ML20079N220

Responses to NUMARC Survey in Support of NRC License Renewal Rulemaking

ML20079N220
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	11/11/1991
From:	FLORIDA POWER & LIGHT CO.
To:
References
RTR-NUREG-1437 AR, S, WM, NUDOCS 9111110117
Download: ML20079N220 (31)

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FPL RESPONSES 70 NUMARC INDUSTRY SURVEY LLCRHSJ RENEWAL RULEliAElHQ

! WASTE MANAGEMENT A. Spent fuel queF.tions:

1. Which of the following p_grrent techniques for at-reactor storage arc you using and how?

A. Re-racking of spent fLal B. Control rod repositioning C. Above ground dry storage D. Longer fuel burnup E ,. Other (please identify)

Response

Turkey Point - Currently, Turkey Point Units 3 and 4 have been reracked to enable operation until the end of 2ife.

St. Lucie -

The St. Lucie Unit 1 spent fuel pool has been reracked to the maximum practical extent. The St. Lucie Unit 2 spent fuel pool has been reracked and has the capacity for additional reracking. Additionally, St. Lucie Plant continues to develop fuel management plans to maximize fuel burnup levels.

2. Do you plan on cont.inuing the use of these current techniques for at-reactor storage of spent fuel during the remaining time of your operating license or do you expect to change or modify them in some way?

Response

Turkey Point - Turkey Point Units 3 and 4 will continue to use the current technique for at-reactor storage of spent fuel during the remaining time of the operating license.

St. Lucie - St. Lucie Units 1 and 2 will in the short term continue to use the current techniques for at-reactor storage; but will need to evaluate additional techniques to reach end of life.

3. Which of the following techniques for at-reactor storage do you anticinate using until of f-site spent fuel storage becomes available and how?

A. Re-racking of spent fuel B. Control rod repositioning C. Above ground dry storage D. Longer fuel burnup E. Other (please identify) l

Response

Turkey Point -

If a decision is madt .o operate the Turkey Point Units for an additional 20 years, FPL v uld consider the above ground dry storage, rod conviddauion rnd longer fuel burnup techniques for at-reac' c - .

St. Lucie -

St. Lucie is ' " ' rod consolidation and/or on-site cask stora, - , .ombination of both) for future implemel. ,

arage.

4. Will the techniques descI 'or continued at-reactor storage of spent ? . LL i -

. lifetime of the plant, including a 2.0- .

'I n 1. 4 - -

e renewal, or are you developing other - .

Response

Yec, the techniquen describw . e.. = 1t be adequate for continued at wactor sto.ng. ci a r- ' o for both Turkey Point and St. U,Nie.

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5. Do you anticipate the need to ucquite v _tional land for the storage of spent-fuel for the operating .ifetime of the plant, including a 20-year period of license renewal? If so, how much land? When would this acquisition occur? Where? (If answer is "yes", 3-4 sentences)

Response

St. Lucie and Turkey Point - No

6. Do you anticipate any additional construction activity on-site, or immediately adjacent to the power plant site, associated with the continued at-reactor storage of spent fuel for the operating lifetime of the plant, including a 20-year period of license renewal? (yes/no)

Response

St. Lucie and Turkey Point - Yes

7. If you answered yes to question 6, briefly describe this construction activity (e.g., expansion of fuel storage pool, building above ground dry stor.=ge facilities).

Response

St. Lucie and Turkey Point - Construction would be required for adding above ground storage. This construction could include a concrete pad for cask storage or a modular concrete storage system.

B. Lcw-level radioactive waste management questions:

1. Under the current scheme for LLRW disposal (i.e. LLRW Policy Amendments Act of 1985 and regional compacts) is there currently or will sufficient capacity for wastes generated during the license renewal period be available to your plant (s)? If so, what is the basis for this conclusion:

Response

St. Lucie and Turkey Point - The state of Florida is a member of the - Southeast Interstate Low Level Radioactive Waste Management Compact (Southeast Compact) which consists of eight party states. - The Southeast Compact is in the process of licensing a facility in North Carolina to serve as a low-level radioactive waste disposal facility for 20 years. The existing facility in Barnwell, South Carolina will cease operation as a regional facility on December 31, 1992. Under provisions of the Southeast Compact the Scotheast Compact Commission will continue to designate party states to host low-level radioactive waste management facilities as necessary to provide for the proper disposal of LLRW generated within the Southeast Compact. Thus, to the extent that the low-level waste ' compact process continues to function and Florida remains a party state in the Southeast Compact, FPL's facilities are assured adequate capacity for wastes generated during the license renewal period.

2. If for any reason your plant (s) is/are denied access to a licensed disposal site for a short period of time, what plans do you have for continued LLRW disposal?

Response

St. Lucie and Turkey - Point -

At the present time, waste generators in the Southeast Compact are not permitted to dispose of LLRW outside the compact region unless the waste is unacceptable for disposal in the current facility.

If St. Lucie and Turkey Point plants are denied access to a licensed disposal facility for a short period of time, sufficient capacity exists for on-site storage (see response to Question No. 7).

3. In a couple of pages, please describe the specific methods of LLRW management currently utilized by your plant. What percentage of your current LLRW (by volume) is managed by:

A. Waste compaction?

2 B. Waste segregation (through special controls or

, segregation at radiation check point)?

C. Decontamination of wastes?

D. Sorting of waste prior to shipment?

E. Other (please identify)

Response

Turkey Point - LLRW management at Turkey Point encompasses four broad categories: 1) spent resins, filter sludges, evaporator bottoms, etc.; 2) dry compressible waste, contaminated equipment, etc.; 3) irradiated components, control rods, etc.; and 4) any other waste.

Management of dry active waste (DAW) starts with prevention of unnecessary material from entering the radiation controlled ,

J area (RCA). This prevents unnecessary material from becoming contaminated and having to be disposed as LLRW. At the contaminated area boundaries, materials are segregated as re-usable or disposable. Turkey Point has made an effort to reduce the amount of disposable materials if re-usable alternatives are available. Waste materials inside the RCA are also segregated as contaminated or potentially uncontaminated. Potentially uncontaminated wastes are surveyed in accordance with NRC guidance and non-radioactive materials are segregated from the radioactive waste.

Radioactively contaminated waste materials are then segregated into incinerable/compactable and non-compactable categories.

These materials are placed in separate 20 or 40-foot land / sea containers for shipment to a waste processor for decontamination, compaction, or incineration. The waste processor ships the resulting radioactive waste to the Southeast Compact LLRW disposal facility.

Liquid waste process!.ng uses a combination of cartridge filter media, activated charcoal, and bead or powdered demineralizer resins depending on the particular liquid process stream.

When depleted, these materials are placed in large_ disposable containers, dewatered, and sent for disposal. If the material exceeds a specific activity of 1 pCi/cc, the containers are -

polyethylene high integrity containers (HICs). Otherwise, they are constructed of carbon-steel.

Other materials are managed by various means appropriate to the material.

A. Waste compaction? 3%

B. Waste segregation through special controls or segregation at radiation check point)? Not determined.

C. Decontamination of wastes? 31%

D. Sorting of wastes prior to shipment? 35%

E. Other (please identify)

Dewatered resin and filter media - 5%

Incineration - 26%

Irradiated reactor components - <1%

St. Lucie - LLRW management at St. Lucio encompasses four broad categories: 1) spent resins, filter sludges, evaporator I

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-_ _ - _mm-_.___m._ - _ _ _ _ - - _ _ _ _ _ _ , . _

bottoms, etc.; 2) dry compressible waste, contaminated equipment, etc. ; 3) irradiated camponents, control rods, etc. ;

and 4) any other waste. Management of dry active waste (DAW) starts with segregation of re-usable and disposable materials at contaminated area boundaries. St. Lucio has made an ef fort to reduce the amount of disposable materials if re-usable alternatives are available. Waste materials are then segregated ir.to compactable/incinerable and non-compactable categories. Compactable/incinerable materials are compacted in' 92-cubic-foot metal boxes and transported to a waste w *mor t'or super-compaction or incineration. Non-

+t 'e materiale are packaged in 2n-foot land / sea s and sent to a processor for decontamination. The 4 --

sors ship the resulting radioactive waste to the b.

mct LLRW disposal facility.

L2; ./ 4ssing uses a combination of cartridge filter

r powdered domineralizer resins depending on medit the po . quid process stream. When depleted, those materials a '. , placed in largo disposable containers, dewatered, and sont for disposal. If the material exceeds a specific activity of 1 pCi/cc, the containers are polyethylene high integrity containers (HICs). Otherwise, they are constructed of carbon-steel.

Other materials are managed by various means appropriate to the material.

A. Waste compaction? 50%

B. Waste segregation (through special controls or segregation at radiation check point)? Not determined.

C. Decontamination of wastes? 42%

D. Sorting of wastes prior to shipment? Not practiced 2 E. Other (please identify)

Dewatered resin and filter media - 7.5%

Irradiated reactor components - <1%

Solidified sludges and oils - <1%

4. In a couple of pages, please describe the anticinated plans for LLRW management to be utilized by your plant (s) during the -

remainder of the operating license and through the license renewal term. What percentaqe of your anticipated waste (by volume) will be managed by:

A. Waste compaction?

B. Waste segregation (through special controls or segregation at radiation check point)?

C. Decontamination of wastes?

D. Sorting of waste prior to shipment?

E. Other (please identify)

Response

Currently, no significant changes in current practices are

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anticipated during the license renewal period for St. Lucie or-Turkey, Point..

Turkey Point-A. Waste compaction? 3-5%

B.- Waste segregation (through- special controls or segregation at- radiation check point)? No chance in policy anticipated. t C. Decontamination of wastes? 30-35%

' D.. Sorting of wastes prior to shipment? 30-35%

E. Other (please identify) ,

Dewatered resin and filter media - 5-10%

Incineration - 25-30%

' Irradiated. reactor. components -: <1%

St. Lucie .j A. Waste compaction? 5%

B. . Waste- -segregation (through- special controls or segregation at radiation check point)? No chance in oolicy anticinated.

C. Decontamination of wastes? -35% .

D.. Sorting of1 wastes prior to shipment?

No chance in policv anticinated.

- E. Other-(please identify)

Dewatered resin and filter media - 10%

Incineration -- 50% -

-Irradiated reactor components - <1%

5 Do you anticipate the need to acrIuire additional land for the storage : of LLRW . for - the operating - lifetime .of the plant, including 20-year period of license renewal? If so, how.much

- land? When would this acquisition occur? Where? (If answer is-"yes", 3-4 sentences)-

Response

-At the present time,.there are no plans-to acquire additional land for storage of-LLRW for_St. Lucie.or Turkey Point.

6. To provide information on-the timing of future low-level waste streams, . if you answered yes to-question # 9, over what-periods

. of time are these activities contemplated?'

Response

St. Lucie and Turkey Point - Not Applicable

7. Do you-anticipate any additional construction activity, on-site,- or immediately adjacent to the- power -plant. site, associated with temporary LLRW storage for the operating lifetime'of the plant, including a 20-year period of license renewal?= (yes/no) 0 1.y --

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Response

Currently, St. Lucie and Turkey Point have sufficient facilities available on site to store DAW for 5 years at the current generation rate. There is also sufficient area on site to store waste from liquid waste processing in shielded containers for 5 years at the current generation rate, though implementation of these storage provisions could require some construction activity. This is the maximum length of time permitted for LLRW storage under current NRC regulations without a 10 CFR Part 30 license. However, no construction activity for additional LLRW storage capacity is anticipated at this time.

8. If you answered yes to question 7, briefly describe this construction activity (e.g. , storage areas for steam generator components or other materials exposed to reactor environment) .

Response

St. Lucie and Turkey Point - Not Applicable

9. To provide information on future low-level waste streams which may effect work force levels, exposure, and wasto compact planning, do you anticipate any major plant modifications or refurbishment that are likely to generate unusual volumer of low-level radioactive waste prior to, or during, the relicensing period for the plant? if so, please describe these activities. Also, what types of mcdificetions do you anticipate to be necessary to achieve license renewal operation through a 20-year license renewal term?

Response

At this time no major plant modifications are planned prior to or _during the relicensing period for St. Lucie or Turkey Point.

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AMATIQ_EESOURCES - ST. LUCIE PLANT

1. Post-licensing modifications and/or changes in operations of intake and/or discharge systems may have altered the effects M the power plant on aquatic resources, or may have been made r r .lfically to mitigate impacts that were not anticipated in Une design of the plant. Describe any such modifications and/or operational changes to the condenser cooling water

-intake and discharge systems since the issuance of the operating License (or Provisional Operating License).

RESPONSE

Before engaging in construction or operational activities which may significantly affect the environment, the St. Lucie plant is required to perform an environmental evaluation of such activity. (Activities are excluded from this requirement if all measurable nonradiological effects are confined to the onsite areas previously disturbed during site preparation and plant construction.) When the evaluation indicates that such activity involves an unreviewed environmental question, the St. Lucie Plant must provide a written evaluation of such activities and obtain prior approval from the NRC.

A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns (1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated in the final environraental statement (FES) as modified by staf f's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant change _in effluents or power level (in accordance with 10 CFR Part 51.56(b)(2) or (3) a matter not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which may have a significant adverse environmental impact. No modifications and/or changes of operations of the intake or discharge systems at St. Lucie Plant have been deemed to involve an unreviewed environmental question.

A review of the Company' Environmental Review Group's meeting minutes was performed to evaluate those intake and discharge system modifications which were reviewed, and which could have potentially altered the effects of the plant on aquatic resources. No intake / discharge system modifications were made which could have potentially altered the effects of the plant on aquatic resources.

Some operational changes / modifications have been made, specifically to mitigate impacts that were not fully anticipated in the design of the plant. These 1

changes / modifications to the intake cooling water systems have been made to reduce the impact of marine biofouling on the condensers. The modifications / changes include, strengthening of the intake travelling screens, installation of "clamtraps" in the condenser tubes to reduce the number of seashells lodged in the tubes, and the addition of a sodium hypochlorite system for use by both units replacing gaseous chlorine (See Response to Question 5. for discussion concerning installation of third intake pipe). Efforts are continuing to reduce the effect of marine biofouling on the St. Lucie plant intake cooling water systems.

2. Summarize and describe (or provide documentation of) any known impacts to aquatic resources (e.g., fish kills, violations of discharge permit conditions) or NPDES enforcement actions that have occurred since . issuance of the Operating License (or Provisional Operating License). How have these been resolved or changed over time? The response to this item should indicate whether impacts are ongoing or were the result of start-up problems that were subsequently resolved.

RESPONSE

l- No significant impacts to aquatic resources in the area of the l St. Lucie plant have been observed since the units have become i operational. Minor incidents involving marine organisms such i as a one-time jellyfish entrainment incident, a minor fish

! kill, as well as some fish entrainment into the plant's intake canal have occurred, but have not and are not expected in the future to result in any significant impact on area aquatic resources. There is an ongoing program to dos.1 with and mitigate the entrainment of sea turtle into the plant's intake canal. The goal of this program is to ensure that all l entrained sea turtles are returned to the ocean if their

! physical condition permits immediate return. Monitoring of I

sea turtle nesting activities-have shown no permanent impact

.from plant activities, with localized impact due to temporary

, construction activities on the beach. The sea turtle i monitoring program is under continuing surveillance by responsible Federal and State agencies which have issued permits for these activities.

Although minor violations of the plant's NPDES permit have occurred over the years since plant start-up, none have been i significant enough to warrant enforcement action by EPA or for that matter, enforcement action from the State of Florida for violation of State regulation for wastewater discharges and/or water quality impacts.

l 3. Changes to the National Pollutant Discharge Elimination System (NPDES) permit during operation of the plant could indicate whether water quality parameters were determined to have no significant impacts (and were dropped from monitoring requirements) or were subsequently raised as a water quality

issue (and were added to the monitoring requirements).

Provide a brief summary of changes (and when they occurred) to the NPDES permit for the plant since issuance of the Operating License or Provisional Operating License.

RESPONSE

Provided below are brief summaries of the changes made to the St. Lucie Plant NPDES permit during operation of the plant:

April _1989 High purity water is generated at the St. Lucie plant by carbon filtration and cation and anion exchange domineralizatior., When the carbon filter is backwashed or the domineralized resins are regenerated utilizing sulfuric acid or sodium hydroxide, the waste effluents are routed to the plant's lined neutralization basins.

Due to the homogeneous nature of the waste scream and the relatively short duration of the discharge, FPL requested that the sample type for a total suspended solids (TSS) be modifled from " composite" to " grab" with the stipulation that a sample shall consist of not less than three (3) grabs taken during the period of discharge.

The liquid radweste waste stream, NPDES serial 003, originates from various maintenance and operational activities which take place in the reactor auxiliary building. This effluent is collected in one of two 40,000 gallon tanks. Prior to sampling, a tank is isolated and thoroughly mixed for an amount of time prescribed by the Nuclear Regulatory Commission as certain radiological analyses are conducted on this stream. Due to the homogeneous nature of the waste stream, the small volu;ae , and short duration of the discharge, FPL requested that the measurement frequency for iron, cooper, and phosphorus be modified to "l/ Batch" and the sample be modified from " composite" to a " grab" so these analyses would be consistent with the TSS sampling.

December 1988 High purity water is generated at the St. Lucie Plant by a water treatment plant by way of carbon filtration and anion and cation exchange domineralization. Much of this high quality water is routed to the secondary sy tem and steam generators as makeup for the water / steam cyvit.

Ammonium hydroxide is added for pH control and hydrazine is added for oxygen removal. Undesirable contaminants such as chlorides from condenser leaks can contaminate the steam generator water. Strict operating

specifications require that suspended and dissolved solids be maintained at very low levels, therefore, to keep the contaminants at these low levels, a continuous steam generator blowdown is required. This blowdown is either recovered or routed to the discharge canal. The concentration of hydrazine in these discharges normally range from 25 ppb to 2 ppm.

During overhauls and/or refueling outages the steam generators, feedwater systems, and/or condensers may be placed in a static mode where the internal metal surfaces of these components must be protected from corrosion.

The typical method used is to fill the system with a hydrazine/amlaonia/ demineralized water solution. This solution must then be drained and discharged to the plant's discharge canal. FPL requested that these discharges, wnich normally occur approximately every eighteen months per unit, be included in the NPDES permit for the St. Lucie Power Plant.

May 1981 Section III. F. was deleted. This special condition was no longer necessary because aquatic monitoring requirements were fulfilled.

Section III. I. was deleted. This special condition was no longer necessary because Florida Power & Light company has demonstrated that compliance with thermal limitations placea on the discharge canal will assure that State and Federal thermal water quality standards are not exceeded in receiving water. Thus, further thermal monitoring was not necessary.

June 1985 FPL requested the deletion of thermal monitoring of surface water temperature in the area of the St. Lucie coding water discharge pipes.

Anril 1985 ,

FPL requested the deletion of all biotic monitoring requirements from the facility's NPDES Permit.

October 1983 Heavy rainfall at the St. Lucie Plant site has periodically resulted in an accumulation of storm water runoff in a low area. Excessive rainfall events can potentially result in crosion of a portion of the once through cooling water intake canal bank if the rainfall volume is enough to cause water to overflow from the low

a ._ -ad area into the canal. In order to prevent this potential, erosion, FPL requested that the subject permit be amended to include the use of a PVC pipe that will drain the non-equipment area stormwater from the low area directly to the intake canal.-

January 1983 Modifications pursuant to 40 CFR 122.15 (a) ( 3 ) (1) reflecting final regulations promulgated on November 19, 1982 entitled " Steam Electric Power Generating Point Sourc- Category; Effluent Limitations Guidelines" are requested as follows:

FPL requested to delete the monitoring requirements and limitations for copper and iron for Steam Cleanup System Blowdown for the St. Lucie Plant. This waste stream is equivalent to boiler blowdown at FPL fossil fueled plants.

4. An examination of time trends in the results of aquatic resources- monitoring can indicate whether impacts have increased, decreased, or remained relatively stable during operation. Describe and summarize (or provide documentation of) results of monitoring of water quality and aquatic biota (e.g., related to NPDES permits, Environmental Technical Specifications, site-specific monitoring required by federal or state agencies). What trends are apparent over time?

RESPONSE

There . have been no discernable trends -at the plant site regarding impacts on aquatic resources. Over the long-term, any impacts on aquatic resources are expected to be stable.

The plant operates its wastewater treatment systems and once-through cooling water discharger in strict compliance with State and. Federal requirements. These requirements apply to plaat effluents as well as conformance with discharges subject to State of Florida water quality standards. With regard to aquatic biota monitoring, the ongoing sea turtle monitoring program is the only routine blotic monitoring presently required by Federal or State regulatory agencies. At present, there are no apparent trends with. regard to sea turtle impacts from plant operation.

5. Summarize types and numbers (or provide documentation) of organisms entrained and impinged by the condenser cooling water system. Describe any seasonal patterns associated with entrainment and impingement. How has entrainment- and impingement changed over time?

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RESPONSE

Impingement of organisms on the traveling intake screens was discussed in the Final Environmental Statement-Construction Pormit (FES-CP). It was concluded that impingement lossen were expected to be of minor significance. Since issuance of the FES-CP, St. Lucie Unit 1 commenced operation. As part of the St. Lucie Unit 1 operating license the utility was required to monitor impingement. Between 1976 and 1978 24-hour impingement samples were taken at the St. Lucie Unit 1 intake screen during 226 days. The mean numbers of fin fish and shellfish collected per 24-hour period were 222 and 82 respectively. The mean weights per 24-hour period were 1.7 kg (3.7 lbs) and .5 kg (1.1 lbs). Principal upecies impinged at the St. Lucio Unit 1 intake were anchovy, grunt, jack, croakers, mojarra, shrimp, and blue crab. The majority of organisms were small with over 80% of the impinged fish less than or equal to 8cm (3 in) in length, and almost 100% of the impinged shrimp 4 cm (1.6 in) or less in length. Assuming continuous St. Lucie Unit 2 operation, it has been estimated that impingement rates (number per year) varied during the years of study from approximately 34,000 (1978) to 131,000 (1976) fin fish and from 26,000 (1976) to 37,000 (1978 for shellfish, on January 24, 1979 the NRC issued an amendment to the St.

Lucie Unit 1 Operating License that deleted the requirement for impingenent monitoring. The environmental impact appraisal which accompanied the amendment concluded that impingement losses due to the operation of St. Lucie Unit i represent a very insignificant portion of the numbers of fishes in the site vicinity and a very small portion of the numbers of shrimp commercially caught off Florida's east Coast.

Operation of the St. Lucie Unit 2 was expected to increase the station's impingement rate. The velocity at the opening to the existing two ocean intake structures during three intake operation was expected to be about 0.4 f t/sec and at the third intake 1 ft/sec. The third intake carries approximately 2/3 of the total flow into the intake canal. During the CP review the same volume of water through two ocean intake structures was found acceptable. With three intakes structures and pipelines the volume of water flowing through the two units is the same; however, the flow velocity through the two original ocean intake structures is reduced. Since the volume with two-unit operation was expected to double, impingement was expected to increase but probably is less than twice the annual impingement estimate calculated from the 3 years of St.

Lucie Unit 1 data. A doubling of the total weight of the mean annual impingement estimate for St. Lucie Unit 1 is less than 0.04% and 0.005% of the commercial fish and shellfish landed in either St. Lucie or Martin Counties.

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_- - - - - . . - - - - _ - .. - . - - - _~

operation.of St. Lucie _ Unit 2 with three intake pipelines will increase the impingement rate of fish and shellfish. The rate of. impingement . is -expected to . be less than ; double the rate observed with one unit operation. When compared to the local commercial fishery-landings even' a five- fold increase would be considered insignificant.

The impact of entrainment on the phytoplankton, zooplankton, and ichthyoplantkton into the. plant circulating water system was_ evaluated in the FES-Cp. It was concluded that there would be no measurable effect on the ecosystem of the adjacent oceanic waters. Since issuance- of the- FES-Cp FPL has conducted monitoring programs to assess - the losses to the -

phytoplankton, zooplankton, and ichthycplankton communities due _ to the - operation of St. Lucio Unit 1. Based on the results of the - monitoring programs for St. Lucie Unit l'and the NRC's experience in evaluating operating = data at other

. coastal facilities it was concluded that operation of St.

Lucie Unit 2 will have no detrimental. impact on the phytoplankton-and zooplankton communities. Two unit operation may increase further the local inshore populations of these two communities due to' increases in the canal standing crop of certain taxa.

FPL since 1976 has collected.ichthyoplankton samples from 6 offshore stations and one station in both the intake and discharge. canal as part of the monitoring requirements for St.

Lucic= Unit 1. Using the results of five years of sampling and a -method of- analysis, .- the -- percent' entrainment of eggs and-larvae drifting past~ the stations was estimated. Assuming two unit operation and 100% mortality.due to plant _ passage it was estimated that:between .3% and .6%-(x y .4%)1 ofJthe eggs and larvae moving past the-station would be-entrained. Under the most conservative conditions a maximum of less than 4% of the eggs 'and--larvae passing the site could-be _ entrained. Bat,ed on above estimated percent loss no significant impact by

. entrainment to _ the -local fisheries was- expected due to-ioperation~of St.sLucieiUnit 2.

- The third intake draws water from virtually the same location i and: depth ~as the existing two intakes and-the volume of water

_ passing through - the plant is . irrespective of. the . number of .

intake pipelines. Therefore, the operation of the third L intake pipeline was_ not ' expected to alter the en ainment L losses predicted for two intake pipelines operation.

There have been considerable year-to-year fluctuations in sea turtle ~ nesting activity on Hutchinson Island since monitoring began in :1971. Lov nesting activity _in 1975 and 1981-1983 in l'

1 the vicinity of the power plant was attributed to construction of plant. intake and discharge structures. Nesting returned to normal- 'or above ' normal levels following both periods of construction. Power plant operation exclusive of construction has had no significant ef fect on nesting near the plant.

Data

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-collected through 1989 have shown.no long-term reductions in total ~ nesting, _ total emergences of nesting success on the island. Formal requirements to conduct this program expired in 1986!but were voluntarily continued in 1989 with agreement from federal and state agencies.

Since plant operation began in 1976, 2,061 sea turtles (including.90 recaptures) representing five different species have been removed frc,m the intake canal. Eighty-four percent of these were loggerheads. Differences in the numbers of turtles- found during different months and years were attributed to natural-variation in the occurrences of turtles I in the vicinity of the plant,-rather than to any influence of the plant _itself. The majority of turtles removed from the intake canal (about 93 percent) worn captured alive, tagged and released-back into the ocean. Turtles confined-between the-A1A barrier not and intake headwalls usually resided in the canal for a relatively short period of time, and most were in good to excellent condition when caught.

6. Aquatic habitat enhancement or restoration efforts (e.g.,

anadromous fish runs) during operation may have enhanced the biological - communities in the vicinity of the plant and

' increased its impacts beyond that originally anticipatei Alternatively, degradation- of habitat or water quality may have resulted in loss of biological resources near the site that were unrelated to plant operation. Describe any changes

.to aquatic habits. (both enhancement and degradation) in the vicinity of the power plant since the issuance of the Operating License (or Provisional Operating License) that may have altered the actual _or perceived impacts of the plant.

RESPONSE

There have' been no changes at the plant site which have resulted in .the enhancement of, nor the degradation of aquatic habitat or aquatic . resources. Since plant wastewater-discharges,.which are relatively minimal, ultimately go to the

-coastal waters of the Atlantic Ocean, it is extremely unlikely that any' detrimental impact to aquatic resources will ever_ be observed. Further, once-through cooling water thermal ef fects are minimized due to the efficient high velocity release of the cooling water _to the' ocean, which serves as the ultimate heat sink. ' Additionally, there have not been any habitat

,.storation activities at the plant Hite, since there were minimal habitat disturbances during construction and none of consequence since operation of the units began. Even in the case of near-shore ocean floor _ disturbances resulting = from construction of the cooling water intake and discharge pipes, no aquatic resource impacts ha'/e been observed and any disturbed areas, such as dune disturbance during cooling water  ;

intake and discharge pipe construction, have generally returned to pre-construction state.

7. Plant operations may have had positive, negative, or no impacts on the use of aquatic resources by others. Harvest by commercial or recreational fisherman may be constrained by plant operation, or may be relatively large compared with fish losses _ caused by the plant. Describe (or_ provide documentation for) other nearby uses of waters affected- by cooling water systems (e.g. , swimming, boating, annual harvest by commercial end recreational fisheries) and how these have changed since issuance of the operating License or Provisional Operating License.

RESPONSE:  !

Plant operations have not resulted in any obvious aquatic resource impacts except for the possible undocumented enhancement of commercial and sport fishing in the area of the once-through cooling water thermal discharges. It should be noted, however, that the discharges are in nearshore, high energy areas with substantial wave action. These areas cannot routinely be depended on for fishery enhancement, due to their relatively small area.

8. Describe other sources of impacts to aquatic resources (e.g. ,

industrial discharges, other power plants, agricultural runoff) that could contribute to cumulative impacts. What are the relative contributions of these sources to overall water quality degradation and losses of aquatic biota?

RESPONSE

Wastewater and thermal discharges from the plant are to nearshore Atlantic Ocean coastal waters in a high energy oceanic zone. There are no other known industrial discharges in the vicinity of the plant which could result in cumulative aquatic resource impact. Further, there are no known agricultural runoff impacts to the local oceanic waters. Most agricultural runoff and stormwater from the area is discharged into the Indian River west of the plant site. The tidally ,

affected Indian River is open to the Atlantic Ocean.

Approximately 12 miles north of the plant (at the Ft. Pierce Inlet) or 12 miles south of the plant (at the Stuart Inlet).

There are no known cumulative water quality or aquatic biota impacts resulting from plant and local industrial / agricultural discharges and/or runoff.

9. Provide documents used to support Section 316(a) and (b) demonstrations. What 316(a) and (b) determinations have been made by the regulatory authorities?

RESPONSE

FPL conducted numerous studies which supported the section 316(a) and 316(b) demonstrations at the St. Lucie Plant. In response to this question we have included the following:

1) Cover page from a-report entitled "Results of Impingement Sampling, St. Lucie Power Plant," May, 1970.

2) Cover page from a report entitled "Effect of Increased Water Temperature on the Marine Biota of the St. Lucie Plant Area," February, 1979.

3) Copy of a letter from EPA presenting their Best Technology Available Findings for Circulating Water system Modifications, January 29, 1982.

Numerous other reports were prepared and the annual non-radiological monitoring reports contain monitoring data regarding onsite biological monitoring at the plant.

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AB170 EFFECTS OF INCREASED WATER TE MPERATURE ON THE MARIN E B1OTA OFTHE ST. LUCIE PLANT AREA FEBRUARY 1979 i

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• REGloN IV 349 COURTL AND tTREET ATL. ANT A *lCORose 303 4 S JAN 2 9 M REPS GM-WP CE m rzro m u.

amnu mxzIrr m:nEsso Mr. rebert z. mrig Vice President RECE1VED Advanced Systems & 'Iwchnology Florids Power & Light cmpany P. O. Icx 529100 8 01 W Hiami, Florida 33152 MANAGER PGWITilNG A PROGRAMS Thi Et. Incie Ibclear Power Plant IPDES IMmber FT.0002208

Dear Mr. Chrig:

Delosed for the alove is the referenced thticnal Pollutant facility. Discharge E.liminatico System (NPIES) perm decision 33495, Ma under Title 40, 03de of Federal Begulaticos, Sectico'Ihis actico ecnstitu 124.50 (45 FR Findings,yand 19, Pespera 1980). tc tw w nts.Also enciceed are the Fermit Faticcsle, Section 315(b Except as noted belcw, the biological sttdy plan entitled " Proposed St. Incie Plant F. Preoperational of the Permit. and Operaticnal Biolcgical Mitcrin .

'Iurtles are not covered by the NPDES Permit. Applicable provisiens of the progr Federal Aoency relative to consultation under the Ddamered Species Act a will irc.c.apurate equatic ano terrestrial cxxutorigrequircumta '

~ in the St Incie Dwironmental Protecticif P11Gi. ~~ ~ .

We have reviewed your Decenter 3, ic61, subctittal relathe to the third intak e and have ret with NRC and MS.

We hereby determine thet the two cristing intakes and the third proposed intake ccnstitute " test technolcgy available" in accordance with Section 316(b) of the Clean Water Act.as bever, noted in the Findings for the third intake, we strcngly feel that icprovements to prevent acoght. entrapment of sea turtles and improved return provisions should be

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We also concur hereb Manitorirs Progra:n" y clut tre "St In:le Plant Auxiliary Cooling Water System as sutmitted cn September 15, 1981, is acceptable in caeting Permit requirements for intensively conitoring the auxiliary ttoling systens contained on pages 1-1 and 1-3 for oxidants.

In accordance with your request of January 26, 1982, the permit is effeccive-nn si 5meure.

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. Director ter thnagement Division Fn:losures (5) Fimi NPDES Permit Permit Ratiomle Resp.nse to Comments Findings under Section 316(b) - to docunents cc: FDIR w/attactment U.S. Fish and Wildlife Service (Atlanta) w/Attachnents U.S. thtional thrine Fisheries Service (St. Petersourg) w/AttacFames U. S. !! lear Regulatory Ca: mission (Washingtcn)

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00040 Juuury 29, 1982 e

i ST. LUCIE NUCLEAR PLANT BEST TECHNOLOGY AVAILABLE (BTA) FINDING FOR CIRCULATING WATER SYSTEM MODIFICATIONS A BTA finding of fact for the existing intake syst m was con-ducted by EPA in 1981. Since that finding, Florida Power and Light Company (FPLL) submitted an application proposing a third cooling water pipeline to correct for predicted headiosses and reductions in canal water level when unit 2 becomes operational. Information found in FPA's finding of fact (1981) and documents submitted on December 3. 1981 by FP&L are the substance of the following findings for the proposed intake structure.

FINDINGS o An ocean pipeline and channel extension to convey cooling water from tha Atlantic Ocean into the existing intake canal is proposed. The 1515 ft long pipeline is 16 ft inside diameter, extends 1195 ft offshore, and it is buried beneath the dunes and ocean bottom'. The pipe will terminate into a velocity esp adjacent to the existing caps. The velocity cap structure will be similar in size and design to the existing structures (EPA, 1981).

o The new pipeline 'till have a maximum design flow velocity -

of approximately 6.8 fps, 3.2 fps less than the velocity of the two existing pipelines. u o The location of the velocity caps are'in a high energy / low ~

impact area as characterized in EPA's (1981) prior finding of fact.

o Permanent losses include 1/2 acre of mangrove swamp pre-empt ed for an access road and canal widening. Removal of less than 1/2 an acre of the swamp represents about 11 of the mangrove between the intake and discharge canals.

3 Temporary impactr because of construction activities include 14.7 acres of disturbed benthos, disruption of littoral flow of sand, decreases in turtle nesting, and excavation of a strip of dune vegetation and cand less than 100 ft wide.

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00041 o Specific provision designed to minimize impact caused by construction includes oo con 3truction of a temporary beach dune when cut-ting through the natural dunes, oo use of sheet piling and/or sitt screens around excavation work to limit turbidity to <50 Jackson units, oo disposal of soils in an approved onshore disposal, oo a turtle nest surveillance and relocation program

• on those aream of beach potentially affected by construction activity, and oo dune aren contours restored to pre-construction conditions, and the disturbed areas replanted with native dune-stabilizing species.

OPINION Base

• upon the information received from FP&L and our experience in assess...g power plant impacts over the past decade, it is our opinion that the design, capacity, construction and location of the third ocean intake structure of the St. Lucie Nuclear Plant reflects BTA for minimizing adverse impacts to terrestrial com-munities and oceanic fishes and invertebrates. .-

- Secause of increased intake capac'ity of this power plant and the present entrapment rate of endangered -s'ea turtles, it seems, .

in our opinion

• that the company should assess technology aimed at preventing entrapment of sea turtles at the velocity cap of this new atructure. Best technology available does not preclude, l in our opinion, additional improvements upon BTA to protect en-dangered species.

l l REFERENCES l

l EPA, 1981. St. Lucia Nuclear Plant 316(b) Finding for Best Tech-nology Available. Region IV, Atlanta, Georgia.

F"&L transmittal of ir formation to tir. Traina, Director of Water cianagement "* vision. December 3. 1981.

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===M MC A ust 15, 1981 ST. LUCI'E NUCLEAR PLAlff 316(b) Finding for Best Technology Available Section 316(b) of P.L.95-217 requires that the location, design, construction and capacity of cooling water intake structures reflect the best technology available (BTA) for minimizing adverse environmental ir. pacts. Decisions relating to BTA are to be made on a case-by-case basis uaf ng such factors as size and type of water body and relative magnitude of flow withdrawn for cooli ng (40CTR, Pt. 401 ) .'

Through deliberations between Florida Power and Light Company (FPL) and several government agencies, BTA was determined for the St. Lucie Nuclear Plant intake system prior to plant operation.

FIhDINGS The 2-unit 1612 net MW St. Lucie Nuclear Plant is located o'n a 'U130-acre site of Hutchinson Island', riorida approximately mid-- .

way between Pt. Pierce and St. Lucie inlets. The nuclear plant is bound on the west by the IndAan River and on the east by the Atlantic ocean.

The condenser cooling water is provided by a once-through .

circulating water system which consists of intake and discharge g _ - - - - - _ - - - - - - - - - - _ _ _ _ _ _ _ _ . _ _ . _ . _ _ - - - - --

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pipes in the ocean linked by canals to the nuclear plant. The ocean intake for Units 1 and 2 is located 1200 ft from the Atlantic shoreline in a high energy / low impact area characterized by water ,

turbulence and shifting sand or sand-shell substrate with a lack of bottom cover or outcroppings. The unstable substrate precludes the establishment of m+Arn:,shites or attached benthic conmunities.

From the ocean intage poir.t, water is drawn through 2 buried pipe-lines (I.D. - 13.0 ft) at 10 fps to the intake canal. This 3d0-ft wide canal begins 450 ft west of the shoreline where it funnels the cooling water some 500 ft to the nuclear plant intake structures (bars and screens). Pump. at the nuclear plant provide a design flow of 2290 cfs (5.62 x 106 m3/ day) for condenser cooling through the nuclear plant. Approach velocities to each of 8 traveling screens are less than 1.0 fps. Traueling screen washings are sluiced to a trash pit where organisms and trash are collected for disposal.

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T.he top of the ocean intakes (Figure 1) are situated approxi-mately 8 ft below the water surface at mean tow water. A vertical '

section to prevent sanding and bottom organism migration and a velocity cap to minimize fish entrapment were installed for each pipe. Presently, with one unit operating, horizontal intake velocities are 0.5 fpst with both units, velocities will increase .

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p ,. to approxinately 1.0 fps. The design of the ocean intake is similar to that employed by Southern California Edison Company at their El Segundo fossil fuel plant. At El Segundo, 272 tons of fish were entrapped during the first year of operation when j no velocity cap was used and the flow vectors entering ths in-take were vertically downward. After installation of a velocity cap with maximum design flows of 3.5 fps, only 15 tons of fish were entrapped in the following year (94 5% reduction) (USAEC, 1974). Velocity ' caps are designed to provide flow rate en a hori-zontal radial direction because fish are familiar with horizontal velocities, and they usuelly will tend to swim against a current even when their net movement is downstream. Vertical velocities, however, are not commonly found in nature, and a detection response mechanism does not seem to exist for them in fishes (USAEC, 1974).

The riorida Department of Natural Resources' Miami Research Laboratory in con] unction with PPL conducted preoperational base-_

line environmental studies of the marine

• environment adjacent to .

the St. Lucie Nuclear Plant from September 1971 to July 1974.

In 1975, Applied Biology, Inc, continued the monitoring through 1980. Unit I was placed on-line in 1976.

The nuclear plant was base loaded throughout 1977, 1978, 1979 and 1980. Monitoring information pertaining to entrapment of fishes and invertebrates over the years-shows that l

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o The greatest yearly canal catch over the past 5 years was 1501 fish in 1980. Total estimated fish biomass lost to o

the Atlantic Ocean that year was 6818 kg or about 0.2% of the St. Lucie and Martin County commercial catches. A total of 121 shellfish weighing 42.5 kg was also collected during the same period.

o rive species of marine turtles are found along Hutchinson Island. The most common is the Atlantic loggerhead turtle followed by the green turtle, leatherback turtle, hawksbill __

turtle, and the Atlantic Ridley g,urtie. The leatherback turtle and the Florida population of green turtles are -

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classified as endangered species by the Federal Government (CPR 41 (208):47180-47198: CPR 43:32,808), and all marine turtles are protected by Florida Statute 307.12; 1974.

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{j o Total sea turtle entrapnent in the St. Lucie intake canal over a 6-year period amounted to 572 loggerheads, 51 greens, 6 leatherbacks, I hawksbill, and 1 Atlantic Ridley. Annual entrapnent of all 5 species has ranged from 0 to 173.

o Ichthyoplankton was generally abundant during the spring and numetr of each year. *he most common larval fishes were horrings and anchovies. Eggs and larvae collected /

averaged f, rom 0.13 to 5.50/m3 as compared to the baseline sampling of 0.23/m3 These concentrations are substantially '

lower than concentrations found in a more productive area, the upper Indian River, where mean densities of eggs and

' larvae were 132.83/m3 (Applied Biology, Inc. and Ray L.

Lyerly and Associates, 1980).

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o Average egg and larval populations in the intake canal (0.899 eggs /n3 and 0.080 larvae /m3)~yere lover than average,'- -

populations fnund offshore, f

o To put the impact o f en* rainment into perspective, an offshore boundary was determined for the region from which ichthyoplankton is potentially withdrawn by the nuclear

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and the shoreline is 3500 m and the average depth is 9.2 m for a calculated cross-sectional area of 32,200 m2 The percentage tous estimates from 1976 through 1980 for fish eags ranged from 0.13 to 0.50 and for fish larvae losses ranged.from 0.01% to 0.184.

Ecciogy Dranch staff has been assessing power plant impacts over the past decade.

There is nothing in the monitoring infor-mation reviewed that, in our opinion, warrants a detailed 316(b) study nor t'.no continued monitoring of the ihtake for fishes and invertebrates. The design, capacity and location of the ocean in-take structure of the St. Lucie Nuclear Plant re flects. in our opinion, BTA for minimizing adverse impacts upon these organisms.

In view of the declining world populations of marine turtles, the Hutchinson Island turtle rookery is of special importance in maintaining marine turtle populations. Because of the nuclear ~

plant's location on Hutchinson Island ahd the protected status .

of sea turtles, it is our opinion that cont nued monitoring of turtle entrapment is necessary to fully evaluate intake location, desian and capacity.

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