ML18227B282

Response to Request for Additional Information of Revised Environmental Technical Specifications, for Operating Licenses DPR-31 & DPR-41

ML18227B282
Person / Time
Site:	Turkey Point   (DPR-031, DPR-041)
Issue date:	02/28/1978
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-78-72
Download: ML18227B282 (58)

Text

O. BOX 013100, MIAMI, FL 33101 Office of Nuclear Reactor Regulation Attention:

Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commissi'on Washington, DC 20555

Dear Mr. Stello:

FLORIDAPOWER,8('LIGHT COMPANY February 28, 1978 L-78-72 Ll f /Qp 8ggge 79/8~

iSSI0+~iOgg Ig Re:

Turkey Point Plant Unit Nos.

3 and 4 Docket Nos.

50-250 and 50-251 Revisions to Environmental Technical Specifications 0 eratin Licenses DPR-31 and DPR-41 By letters dated September 7, 1976,(L-76-323) and October 5, 1976 (L-76-350)

Florida Powe~

8 Light Company (FPL) proposed changes to the Turkey Point Plant Environmental Technical Specifications (ETS).

Your staff has requested additional information which is enclosed as Attachment 1 and is incorporated in a revised version of the ETS (Attachment 2).

The revised version of the ETS (Attachment 2) includes a rewritten Section 4.0 which clearly delineates the objective, monitoring requirements, reporting requirements, and bases for each specification.

This rewritten section retains all of the requirements of Section 4.0 as.presented previously (except changes already discussed with your staff); only the format and wording are changed in order to improve ease of implementation and verification.

Attachment 2 includes bars in the right hand margin to indicate changes from our submittal of October 5,.'1976 as modified by our letter of February 23, 1977.

These changes

'have 'been reviewed,and approved by the Florida Power 5 Light Company Environmental Review 'Group an'd Company Nuclear, Review Board.,

They have determined that the changes, do not impact the environmental', assessment of the licensed facility, and do not affect the health and safety of the public.

Yours r truly, Rober,t E. Uhrig Vice President REU:NLR:sl Attachmen't cc:

J.

P. O'Rei-lly Robert Lowenstein, Esquire 0 (Q PEOPLE... SERVING PEOPLE

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. ATTACHIIENT 2 P

PEHDIX 8 TO OPEPATI t'>6 LICENSE NOS DPP.-31 AND BPP.-~1 EhVI RONI'"E'ITAL TECl.l"/I CAL SPECI F I CATIOf!~

FOR FLORIM POHER a L16HT CPIPAflY T0PKEY POINT LiP,ITS 3'p DOCKET."!OS, 50-250 ANo 50-251

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ATTACHMENT 1 Specification 3.2.2.1.2 Monitoring of cobalt, arsenic, and mercury for the past three years has shown the concentration of these heavy metals to be <0.02mg/1,

<0.00lmg/1 and

<0.0002mg/1, respectively.

These represent the minimum levels of detection for the three parameter's.

Therefore, we have deleted the monitoring requirement for these heavy metals.

Specification 4.2.4.1 The existing Turkey Point Environmental Technical Specifications require annual aerial photographs of the Turkey Point site cooling canal system using both color and color infrared photography on a seal'e of 1 to 25,000.

It is proposed that these requirements be modified so that an annual aerial photograph is required annually but need only be color infrared at a scale of 1 to 24,000.

The two primary reasons for the aerial photography requirements are:

1)

To provide a method for assessing changes in the vegetation 2)

To be able to visibly identify significant physical changes at the site It is felt that the color infrared photographs alone provide all of the information required to assess physical changes as well as changes in the vegetative community and that the color photography requirement is redundant and therefore unnecessary.

The change in scale will bring the scale of the aerial photograph in line with U,. S. Coast and Geodedic maps and will provide a scale whereby measurements can be made easily.

The existing 1 to 25,000 scale is the same as 1" = 2,083.3 feet, whereas the proposed 1 to 24,000 scale is the same as 1" = 2,000 feet.

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1. 0 DEFINITIONS Pacae 1.1 National Power Emergency

l. 2 Regional Emergency

l. 3 Reactor Emergency 1.4 Cooling System and Condenser Cooling Water System 1.5 Licensed Facilities 1.6 Frequency definitions 1.7 Closed Mode of Operations 1.8 Open Mode of Operations 1

1 1

1 1

1 1

1 2.0 ENVIRONMENTAL PROTECTION LIMXTS 2.1 2 '

2 ~ 3.

Gener'al Closed Mode 2;2. 1 Chemical Concentrations 2.2.2 Additional or Revised Limitations Open Mode 2.3.1 Discharge Temperature

2. 3. 2 Chemical Concentrations

2. 3. 3 Turbidity 2..3.4 Discharge Velocities and Volume 2.3.5 Additional or Revised Limitations 2

2 2

2 3

3 3

3 4

3 0 MONITORING RE UXREMENTS 3.1 3 2 Closed Mode 3.1.1 Temperature of Cooling Water 3.1.2 Chemical Concentrations, in Cooling Water 3.1.3 Monitoring Unit Operability Open Mode 3.2.1.

Temperature of Cooling Water 3-2-2 Chemical Concentrations in Cooling Water 3.2.3 Turbidity Control 3.2.4 Flow and Velocity of Discharge Water 3.2.5 Monitoring Unit Operability 5

5 5

5 6

6 6

7 7

7 4.0 SURVEXLLANCE AND SPECXAL STUDY PROGRAMS 4.1 Aquatic Environment 4.1.1 Closed Mode

4. l.l. 1 Aquatic Biota 4.1.1.2 Groundwater 4.1.2 Open Mode

4. 1.2. 1 Aquatic Biota 4.1.2.3..1 Epibenthic Biology 4.1..2. 1; 2 Benthic Biology 4.l. 2. 1. 3 Plankton 4.'1.2.1.4 Attached grasses, macroalgae and sponges 4.1.2. 1.5 Macroinvertebrates and fi.sh 4.1.2.1;6 Entrained Organisms 4.3 2,1.,7 Recovery in discharge areas

. 4-1.2.2 Groundwater

.,4.,1.2. 3 Water Temperature Survey 9

9 9ll 12:.

.12 12 12 13 13 13 13 14 15

il

TABLE OF CONTENTS (cont'd)

, 4. 2 Terrestrial'nvironment

4. 2. 1 Baseline Program 4.2.2 Impact at Turkey Point Site 4.2.3 Revegetation of Cooling Canal Banks

'4.2.4 Long-term Monitoring

5. 0 ADMINISTRATIVE

Pacae, 15 15 16 17 18 19 5.1 Review and'Audit 5.2, Action to be taken if a protection limit is

,exceeded.

5.3 Operating Procedures 5.4 Plant Reporting Requirements 5.4.1 Routine Reports 5.4.2 Non-Routine. Reports

'.4.2.1 Prompt Reports 5-4.2.'2 30-day Reports 5.,5 Changes 5.6 Records 'Retention

'QO 20 20 20 21.

21 21 22 22'

F

APPENDIX B RONMENTAL TECHNICAL SPECIFICA NS

1. 0 DEFINITIONS The definitions for terms used in these environmental technical specifi-cations are listed below.

"National power emergency" shall mean any event causing authorized Federal officials to require or request that Florida Power 6 Light supply electricity to points within or without the State of Florida.

1.2 "A regional emergency" shall mean any of the following occurrences within the State of Florida:

(1) a catastrophic natural disaster including hurricanes,

floods, and tidal waves; or (2) other emer-gencies declared by State, county, municipal, or Federal authori-ties during which an uninterrupted supply of electric power is vital to public health and safety.

1.3 "Reactor emergency" shall mean an unanticipated equipment malfunc-tion necessitating, prompt remedial'ction to avoid endangering the public health or safety.

1.4 "Cooling system" and "condenser cooling water system" shall include any and all waterways,

lakes, ponds,

canals, dikes, levees,

dams, barriers, or other structures,

devices, or appurtenant facilities which shall be constructed and employed to reduce the temperature of water discharged from Florida Power 6 Light's generating facilities at Turkey Point.

1.5 "Licensed facilities" shall mean Turkey Point Units No.

3 and 4.

1.6 Frequency Definitions:

Daily Not less than. 360 times per annum - interval may be not less than 12 or more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

Weekly - Not less than 48 times per annum interval may vary by 3 days

~

Monthly Not less than 12 times per annum interval may vary by 15 days.

Quarterly Not less, than 4.times per annum interval may vary by 30 days.

Semi-annually Not less than 2 times per annum interval may vary by 60 days.

Refueling at refueling intervals not. to exceed 24 months 1.7 "Closed Mode of Operations" shall mean recirculation of cooling water through the cooling canals with -no intake.from or discharge to Card Sound.

1.8 "Open Mode of Operations" shall mean operation of the cooling water system open to Card Sound.

<EB 2 8 19'

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2. 0 ENVIRONMENTAL PROTECTION LIMITS

~Ob 'ective:

To define operating limits for the condenser cooling water system for the licensed facilities to ensure that the environment is adequately protected.

2.1 GENERAL 2.1.'1 The condenser cooling water system shall be operated so as to avoid adverse effects on the environment to the fullest extent practicable, in a manner consistent with the limits and conditions of the consent Final Judgment and orders sub-sequently entered in Uni'ted States of America v. Florida Power s Light Company, Civil Action No. 70-328-CA, in the United States District.Court for the Southern District of Florida.

Flexibility of operation is permitted, consistent with considerations of health and safety, to ensure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in operations which exceed the limits set forth in this specifi-cation,, as provided below in 2.1.2 and 2. 1.3.

2.1.2 During a national power emergency, regional emergency, reac-tor emergency, or at any time when the health 'or safety of the public may be endangered by the inability of Florida Power a Light to supply electricity from any other sources available to it, the operati.ng limits shall not be exceeded except as is necessitated by the emergency..

2.1.3 Whenever, in 'accordance with subparagraphs 1.

and 2. above, Florida Power 6 Light exceeds the operating limits other-wise imposed, notification.shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone or telegraph to the Director of the Region II Office of Inspection and Enforcement according to paragraph 5.4.2.1 of these specificati.ons.

2.2 CLOSED MODE 2.2.1 CHEMICAL CONCENTRATIONS The total residual chlorine level

( including chloramines) in effluent water from the licensed facilities shall be

'controlled. such that residual chlorine i:n discharge water leaving Lake Warren shall not exceed 0.1 mg/l.

2. 2. 2 ADDITIONAL OR REVISED LIMITATIONS Additional or revised limits of operation will be set forth as-revisions occur in the mode of operation of the cooling system or as monitoring results indicate i.t to be appropriate.

FEB 2 8 1978

II

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Bases:

The Final Judgment consent decree (Civil Action No. 70-328-CA in the United States District Court for the Southern District of Florida) and the NRC's Final Environmental Statement for Turkey Point Units 3 and 4 (July 1972) set forth needs for protection of the environment related to operation of this plant.

The limits set forth above are in response to the discussions in those documents for chlorine concentrations in the cooling system.

The limits set forth are expected to provide reasonable assurance that'here will be no unacceptable adverse impacts" on the environ-ment from normal operation of the licensed facilities. It is recognized that these limits may be appropriately modified as the mode of operation of the cooling system is changed.

2..3 OPEN MODE 2.3.'1 DISCHARGE TEMPERATURE

2. 3. 1.1 Operations of licensed facilities shall be controlled so,that temperature of water discharged to Card Sound shall not exceed 95 F.

2. 3.1.2 Operation of the licensed facilities shall be conducted to the extent practicable so as to minimize the dis-

'charge water temperature rates of change.

2 '- 2 CHEMICAL CONCENTRATIONS 2.3.2.1 The total residual chlorine level (including chloramines) in effluent water from the licensed facilities shall be controlled such that residual chlorine in discharge water leaving Lake Warren shall not exceed 0.1 mg/1.

2. 3. 2.2 Data (including existing plant data) shall be. analyzed periodically (at least semiannually) to ascertain the minimum effective amount of chlorine usage necessary to achieve adequate control of fouling of cnndenser tubing and piping, and operation of the licensed faci-lities shall be conducted to the extent practicable so as not -to. exceed this minimum usage of chlorine.

2. 3.2. 3 The salinity of water which is discharged from the cooling canal

system, as measured at the outlet to Card Sound, shall not exceed 1.10 times the salini-ty of the water of Card Sound and shall not exceed 44 parts per thousand.

2. 3. 3 TURBIDITY Return waters to Card Sound shall not exceed 50 J.T.U.

above background.

<EB.2.8 lg78

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2. 3. 4 DISCHARGE VELOCITIES AND VOLUME 2'.3.4.1 The rate of discharge shall be controlled so that water willnot enter Card Sound at a velocity greater than 1.5 fps.

2.3.4.2 Water shall not be discharged at an average 24-hour rate in excess of 2150 cfs into Card Sound.

2 3.5,ADDITIONAL OR REVISED LIMITATIONS Additional or revised limits of operation will be set forth as revisions occur in the mode of operation of the cooling system or as monitoring results indicate it to be appropriate.

Bases:

The Final Judgment consent decree (Civil Action No. 70-328-CA in the United States District Court for the Southern District of Florida) and the NRC's Final Environmental Statement for Turkey Point Units 3 and 4 (July 1972)'et forth needs for pro-tection of the environment related to operation of this plant.

The limits set forth above are in response to the discussions in those documents

.'of temperature, chlorine concentrations, tur-bidity< salinity, and velocity and flow of discharge water from the cooling system.

The limits set forth are expected to provide reasonable assurance that there will be no unacceptable adverse impacts on the environment from normal operation of the licensed facilities. It is: recognized that these limits may be appropriate-ly modified as the mode of operation of the cooling system is changed'.

FED 28 >g78

3 0 MONITORING REOUIREMENTS

~Ob 'ective:

To verify the operating conditions of the cooling system and define monitoring and surveil3.ance related to the cooling system and effluents discharged from the licensed facilities.

3. 1 CLOSED MODE 3 l. 1 TEMPERATURE OF COOLING WATER Temperatures of cooling water used in the licensed facilities shall be measured at the point of intake, and at the outlet end of Lake Warren, not less often than at hourly intervals.

The sensors should repre-sent the mean canal temperatures to'.+ 0. 5 F.

3.1.2 CHEMICAL CONCENTRATIONS IN COOLING WATER 3.1.2.1 Prior.to leaving Lake Warren measurements on cooling water from the licensed facilities shall be made 1.

Not less often than at weekly. intervals for:

(a) pH +'O.l (b) dissolved oxygen (D.O.) + 0.2 ppm (c) salinity + 1 ppt (d) total residual chlorine (free and combined forms) at time of maximum concentration, i.e.

during a chlorination period. If no chlorina-tion's:being conducted, this requirement does not apply.

2.

Monthly for:

(a)

COD (b)

Copper, Zinc 3.1.2.2 Records shall be maintained of additions of chlorine and all other. chemicals from the licensed facilities to. the water pumped through the licensed facilities.

3 3 MONITORING UNIT OPERABILITY Monitoring units for temperature and chemistry shall be calibrated and maintained operable in a practicable manner.

When equipment malfunctions occur, immediate action shall be taken to return the units to operation.

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Bases:

The monitoring program, as set forth will provide information to allow for a reasonable determination of the quality of water

'ithin the cooling system and of compliance with the limits set forth. It is recognized that these limits may be appropriately modified as the mode of operation of the cooling system is changed.

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3. 2 OPEN MODE 3.2.1 TEMPERATURE OF COOLING WATER Temperatures of cooling water used in the licensed facili-ties shall be measured at the point of intake, at the point of discharge from the Card Sound Canal and at the outlet end of Lake Warren, not'less often than at hourly intervals.

The sensors should represent the mean canal temperatures to

+ 0 5oF 3.2.2 CHEMICAL CONCENTRATIONS IN COOLING WATER 3.2.2.1 At the intake to the licensed facilities for water from Biscayne Bay measurements shall be made on intake water:

1.

Not less often than at daily intervals for:

dissolved oxygen (D.O.) + 0.2 ppm 2.

Monthly for:

3.2.2.2 Cu, Zn and ammonia (NH3)

Prior to leaving Lake Warren measurements on cooling water from the licensed facilities shall be made 1.-

Not less often than at daily intervals for:

(a) pH + 0.1

(b) 'dissolved oxygen (D.O.) + 0.2 ppm (c) salinity + 1 ppt 2.

Weekly for (a) total residual chlorine (free.and combined forms)

at'time of maximum concentration, i.e. during a chlorination period. If no chlorination is being conducted, this requirement. does not apply.

(b) ammonia (NH3)

(c) biological oxygen demand and chemical oxygen demand (BOD and COD)

.E) 28>SN

3.

Monthly for Cu, Zn 3.2.2;3 At mouth of Card Sound Canal measurements on'discharged water shall be made:

1.

Not less often than at intervals of three times daily at time intervals as nearly equal as practicable for:

,(a) salinity + 1 ppt (b) dissolved oxygen (D.O.)

+ 0.2 ppm 2..Weekly at'ow slack tide on a weekday for:

(a) suspended solids (b) dissolved and particulate organic carbon (c)

" total residual chlorine (free and combined forms)

(d)

COD, BOD and ammonia (NH3)

(e) pH + 0.1 3.2.2.4 Records shall be maintained of additions of chlorine and all other chemicals from the licensed facilities to the water pumped through the licensed facilities.

3. 2. 3 TURBIDITY CONTROL At the 'mouth of Card Sound Canal measurements on discharged water shall be made not less often than three times daily at time intervals as nearly equal as practicable for turbidity except when actions other than normal system operations may be expected to result in increased turbidity, in which cir-

. cumstance,measurements shall be done at hourly intervals.

3.2.4 PLOW AND VELOCITY OF DISCHARGE WATER Flow and velocity of cooling system discharges from Card Sound Canal shall be measured not less often than at hourly intervals.

3. 2. 5 MONITORING UNIT OPERABILITY Monitoring units for temperature, chemistry, flow and velocity shall be calibrated and maintained operable in a practicable manner.

When equipment malfunctions occur, immediate action shall be taken to return the units to operation-

4b

Bases:

The monitoring program as set forth will provide information to allow fox a reasonable determination of the quality of waters within and discharged from the cooling system and of compliance with the limits set forth. It is recognized that these limits may be appropriately modified as the mode of operation of the cooling system is changed.

4l I

0 4.0 SURVEILLANCE AND SPECIAL STUDY PROGKQIS This 'section describes, the various aquatic and terrestrial surveillance programs which assess the effect of plant operations on the environment.

4. 1 A UATIC ENVIRONIKNT'.1.1

- Closed Node The programs in this section are conducted to monitor the chemical and physical effects of,.the power plant discharge on biological communities.

The influence of

'these abiotic variables on the aquatic biota of,the cooling canal system and the. character'istics this system

'evelops will be compared to an adjacent lagoonal ecosystem for which three years of baseline data are available.

~Ob'ective The objectives of the program are:

(1) to compare the chemical and.physical para-meters of the water in,the system with those in the adjacent lagoon and to determine the ability of the cooling canal system to sup-

,port biological life; (2) to compare the chemical parameters of sediments in the canal system with those of the adjacent lagoon and determine the ability of these sediments to support biological life; and (3) to follow the biological succession that occurs in the cool'ing canal system.

e

4. 1.1. 1. 1 Plankton:

Phytoplankton and zooplankton samples

- shal'1 be collected quarterly at each of eight stations.

analyzed qualitatively and quanti-tatively for dominant genera of the community.,Biomass, chlorophyll "a" and primary productivity shall also be determined; Resul'ts shall be re-ported on a unxt/volume basxs qualitatively and quantitatively to taxonomic groups.

Biomass and life history stages shall also be determined.

Results shall be reported on a unit/volume basis.

0 4.l.l.l.2 Fish:

Samples shall be collected monthly by fish traps at the eight stations used for plankton collections.

In addition, gill nets shall be fished at stations where there are water depths of 2 meters or more.

All samples shall be analyzed for species present, their relative abundance, their life history stage, biomass and size distribution.

In the event of large, fish kills in the cooling canal system, notification shall be made, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as specified in Section 5.4.2.

4.1.1.1.3 Benthos and Substratum:

Samples shall be collected at the same eight locations as plankton and analyzed as follows:

Characteristics of the Sediment:

Samples shall be analyzed monthly for salinity and the presence of selected nutrients.

These data shall be compared with three control stations.

Microbial Activit in Sediments:

On a monthly basis, aliquots of the substratum, shall be placed in an enrichment media to determine the presence or absence of.

microorganisms responsible for nutrient turn-over of materials trapped in sediments.

Benthic Or anisms:

Samples shall be taken on a semi-annual basis to determine quali-tative and quantitative abundance of benthic infauna.

4.1.1.1.4 Recover in Dischar e Area:

Changes in grasses and macroalgae density shall be determined semiannually by sampling established quadrat stations in the mouth of Grand Canal.

Re ortin Re uiremen'ts The data obtained from the above programs (paragraphs 4.1.1.1.1 through 4.1.1.1.4) shall be analyzed and compared with pre-operational data collected, in Biscayne Bay/Card Sound to identify any biological changes that may result from operating the licensed facilities.

FED 28 ~SZa

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The data shall be further compared with the three years of baseline data on the biological characteristics of the adjacent Biscayne Bay/Card Sound ecosystem.

This evaluation shall be included in the Annual Environmental Monitoring Report (Section 5.4.1).

Bases Since the cooling canal system is operating in a closed mode, with attendant stresses,to marine organisms (heat, pressure

changes, turbulence, etc.)

and no means of external biological recruitment, monitoring the system will determine its biological stability.

The successional stage of this system can be compared to the control areas.

Due to the original once-through mode of cooling, the discharge area into Biscayne Bay was denuded of grasses.

Upon termination of this cooling mode, data on the recovery of this community is necessary.

4.l.le2 Groundwater

~Oh ective The purpose of this program is to evaluate the extent of salt water intrusion between the cooling canal system and the groundwater west of the canal system.

S ecification This progzam shall. involve monitoring of wells and surface points for temperature, water level and conductivity (salinity).

Monitoring at these locations varies as does frequency, from semiannually to weekly.'he monitoring schedule is reviewed on a semiannual basis by'FPL with consultation of the South Plorida Water Management District (SFWMD) and the U.S.G.S.

S~elD and U.S.G.S. shall determine the continued need for this monitoring program.

Re ortin Re uirements Copies of the reports prepared above shall be submitted as part of the Annual Environmental Monitoring. Report (Section 5.4.1).

Bases The long-term effects of operating a salt water cooling system on the adjacent groundwater is useful.

Monitoring the extent of salt water intrusion willprovide data on this interaction.

FE8 2 8 1976

4.1.2

~ee Mcde These programs are conducted to monitor the effluents discharged from the licensed facility when the cooling canal system is open to Card Sound.

Temperature, salinity, chemical concen-

trations, and biological flora and fauna in the area of potential impact will be sampled;

~Ob 'ective The objectives of the program are to:

(1) map'he area affected by the power plant discharge; (2) compare the planktonic; epibenthic and benthic flora and fauna of this area, with control areas; and (3) assess the operational effect of the cool'ing canal system on the physical,

chemical, and biological characteristics of Card'ound.

S ecification The aquatic biota surveillance of Card Sound shall begin within two weeks after the open mode of operation begins and shall include:

4.1.2.1.1 4.1.2.1.2 E ibenthic Biolo Four replicate samples shall be collected quarterly at each of four stations.

Collections shall be by seining, trawling, fish traps or gill nets and the samples shall be analyzed qualita-tively and quantitatively for species pre-sent (if possible),

biomass, life history stage and size distribution.

Benthic Biolo

=

Replicate benthic grab samples shall be collected quarterly at the same stations as the epibenthic samples.

Population characteristics, including taxonomic identification to genus (exception:

annelid polychaetes to family), number of individuals, and biomass shall be determined.

The data shall be analyzed to detect any significant changes in the benthic community.

Samples shall be taken to a depth of at least 20 cm, where practicable.

4.1.2.1.3 Plankton:

Phytoplankton and zooplankton samples shall be collected monthly at each of four stations.

quantitatively for the dominant genera of the community.

Biomass, chlorophyll "a", and FEH 2 6 197iz

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primary productivity shall also be determined'.

Results shall be reported on a unit/volume basis.

quantitatively to "generic levels.

Biomass and life history stages shall also be determined.

Results shall be reported on, a unit/volume basis.

4.1.2.1.4 Attached Grasses, Macroal ae and S on es:

Species, growth, recruitment, and relative health of the plant and animal community shall be determined on a quarterly basis at eight quadrat stations.off Card Sound Canal.

4.1.2.1.5 impinged on the traveling screens during three consecutive eight-hour periods twice per week at the licensed facility shall. be identified by species, size and quantity.

Xn the event of large fish kills on the travelling. screens or in the cooling canals, notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as specified in Section 5.4.2.

4. 1. 2. 1. 6 Entrained Or anisms:

Water samples, shall be collected biweekly at the licensed facilities intake and discharge, at a point partway down the Card Sound Canal and at the point of discharge into Card Sound.

Representative organisms and their numbers shall be determined and their survival at different locations shall be measured by applicable "state-of-the-art" techniques.

Results shall be compared with similar samples from control areas.

4.1.2.1.7 Recove in Dischar e Areas:

Changes in grasses and macroalgae density shall be de-termined semiannually by sampling established quadrat stations in the mouth of Grand Canal.

Re ortin Re uirements The data obtained from the above programs (paragraphs 4.1.2.1.1 through 4.1.2.1.7) shall be analyzed as they

,are collected and shall be compared with pre-operational data that have been collected.

During the open mode of operation, environmental reports shall be submitted within 30 days after each monthly period.

The NRC shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when the open mode of operation commences.

0 Bases Whenever the open mode,'is.utilized, its impact upon the biota of Biscayne Bay/Card Sound should be monitored.

These ongoing monitoring and.assessment programs may requi,re modifications.

The grasses and associated macroalgae are considered the productivity base for Biscayne Bay/Card Sound.

Monitoring this segment of the community during the open mode of operation should identify any imp'acts.

Although the effects of impingement and entrainment while in the open mode are expected to have no signi-ficant effect on the total productivity of Biscayne Bay/Card Sound, verification is needed.

Impingement and entrainment data will be analyzed on a monthly basis to expediently identify any impacts.

.In the open mode of operation, there may be wedges of, saline and warm water in direct contact with the bottom of Biscayne Bay/Card Sound.

Mobile and non-mobile components 'of the benthic community need to be monitored to determine the extent and significance of the impact.

4.1.2.2 Groundwater

~Ob 'ctive The purpose of this program is to evaluate the extent of salt water intrusion between the cooling canal system and the groundwater west of the canal system.

S ecification This program shall involve monitoring of wells and surface points for temperature, water level, and con-ductivity (salinity).

Monitoring at these locations varies as does frequency, from semiannually to weekly.

The monitoring schedule is reviewed on a semi-annual basis by FPL with consultation of the South Florida Water Management District (SFWMD) and the U.S.G.S..

SFWMD and the USGS shall determine the continued need for this monitoring program.

Re ortin Re uirements Copies of the reports prepared above shall be submitted as part of the Annual Environmental Monitoring Report (Section 5.4.1).

Bases The long-term effects of operating a salt water cooling system on the adjacent groundwater is useful.

Monitoring the extent of salt water intrusion will provide data on this interaction.

,FEB 2 8 te7u

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-4.1.2.3 Water Tem erature Surve

~Ob'ective The purpose of this survey is to map isotherms of the discharge area and determine, if possible, the effects of discharges.to Card Sound.

S ecification A water temperature survey shall, be conducted monthly in the vicinity of the Card Sound Canal discharge.

Temperatures, just below the surface shall be determined with calibrated thermocouples and recorded.

Predetermined traverses of the plume shall be made by boat.

In addition, vertical, temperature.profiles shall be taken at certain locations along the traverses.

Re oxtin Re uirements A report shall be submitted within 30 days after each monthly period.

Bases No discharges have been made to Biscayne Bay/Card Sound from the cooling canal system during the closed mode of operation.

Data on the extent and orientation of the plume will be necessary to assess the impact of the discharge.

In view of the current operation of the cooling canal system in the closedmode, the surveillance program set forth above in Section 4.1.2 shall not be performed while there is no discharge of water to Card Sound.

4. 2 'ERRESTRIAL ENVIRONMENT 4.2.1.

Baseline Pro ram

~Ob 'ctive This baseline program is to establish, through an intensive and comprehensive research

program, the biotic and abiotic factors characteristic of a South Florida terrestrial ecosystem.

This baseline data will be utilized to assess the impact of the cooling canal system.

S ecification 4.2.1.1 The species and relative composition of plant communities as a function of topography over a, 10,000 acre tract of land that includes tidal, FE8 2 8 tg?'9-

0 Ik mangrove salt marshes, fresh water wetlands and terrestrial communities shall be determined.

This shall include analyses of the.characteristics of the soil which these plants colonize (e.g.,

depth'f organic layer, pH, available nutrients, soil profile, salinity, etc.)

and shall serve as the basis for predicting conditions under which these

'lant associations will survive.

4.2.1.2 Species composition and abundance of native animals that live in association with the different plant communities and utilize them for food, shelter and bieeding, shall be determined.

Field observations and.trapping techniques shall be used to prepare lists of the species

noted, especially.

any rare or endangered

species, and shall include birds,

mammals, amphibians, reptiles, fishes and selected invertebrates.

Re ortin Re uirements A report summarizing the three years of data collected shall be submitted to the NRC by April 15, 1978.

Bases To determine the impact of constructing the cooli.'ng canal system on a South Florida ecosystem, a baseline set of data needs to be developed.

This study will determine. the chemical, physical and biological factors of an area similar in character to that disturbed when the cooling canal system was built.

4.2.2 Xmpact at Turke Point.Si:te

~Ob 'ective To compare data obtained at the Turkey Point site with data obtained at an area adjacent to the. cooling canals (Baseline Program, paragraph 4.2.1) for an impact assessment.

S ecification A study of the present and existing flora and fauna shall be conducted at the Turkey Point site to "ground-truth" aerial photographs that exist of the area prior to construction.

Results of this program shall be cor-related with the Baseline data obtained in Paragraph 4.2.1, to determine the. long-term ecological effects of construction.

FEB 28 1978

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Re ortin Re uirement The results shall be summarized and submitted to the NRC by April 1S, 1978.

Bases This technique will assess the changes of different plant communities resulting from the construction of the cooling canals.

4.2.3 Reve etation of the Coolin Canal Banks Ob'ectives The purpose of this study is to assess the floristic species that colonize the mud spoil banks and their growth

rates, created by constructing the cooling canals.

S ecification 4.2.3.1 This program shall analyze soils of the berms for pH, chloride content and selected nutrients.

Soil samples shall be taken at points (l) just above the canal water level, (2) half-way 'be-tween the water and the top of the spoil bank, and (3) from the top of the banks.

Tests to determine erosion rates in both the wet and dry season shall also be performed.

Simultaneously, a biological study shall be conducted to identify the number and species of fauna, as practicable,

'ssociated with these banks, as compared to baseline data.

The survey shall include both species that are permanent residents (e.g.,

amphibians, reptiles) and transient users (e.g.,

birds) of the habitat.

4.2.3.2 An experimental program shall be conducted to

=revegetate the canal berms using native and/or commercially useful species that will'c'olonize the spoil banks.

The rate of this revegetation effort shall be compared with the natural rate of revegetation that occurs on other berms of the system.,

Re ortin Re uirements Results of the studies in paragraph 4.2.3.1 shall be included in the Annual Environmental Monitoring Report.

The requirements under 4.2.3.2 shall be fulfilled and summarized in a report to be submitted to the NRC by April 15, 1978.

I Bases The soil analyses,. faunistic,survey, and floristic studies are needed to determine the rate and extent of recovery after., construction terminates.

These data can. also be used to assess the.total impact of the cooling canal system on the terrestrial ecosystem.

4.2;4 Lon -term Monitorin

~OB 'ective To obtain information which will help to evaluate the long-term impact of= the cooling canals.

S ecifications In conjunction with the.work described in paragraphs 4.2.1 and 4.2.3 above, long-term monit'oring will include:

4.2.4.1 Annual color infrared aerial photographs of the site at a scale of 1:24,000.

4.2.4.2 Surveillance of canal banks,to document changes in edaphic and floristic conditions, especially reinvasion by native flora such as red mangrove.

4.2.4.3 Annual,sampling of selected soil and flora west an'd south of the cooling canals to determine the impact of the cooling canal system on the surrounding vegetation.

Re ortin Re uirements Results of these programs shall be included in the Annual Environmental Monitoring Report.

Bases Since some of the effects of construction and operation of the cooling canal system will not'tabilize for many years, continued monitoring and assessment will be necessary to determine the extent and duration of the impact.

'EB 2 8 1978

Cl

-'19-5 0 ADMINISTRATIVECONTROL

~Ob 'ctive:

To describe the administrative controls and procedures necessary to implement the environmental technical specifications.

5.1 REVIEW AND AUDIT The licensee shall be responsible for the establishment, execution and review of the necessary programs to administer the Environ'-

mental Technical Specifications (ETS).

The licensee may delegate, to other organizations the work of establishing and executing portions of the ETS, but shall retain responsibility therefor.

Administrative measures should, provide.that the individual or group assigned the responsibility for auditing or otherwise verifying that an activity has been performed is inde-pendent of the individual or group directly responsible for per-forming the specific. activity.

The review function shall be per-formed by the Company Environmental Review Group (CERG), as described in the Topical Quality Assurance Report.

An audit shall be conducted at least once per year.

The audit shall include contractor operations.

The licensee shall establish organizational and administrative pzocedures that will provide for management review of items 5.1.1 thru 5.1.7 and independent audit functions for 5.1.1 and 5.1.7 below.

5.1.1 Environmental technical specifications 5.1e 2 Results of the environmental monitoring programs prior to their submittal in each Annual Environmental Monitoring Reoort.

5. 1.3 Proposed. changes to the environmental technical specifi-cations and the evaluated impact-of the change.

5.1e4 Proposed changes or modifications to plant systems or equipment and the evaluated impact which would require a change in the procedures described in 5.1.7 below, or which would affect the evaluation of the licensed facili-ties environmental impact.

5.1.5 Coordination of environmental technical specification developm'ent with the safety technical specifications to avoid conflicts and for consistency.

5.le 6 Proposed sampling, analysis, calibration and alarm check proceduzes, as specified in 5.3.1 and any other proposed procedures or changes thereto as determined by the responsible company official to affect the licensed facilities environ-mental impact.

FEB 2 8 1978

4h II 5.1.7 Investigation of all reported instances of violations of environmental technical specifications, including appropriate recommendations to prevent recurrence.

5.2 ACTION TO BE TAKEN IP A PROTECTION LIMIT IS EXCEEDED 5.2'.1 Exceeding a protection limit shall be promptly reviewed as specified in Section 5.1; 5.2.2 As specified in Section 5.4.2, a separate report for each-occurrence shall be prepared.

This report shall include an evaluation of the cause of the occurrence, a record of the corrective action taken,"

and recommendations for appropriate action to prevent or reduce the probability of a recurrence.

5.2.3 The circumstances of'the occurrence shall be reported to the NRC as specified in Section 5.4.2.

5. 3 OPERATING PROCEDURES 5.3.1 Detailed written procedures, including appliable checkoff lists and instructions, shall be prepared, approved as specified in Section 5.3.2 and adhered to for operation of all systems and components involved in carrying out the environmental monitoring program.

Procedures shall include

sampling, instrument calibration, analysis,'nd actions to be taken when limits are aporoached or exceeded.

Calibration frequencies for instruments used in performing the measurements recuired by the environmental technical specifications shall be included.

Testing, frequency o

any alarms shall be included.

These frequencies shall be determined from experience with similar instruments in similar environments and from manufacturer's technical manuals.

5.3.2 All procedures described in 5.3.1 above, and,changes

thereto, shall be reviewed and approved, as specified in Section 5.1, prior to implementation.

Temporary changes to procedures whi'ch do not change the intent of the original procedure may, be made, provided such changes are approved by two members of the company management staff.

Such changes shall be-.documented, subsequently reviewed and approved on a timely basis.

5-4 REPORTING RE UIREHENTS 5.4.1 Routine Re rts An Annual Non-Radiological Environmental Monitoring Report covering the previous twelve months operations. shall be sub-mitted to the NRC within 90 days after January 1 of each year.

FEB 2 8 l".8

0 In the event that some results are not available within the 90 day period, the xeport shall be submitted noting and

- explaining the reasons for the missing results.

The missing data shall be submitted as. soon as p'ossible in a supple-

'mental report.

These reports shall include the following:

1.

Records of monitoring requirement surveys and samples.

2.

Analysis of environmental data.

3.

Records of changes i.n suxvey procedures.

4'.

List 'of any special environmental studies related to the licensed facilities not required by the environ-mental technical. specifications.

5.

Records of any violations of the environmental technical specifications.

6.

Records of changes as described in Section 5.4.2.

5.4.2 Non-Routine Re rts A report shall be submitted to the NRC i:n the event that a protection limit is exceeded, or the occurrence of an unusual or important event associated with operation of the licensed facilities involves a significant environmental impact.

Reports shall be submitted under one of the report schedules described below.

5.4.2.1 Prompt Reports, Those events requiring promot reports shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone, telegraph, or facsimile transmission to the Director of the.Regional Office of Inspection and Enforcement and within 10 days by a

,written report to the Director o the Office of Inspection and Enforcement.

5.4.2.2 30-Day Reports Those events not requiring prompt reports shall be reported within 30 days by a written repox't to the Director of the Regional Office of Inspection and Enforcement with a copy of the Director of the Office of Inspection and Enforcement.

The reporting schedule for reports concerning limiting conditions shall be reported on the 30-day schedule.

Reports concerning unusual or important events shall be reported on the prompt schedule.

Ib If flritten 10-day and 30-.day reports and to the extent possible, the preliminary telephone, telegraph, or facsimile reports shall a).describe,

analyze, and evaluate. the occurrence, including extent and magnitude of the impact, b) describe the cause'f the occurrence and c) indicate the corrective action (including any significant changes made in procedures) taken to preclude repetition of the occurrence and to prevent similar occurrences involving similar components or systems.

The significance of an unusual or apparently important evdht with regard to environmental impact may not be obvious. or fully appreciated at the time of occurrence.

In such cases, the NRC shall be informed promptly of changes in the assess-ment of the significance of the event and a corrected report shall be submitted as expeditiously as possible.

'5.'5 CHANGES 5.5.1 Nhen a change to the plant (that affects the environmental impact evaluation contained in the Environmental Report or the Environmental Statement) or to the environmental monitoring procedures or equipment is planned, a report of the change shall be submitted to the NRC for information prior to implementation of the change.

This is not intended to preculde making changes on short notice that are significant in terms of decreasing adverse environmental impact.

However, these changes shall be promptly reported.

The report shall include an evaluation of the impact of the change for both environmental and safety considerations.

5.5.2 All documentation concerning changes or additions to per-mits and certificates required by Federal,

State, local and regional authorities for the protection of the environ-ment shall be submitted to the Director of Nuclear Reactor Regulation for information.

The submittal shall include an evaluation of the environmental impact of the change.

5'.5.3 Request for changes in environn>ental technical specifications shall 'be submitted to the Director for Nuclear Reactor Regulation for prior review and authorization.

The request shall include an evaluation of the impact of the change for Environmental considerations.

5.6 RECORDS RETENTION 5.6.1 Re'cords and logs relative to specifications contained in Section 5.0 of the environmental technical specifications shall be retained for five years except as described in 5.6.2 belo~r.

FEB 28 tepee

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C 5.6.2 All records and logs relative to the following areas shall be retained for the life of the licensed facilities.

1.

Records and drawing changes reflecting plant design modifications made to systems and equipment as des-cribed in Section 5.5.l above.

2.

Records of environmental monitoring data.

FEB 2 8 ]978

41

STATE OF FLORIDA

')

)

COUNTY OF DADE

)

ss E. A. Adomat.

being first, duly sworn, deposes and says:

That he is Executive Vice President Light Company, the Licensee herein; of Florida Power That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is:

authorized to execute the document on behalf of said Licensee.

E. A. Adomat

-Subscribed, and sworn to before me this

>ZQ day of NOTARY PUBLIC, in and for the County of Dade, State of Florida NOTARY PUBUC STATE OF FLORIDA IR LARGE MY COhLMISSIOtt FXPIRFS AUGUST 24, 1931 My commiss'on expires:

SONDED YHRIJ ttAYIIARO.SOtIDIIIG AGQ~CY

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