ML18088A948

Proposed Environmental Technical Specifications for St. Lucie Unit No. 1

ML18088A948
Person / Time
Site:	Saint Lucie
Issue date:	09/02/1975
From:	Robert E. Uhrig Florida Power & Light Co
To:	Muller D Office of Nuclear Reactor Regulation
References
Download: ML18088A948 (17)

Text

,e NRC DISTRIBUTION FOR PART 50 DOCKET MATERIAL (TEMPORARY FORM)

CONTROL NO:

F I LE'NVIRO FRQM: Florida Power

& Light C Miami, Fla.

33101 R.E Uhri

~ DATE OF DOC 9-2-75 DATE REC'D LTR 9-5-75 TW)(

RPT OTHE R TO:

Mr. Daniel R. Muller CLASS UNCLASS PROPINFO XXX ORIG 1 signed INPUT CC OTHER NO CYS REC'D 1

SENTNRC PDR SENT LOCAL PDR XX DOCKET NO:

50-335 DESCRIPTION:

Ltr re.our 8-15-75 ltr...

furnishing addi info to Enviro Tech Specss for St. Lucie Unit 1 Plant....

ENCLOSURES:

PLANT NAME:

St. Lucie Unit 1 FOR ACTION/INFORMATION DHL 9-10-75 BUTLER (L)

W/ Copies, CLARK (L)

W/ Copies

%'ARg (L)

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DEYOUNG (L)

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GOLLER (L) (Ltr)

P. COLLINS DENISE EG OPR ILE 8E REGION (2)

MIPC TECH REVIEW SCHROEDER MACCARY KNIGHT PAW LICK I SHAO STELLO HOUSTON NOVAK ROSS POLITO EDESCO QtrCOLLINS LAINAS ENAROYA OLLMER.

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DUNCAN A/T IND-BRAITMAN SALTZMAN MELTZ PLANS MCDONALD CHAPMAN DUBE (Ltr)

E. COUPE PETERSON HARTFI EL'D (2)

KLECKER EISENHUT WlGG INTON EXTERNALDISTRIBUTION 4 LOCALPDR F" Pierce Fla ~ ~

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P 0 BOX 013100'IAMI'LORIDA3310'I Regulatortj Docket'i Ol c~P 6

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'v Mr. Daniel R. Muller, Assistant Director

'or Environmental Projects Division o'f Reactor Licensing Office of Nuclear Reactor Regulation U.

S. Nuclear Regulatory Commission Washington, D.

C.

20555

Dear Mr. Muller:

FLORIDA POWER 5 LIGHT COMPANY September 2,

1975 L-75-421 I

~,

e 8 ggjjp Gp LP Re:

Proposed Environmental Technical Specifications for St. Lucie Unit No.

1 Docket No. 50-335 Your letter of August 15, 1975, transmitted to Florida Power 6

Light Company the environmental technical specifications which your staff proposes.

to incorporate as Appendix B into the Oper-ating License for St. Lucie Unit No.

1.

Overall, the cooperation with members of your staff and the resultant technical specifications have been quite satisfactory.

There were however, some differences of opinion between the Applicant and members of your staff which were not resolvable to our satisfaction before issuance of these technical specifications.

Since amendment of the Operating License to effect technical specification changes can be a time-consuming

process, and since we would be operating under unacceptable con-ditions in the interim, it is in our best interest to develop a

set of technical specifications which we can live with before they have the force and effect of law following incorporation into the Operating License.

Therefore, having exhausted the avenues towards resolution of these differencEB with your staff, we look to you for favorable disposition of what we believe to be valid positions.

First of all, I take this opportunity to forward information which

'he proposed environmental technical specifications (ETS) requested by September 12, 1975.

In Table 3.2-1 at Station No. H40, please

'dd the following:

HELPING BUILD FLORIDA

'+C 1

0 1

A

Mr. Daniel R. Muller September 2,

1975 DESCRIPTION BEARING

'ISTANCE Davis Dairy, Military Trail, west of Boynton

Beach, Palm Beach County 1720 89.700 km (55.77 mi)

In table 3.2.2, Sheet 3, Item 5.1, for control location un'der the column labelled "Criteria and Sampling Locations," the entry should

read, "1 location, 55.77 mi south of the plant, Palm Beach County:

H40 (Control)."

Next, in reviewing the proposed set of ETS, a number of items requiring clarification or simple corrections were uncovered.

These are as follows:

Section 2.1.1, Monitorin Re uirement Thi;s section pres'ently states

that, "A continuous. temperature measuring system shal'1 be installed in the discharge canal at mid-depth."

We believe 'tha't thi;s location is too restrictive.

It would be 'better'tated as "...in the discharge canal at a

location not les's 'than 2 feet below 'the 'surface 'of the water and not les's than 2 feet above "the 'bottom of the canal."

Section 2.1.2, Monitorin'e uirements Change second sentence to read, "The system's accuracy shall be'+

2 F."

Se'c'tion 2'.2'.1','

ec'i'fi:cation In the first sentence, change,"terminis" to "ter'minus."

The last sentence should be changed to read, "Chlorine 'shall not be 'added for more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day."

As the sentence presently reads, it could be interpreted to'ean tha't we'ust add chlorine for less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day whether'e need to or not..

Section 2.4.3.a.(1),

S ecification The second equation should read "0.33 (QT (K +1.18')

< 1" Table 2.'4-5, Delete the extraneous set of parentheses under "Reactor Containment Building".

Item should read

"(when'ever there is flow to Plant Vent)."

Footnote "a" should also be applied to "Reactor Containment Building" and "Radwaste Area."

P

(\\

Mr. Daniel'.

uller September 2,

1975 Section 3.1.A.6, S ecification In the second paragraph, last sentence, the 'accuracy should be "+2 F" in order to be cons.istent with that stated above.

In tEe third paragraph,'he Section referred to should be ff2 1 1

ff Table 3.2-1, Station H10 The entry under the column labelled "Vector Sampled" should read "Direct" vice "Direction."

~3:2-.1 Station H12 was inadvertently left off in your reproduction of our submittal.

Fi ure '3.2-2 Page number was inadverteritly left off. It should be page 1 0 ~

Table 3. 2. 2, Sheet 1

In item 1.2, under the column labelled "Type and Frequency of Analysis", delete the word "by" in front of the word "exposure".

Table 3.2.2, Sheet' In items 5.2.1 and 5.2.2, under the words "Harvest Time",

under'he column labelled "Collection Frequency,"

add

"(Annual)."

Sect'ion 5.6.l.a Add the following seritences3 after the first sentence "In the'vent that some results are 'not available wi;thin the 90-day period, the report shall be submitted noting and explaining the missing results.

The missing data shall be submitted as soon as possible in a supplementary rep'ort."

Se'ction '5.6.1.b Change the first sentence of the second paragraph

'to read, "Results of all radiological environmental samples taken shall be summarized on an annual basis in a format similar to that indicated in Table 5.6.1-F."

Thi's will serve to make 'the language of thi.'s sentence consistent m.'th 'that-found in the sections which 'follow.

We

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I Mr. Daniel R.

lier September 2,

1975 Table 5.6.1-F Table designation was inadvertently left off in your re-production.

Section 5.7.l.a The section referred to should read, "5.3.3.F.5" Third, there 'are two items which our review has uncovered which require corrective action not of a simple nature and which have not been brought to the attention of your staff.

I take thi*s vehicle as a means of so doing:

Section 2.4.4.b The requirement for continuous measuring and recording of the flow rate of gaseous releases should be deleted.

The plant vent and the fuel handling building pres'ently have no provision for continuous monitoring and recording of flow rate because of the sampling phi:losophy which was to be followed.

Gaseous releases from both points are contin-uously monitored and recorded for activity.

These monitors are set to alarm at the proper'imit with the, maximum-design flow rate occurring, i.e.', the 'sampling flow rate is set'o be isokinetic at the maximum ventilation flow.

Thus, any flow rate les's than maximum will res'ult in a conservative reading on the radiation monitor, and no flow indicator is necessary.

Section 2.4.4.c This specification conflicts with 2 other specifications and should therefore be deleted.

This specification requires the gross activity monitor, the iodine collection device and the particulate. collection device to be operational during gaseous releases from the primary system waste gas holdup system (the waste gas decay tanks).

Gaseous wastes from the gas decay tanks are routed to and released from the plant vent.

The plant vent monitor contains the iodine and particulate collection devices.

Specification 2.4.3 and Specification 2.4.4.b allow the activity monitor (plant vent monitor) to be inoperable with on-going releases for up to 7 days.

Since the 'iodine and particulate 'collection devices are located in the plant vent monitor, these 'provisions would also apply to them.

Finally, there remain those specifications on which FPL and your staff could not reach agreement.

Having presented our positions to your staff, we now present them to you, as follows, in the expectation tha't they will be resolved to our satisfaction:

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. gr. Daniel R. Muller Section 2.1.2, Monitorin Re uiremen'ts As presently stated in the ETS the hT across the condenser must be determined once per hour while the unit is in operation.

We believe that this is an unreasonable requirement and would propose that the aT across the condenser be determined once per 8-hour shift.

As the specification is presently stated, on a monthly basis, the typical auditing frequency of the NRC Office of Inspection and Enforcement, the operators'ogs would be required to contain 720 entries, for a 30-day month with no outages, of this parameter.

If conditions in the control room are such that the operator is occupied and therefore unable to obtain and record this information for even one of these entries, the unit would then be in violation of its technical specifica-tions.

The specification itself states

that, under specified conditions, "the condenser temperature rise shall not exceed 35 F for greater than a 72-hour period."

Determination of the condenser's tT on a once 'per 8-hour basis would allow more than ample time to note the'"excessive condition and to take measures to bring the 'hT within acceptable limits withi'n the 72-hour time frame.'ection 2.2.1, S e'c'ification The specification presently limits Total Residual Chlorine to O.l mg/1 at the terminus of the discharge canal.

Thi.'s limita-tion is in agreement with 'the existing NPDES permit for St. Lucie Unit No.

1.

We wish "to note, for your information, that steps are being taken to change 'the NPDES permit limitation to 0.2 mg/1, and that we "will reques't a technical specification change 'once 'our change 'of the'PDES permit is 'completed.

Table '2'..4-1 As pres'ently formed, the table requires a monthly sample and monthly and quarterly composite samples of the Steam Generator Blowdown.

We wish to apply Footnote 4, which requires such sampling only when the gross -activity in the 'secondary coolant

system, as required to be 'determined in Appendix A of the technical specifications, exceeds 10-5 uCi/ml, to these sampling frequencies.

The Appendix B technical specifications do not exist in a vacuum.

They are complemented by the

'ppendix A technical specifications which 'have be'en es'tablished for the purpose of furthering and maintaining health and safety.

Appendix A requires routine 'surveillance of the 'Steam Generator for the pres'ence of radioactivity and would establish whether or not monitoring of the Steam Generator Blowdown would be appropriate.

This has been recognized by the incorporation of Footnote

'4 into the ETS and its application

Mr. Daniel R. Muller September 2,

1975 to the weekly sampling frequency.

Since the routine sur-veillance required by Appendix A measures'ross

activity, any activity required to be analyzed by the 'monthly sample or the monthly and quarter'ly composite samples would be detected through 'the 'application of the Appendix A tech-nical specifications.

The requirement to conduct such sampling even when the gross activity in the '.Steam Generator does'ot exceed 10-5 uCi/ml is unnecessary.

Under'hose

'ircumstances'hen this gross activity does not exceed its limits, the collection of tanks of non-radioactive water'erves no useful purpose.'

Table '2.'4-2 The requirement for a Service Water Discharge 'Pipe Alarm and Monitor and measurement of gross activity should be deleted.

A process monitor is not required in the Service Water (Intake Cooling Water') Discharge Pipe for the following reasons (1)

The Intake Cooling Water'oes not directly cool any components containing reactor coolant (the 'primary

system, or RCS).

All heat removal is acc'omplished thru the 'intermediate Component.Cooling Water System (CCW) which has a proces's monitor wi;th 'appropriate technical specifications concerning operability and calibration, and which 'is listed on Table 2.4-2.

(2)

The only way that activity would be released to the environment via the Intake 'Cooling Water system would be thru a heat exchanger leak from the RCS to CCW then thr'u another heat exchanger leak from CCW to Intake Cooling Water.

Obviously, activity of any magnitude to cause concern would activate the alarm on the CCW monitors.

Additionally, the'ctivity would be so diluted from the double system leakage 'pathway that it is unlikely that standard process monitors would be 'able to det'ect anything but the most gross compound leakage in both sets of he'at exchangers.

In such a

highly unlikel'y event, there would already be ample plant indications, such as excessive CCW make-up, excessive RCS leakage, alarming monitors, etc.

Tab'le 2.4-5 The requirement for Steam Gener'ator Blowdown Tank Vent Alarm and Monitor should be del'eted.

This process monitor is not required for the following reasons:

1 K

Mr. Daniel R. Muller September 2,

1975 (1)

In the unlikel'y event that, in spite of the volatile steam generator che'mistry control, primary to secondary leakage 'did occur, the activity would be accounted for by:

{a) sampling the steam gener'ators to determine the activities actually going to the blowdown tank; {b)'ssigning all but a minute "amount of noble 'gases to the flash tank vent;. and (c) determining an appropriate stripping factor for iodine and particulates (typically on the 'order'f 30%) fox'hi.'s type of blowdown flash 'tank and assigning released activities accordingly; for example,'0%

to blowdown tank "vent (gaseous pathway) and 70%

to blowdown tank drains (liquid pathw'ay).

Since this method accounts for 100% of the released activity from the "Steam Generator Blowdown Tank, slight inaccuracies'n the activity rel'eases from the Steam Gener'ator Blowdown Tank Vent determined, due to charging off more or less to ei'ther" liquid or gaseous

pathway, would be acceptable since this blowdown tank will be 'used for only a short period of the plant's *opeiation, after which the Steam Generator Blowdown Treatment Facility will be available.

At thi's time there will be no such release 'point.

(2)

Since process

monitors, as used in the St. Lucie

Plant, are used primarily as trend monitors (actual released activities are determined from laboratory analyses')

thi.s monitor would be nothing more than a backup to the steam generator blowdown-monitor and the air ejector vent monitor, both of whi:ch have appropriate technical specifications.

The 'entries'extaining to the Turbine 'Gland Seal Condenser and Waste 'Evaporatox Condenser Vent should be deleted.

The gaseous effluent fr'om these 'systems is routed to the Condensei Air Ejector, which 'provides for complete monitoring.

Although it was agreed that these items would be deleted by your staff on this basis prior to the issuance of these

'ETS, their appear-ance here would indicate "ei;ther a simple 'oversight or a reversal of your staff's position.

If it is the'atter

reason, we would appeal their incorporation for the "reason that such monitoxing is provided for in the Condensex Air Ejector monitoring system, and its requirement hex'e 'would be redundant and wo'uld impose additional unnecessary financial burden upon FPL.

I wish to again commend your staff on its cooperation.

A spirit of compromise was evident on both sides throughout the 'development of

Mr. Daniel R.

uller September 2,,1975'hese technical specifications.

I wo'uld hope that further'compromise will produce a set of specifications which will be workable through-out the life of St." Lucie Unit No.

1 Yours very truly, Rober't E. Uhr'ig Vice President REU:nch cc:

Mr. Norman C.

Moseley'ack R.

Newman, Esquire

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