIES REQU'IRED9 LTTR 24 ENCL 21

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FLORIDA POWER & LIGHT COMPANY September 26, 1983 L-83-499 Office of Nuclear Reactor Regulation Attention: Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Eisenhut:

Re: Turkey Point Units 3 8 4 Docket Nos. 50-250, 50-251 Radiological Effluent Technical S ecifications Your Messrs. C; Willis and C. Miller met with our staff on August 29, 1983 to review our submittal of Radiological Effluent Technical Specifications.

Following the meeting we committed to provide:

1) The pages of our previous submittal containing the agreed upon changes;

2) The bases for our Radiological Environmental Monitoring Program, in comparison with the program guidance provided in NUREG 0472.

A preliminary table from the ODCM showing our selected sample locations is also attached to assist you in evaluating the Radiological Environmental Monitoring Program.

'lease find items 1) and 2) attached. The Technical Specification pages are provided as agreed upon with a few very minor exceptions (i .e., replacement of "SPING-4" with generic descri ption, removal of charcoal adsorber from definitions since Turkey does not use same, and changing "Containment Purge" to PURGING and VENTING, for format consistency.)

Very truly yours, Robert E. Uhrig Vice President Advanced Systems 8 Technology REU/JEM/js Attachments cc: J. P. O'Reilly, Region II Harold F. Rei s, Esquire 8309300l34 83092b PDR ADGCK 05000250 P PDR PEOPLE... SERVING PEOPLE

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TURKEY POINT UNIT NOS. 3 5 4 RAD IOLOG ICAL ENVIRONMENTAL MONITORING SAMPLE SELECTIONS (TABLE 4.12-1)

The objective of the proposed Turkey Point Radiological Environmental Monitoring Program is to provide measurenents of radiation and of radioactive materials in those exposure pathways and for those radionucl ides that lead to the highest potential radiation exposures of members of the public resulting from the station operation and to supplement the radiological effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environnental exposure pathways.

On July 11, 1983, FPL submitted a proposed amendment to the Turkey Point Unit Nos. 3 5 4 Technical Specifications (L83-402) which includes a Radiological Environmental Monitoring Program that meets this objective and was prepared using guidance issued by NRC.

Radiological environmental monitoring for the Turkey Point Plant is conducted by the Florida Department of Health and Rehabilitative Services, Environmental Radiation Control Laboratory. The monitoring program has been essentially unchanged since September, 1973. Since that time numerous environmental monitoring samples have been collected and analyzed. To date, there has been no indication that operation of the Turkey Point facility is contributing.

significantly to the dose to any member of the public. In consideration of this significant data base and the NRC sample selection criteria, FPL has determined that some of the samples currently required by Turkey Point Techni cal Speci f i ca ti ons a re no 1 onger necessa ry.

The basis for FPL's proposed enviroanental monitoring program is as follows:

Direct Radiation Turkey Point 3 8 4 Technical Specifications require direct radiation measurements (TLD) at 9 locations with a collection frequency of monthly.

The proposed monitoring program increases the number of surveil lance locations to 21. Sample collection frequency is quarterly; however, these TLO's may be retrieved and analyzed at any time if there is a need. The proposed locations correspond to the "Ring" TLD's which have been deployed around the Turkey Point Plant by Florida 'Department of Health and Rehabilitative Services.

Locations are specified in the Turkey Point ODCM.

NUREG 0472 specifies about 40 locations to be monitored. Since NUREG U472 is a generic document, it applies to inland plants as well as coastal plants.

FPL's Turkey Point Plant is situa'ted along the shore of Biscayne Bay. The only land areas east (5 - 8 miles) of the facility are a series of offshore islands, the largest of which is Elliott Key. These islands are undeveloped. It is estimated there may be approximately 60 part time residents on the islands (FSAR 2.1). It is also to be noted that these islands are located in sectors of least prevalent wind direction (FSAR 2.6).

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FPL has concluded that the 21 Direct Radiation Monitoring locations which we have proposed meet the intent of NUREG 0472.

Airborne The proposed monitoring locations (5) were selected based upon the criteria contained in NUREG 0472. Since there are existing stations at Turkey Point, the proposed locations were selected from existing sample locations that most closely matched the criteria. The locations selected were:

l. 3 samples fran close to 3 site boundary locations (in different sectors) of the highest calculated annual average ground-level 0/g.

a. Homestead Bayfront Park (T51) - NNW

b. Entrance Road (T58) -NW

c. Boy Scout Camp (T72) - WSW

2. 1 sample from the vicinity of a community having the highest cal culated annual average ground-level 0/g.

a. The community is the Homestead Air Force Base (T57) - NW

3. 1 sample from a control location 15 - 30 km distance and in the least prevalent wind direction.

a. The least prevalent wind direction is over the water. The existing control location in tliami (T64) vas chosen as suitable for the control location.

Each of the above sample locations will be continuously sampled for particulates and iodines. The locations for the above samples are specified in the Turkey Point ODCN.

In addition to particulate and iodine monitoring, the current Technical Specifications specify sampling of precipitation. Based upon the significant data base associated with sampling precipitation at Turkey Point, FPL could find no reason to continue such surveillance.

FPL has concluded that the proposed airborne monitoring program meets the intent of NUREG Q472.

Wa terborne Circulating water and intake cooling water for the Turkey Point facility ccme frcm an on-site closed cooling canal system which ccmpletely surrounds the facility (FSAR 2.1). Liquid effluents are directed to the closed system.

The closed cooling canal is highly saline and is, therefore, unfit as a direct source for-irrigation or consumption. It is also not used for recreation.

Under normal conditions the hydraulic gradient causes groundwater to move slowly towards the east (FSAR 2.10). The nearest wells containing water sufficiently fresh for irrigation purposes are about 3 1/2 miles from the

4l site. Near ccmmunity drinking waters are obtained from well fields in the vicinity of Nomestead, approximately 10 miles away.

The proposed sample locations for the Turkey Point waterborne samples are east (T42) and southeast (T81) of the closed cooling system, at locations beyond the site boundary in the direction of the nodal hydraulic gradient. The control location (T67) is sufficiently beyond any influence from the plant.

These locations are specified in the Turkey Point Plant ODCH.

The current Turkey Point 3 8 4 specifications require veterborne samples that are not consistent wi th the bases of NUREG 0472 in accordance with the following criteria:

1. Salt water not used for recreation.

2. Not tapped for drinking or irrigation.

3. Hot subject to contamination frcm plant effluents.

In consideration of the above and the significant data base available from the exi sting sample program, FPL sees no reason to continue Technical Specification surveillance on samples which NUREG 0472 excludes. FPL believes, therefore, that the proposed waterborne samples meet the intent of NUREG 0472.

Ingestion Fi sh and Invertebrates As previously stated, all liquid effluents are directed into the closed cooling canal. Commercial and/or recreational fishing is prohibited in the closed cooling system. The proposed sample locations (TUl and T67) are consistent with the gradient considerations used,to select the waterborne sample point. In consideration of the no direct release pathway and historical sampling experience, no specificty has been applied to the crustacea or fish sampling requirenent. For crustacea this is consistent with the current sampling requirements which specify lobster, crab and/or shrimp. Generally the'ample type which is predominant at ttte specified locations is the blue crab. For fish, the samples that will be collected are representative of the types which wil I be caught recreationally. Locations for fish and crustacea samples are specified in. the Turkey Point Plant ODCtl.

Broad-Leaf Ve etation The proposed sample schedule implements sampling of broad-leaf vegetation grown nearest each of two different off-site locations of highest predicted annual average ground-level D/g. NUREG 0472 specifies that 3 different kinds of broad-leaf vegetation be sampled. The topography of the Turkey Point Plant is unique, however, in that the site cooprises mangrove swamps fran along the shoreline, extending inland 3 or 4 miles. Open fields extend westward frcm the edge of the swamp (FSAR 2.4). There are not very many species of broad-leaf vegetation which thrive in the Turkey Poi'nt environoent. At the locations chosen to

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meet the criteria for U/g (T40 and T41), it vas judged that only one broad-leaf sample type would be consistently available. The sample type is the Brazilian Pepper leaf. No specificity vas placed on the selected samples, however, in order not to precl'ude other types of vegetation

(~e... mangrove) if it is -found selectively availabl'e. The control location (T67) ves selected based upon availability of similar broad-leaf type. Sample locations are specified in the Turkey Point Plant UUCH.

The proposed sample locations do not include samples for milk or food products (other than broad-leaf vegetation).

No milk sampling is required based'pon the last milk animal survey which indicated there are no milk animals within 5 mil es of the Turkey Point Plant. Should milk animals be found within 5 miles during a land use census, this sample would have to be added to the program pursuant to Speci fi ca ti on 4.12. 2.

No food product sampling is specified, since water used for irrigation purposes is not influenced by plant discharges.

In consideration of the above, and the significant data base available from the existing sample program, FPL sees no reason to continue Technical'pecification surveil lance on samples not specified by NUREG 0472.

FPL has determined that the proposed ingestion monitoring samples meet the intent of NUREG 0472.

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OXN RADIOLOGICAL ENVIRONMENTAL SURVEILLANCE TURKEY POINT PLANT Key to Sample Locations Samp e Col 1 ecti on Approximate Direction Pathway Location Description Samples Collected frequency Distance (miles) Sector DIRECT RAD IATION N-1 Convoy Point TLD quarterly D IRECT RAD IATION North of Moody Dr. TLD quarterly D IRECT RAD IATION N-10 Old Cutler Rd. at TLD quarterly 12 S.W. 87th Ave.

D IRECT RADIATION NNM-1 Turkey Point TLD quarterly NNM Entrance Road 0 IRECT RAD IATION NNW-10 Burr Rd. at Hainlin TLD quarterly Hill Dr.

0 IRECT RAD IATION NM/WNM-I Turkey Point TLD quarterly Entrance Road 0 IRECT RAD IATION NW-S Dol an ' Fa rm on TLD quarterly King's Highway 0 IRECT RAD IATION NM-10 Intersection of Farm TLD quarterly 10 Life Rd. and Coconut Palm Dr.

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RADIOLOGICAL ENVIRONMENTAL SURVEILLAN.E TURKEY POINT PLANT Key to Sample Locations Sample Collection Approximate Direction Pathway Location Description Samples Collected Frequency Distance (miles) Sector D IRECT RAD IATION W/WNW-5 Palm Drive at TLD quarterly Tallahassee Rd.

DIRECT RAD IATION WNW-10 Homestead near vehicle TLD quarterly inspection station DIRECT RAD IATION W-1 On site near cooling TLD guar terly tower D IRECT RAD IATION W-10 Florida City near TLD quarterly 10 fire tower D IRECT RAD IATION WSW-10 Old Hawk missile site TLD quarterly 12 WSW south of Florida City D IRECT RAD IATION SW/SSW-1 On site near land TLD quarterly utilizaiton offices DIRECT RAD IATION SW-10 U.S. 1 south of TLD quarterly 10 Fl orida City D IRECT RAD IATION SSW/SW-5 On si te, southeast TLD Quarterly SSW corner of cooling canals

lk OX M RADIOLOG ICAL ENVIRONMENTAL SURVEILLAN:E TURKEY POINT PLANT Key to Sample Locations Samp e Collection Approximate Uirection Pathway Location Description Samples Collected frequency Distance (miles) Sector D IRECT RAD IATION SSW-10 At Card Sound Bridge TLD quarterly 10 SSW DIRECT RADIATION S-5 On site, south end of TLD quarterly cooling canals D IRECT RAD IATION S-10 Card Sound Rd. at TLD quarterly 10 Steamboat Creek DIRECT RADIATION SSE/S-1 Turtl e Point TLD quarterly SSE D IRECT RAD IATION SSE-10 Ocean Reef TLD quarterly SSE AIRBORNE T51 Homestead Bayfront Radioiodine Weekly Park and particulates AIRBORNE T57 Tree Nursery Radi oi odi ne Weekly 316th Street and particulates AIRBORNE T58 Turkey Point Radi oi odi ne Weekly Entrance Rd. and particulates

i OX M RADIOLOGICAL ENVIRONMENTAL SURVEILLACE TURKE Y PO I NT P LANT Key to Sample Locations Samp e Col l ect i on Ap proximate Direction Pathway Locati on De seri pti on Sampl es Col 1 ected Frequency Di stance (mi 1 es) Sector AIRBORNE T64* Natoma Substation Radioiodine Weekly 22 NNE and parti culates AIRBORNE T.72 Tur key Po i nt Boy Radi oi odi ne Weekly WSW Scout Camp and particul ates WATERBORNE T42 Biscayne Bay, at Surface water Monthly Tur key Point Sediment frcm Semi-shoreline annually WATERBORNE T67* Bi scayne Bay, Surface water Monthly 13-18 N, NNE vicinity of Cutler Plant, north Sediment frcm Semi-to Matheson Hammock shoreline annually Park WATERBORNE T81 Card Sound, near Surface water Monthly mouth of old di scharge canal Sediment fran Semi-shoreline annually

• Denotes control sample.

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ODC M RADIOLOGICAL ENVIRONMENTAL SURVEILLACE TURKEY POINT PLANT Key to Sample Locations Sample Col l ection Approximate Direction Pathway L'ocation Description Samples Collected Frequency Distance (miles) Sector FOOD PRODUCTS T67* Biscayne Bay, vicinity C rustacea Semi- 13-18 of Cutler Plant north annually to Matheson Hammock Park Fish Semi-annually FOOD PRODUCTS T81 Card Sound, vicinity Crustacea Semi-of Turkey Point annually Faci 1 i ty Fish Semi-annually FOOD PRODUCTS T40 South of Palm Dr. Broad leaf Monthly on SW 117th St. vegetation extension FOOD PRODKTS T41 Palm Dr. West of old Broad leaf Monthly missile site near vegetation the site boundary FOOD PRODXTS T67 Near Biscayne Bay, Broad leaf Monthly 13-18 H, HHE vicinity of Cutler vegetation Plant north to Matheson Hammock Park

• Denotes Control Sample.

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