ML17339A706

Disposal of Spent Powdex Ion Exchange Matls, for Fl Power & Light Co

ML17339A706
Person / Time
Site:	Turkey Point
Issue date:	10/25/1979
From:	Kunin R AFFILIATION NOT ASSIGNED
To:
Shared Package
ML17339A705	List: ML17339A704 ML17339A706
References
NUDOCS 8003210428
Download: ML17339A706 (21)

Text

DR. ROSERT KUNIN CONSULTANT I318 MOQN DRIVE YAROLEY. RE. I906V 215'136'2420 2IS 295 9430

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THE DISPOSAL OF SPENT POVTDEX ION EXCHANGE MATEHIALS by Dr. Bobert Kunin, Consultant Yardley, Pa. 19067 October 25, 1979 8000@@.,o+2-C SPBCIALICINQ IN ION BXCltANQB>WATBR TRBATMBNTI CHBMICAl I ROCBSSINQy ANO POLLUTION CONTROL

DR. ROBERT KUNIN CONSULTANT 1318 MOON DRIVE YARDLEY. PA.

1906'15'736'2420 215'2~3O

,THE DISPOSAL OF SPENT POWDEX ION EXCHANGE M4.TERIALS Introduction This report is an analysis of the rational involved in the disposal of Powdez ion exchange materials employed in power utilities. In many respects, it also applies to the disposal of other ion exchange materials of known origin and history. Since the origin and history of Powdez resins in a utility are weQ-documented and the composition of the new and used materials are well-defined, the analysis contained in the report is directly pertinent to the discharge of Powdex. The analysis could also be applied to other resin systems {Seprex) that may be equally defined.

gR I. The 'Nature of Powdez Materials Powdex materials are special preparations of ion exchange resins in fine1y div'ded forms. The Powdex formulations normally contain a mixture of cation exchange resins in the hydrogen or ammonium forms and anion exchange resins in the hydroxide form. The cation exchange resins are of the sulfonated styrene-divinylbenzene structure and the anion exchange resins are quaternary ammonium derivatives of similar styrene-divinylbenzene copolymers. Since these structures are highly crosslinked polyelectrolytes, they are very insoluble and truly resistent to biologicai degradation. These copoi~~er skeletal structures contribute nothing to the overall COD, or even TOC content of solutions, or waters that contact

'OD, them. In essence, the only activity of these ion exchange resins is their ion exchange activity.

SP CIALIZING IN ION BXCHANGB>WATQR TRBATMBNT, CHBMICAL PROCBSSING, ANO POLLUTION CONTROL '

II. Toxicity of Powdez Materials The ion exchange resins contained in Powdex formulations have been used in many, many applications approved by the Food & Drug Administration (FDA), Public Health Service (PHS), United States Dept. of Agriculture (USDA), and the U.S. Pharmacopia. Further, these same ion exchange resins have been used as artificial soil media for the growth of plants without any adverse effects. The non-toxic aspects of the Powdex ion exchange resins may be brought into focus dramatically by the fact that the ion exchange

'I resin products used in Powdex formulations have been approved.

for the hemoperfusion of blood ("in vivo" treatment of blood) and as drug or drug-carriers for oral administration in large dosages (10-60 grams per day).

Not only are many of our drinking water supplies treated by these ion exchange resins, many of our food products (dextrose, fructose, sucrose, sorbitol, glycerine, etc.) are similarly treated.

References pertaining to these applications attesting to, the non-toxicity of these ion exchange resins and their approved uses. are as, follows:

1. Kunin, Robert, Ion Exchan e Resins, Krieger Pub. Co.,

New York, (1972); J. Wiley, New York (1958).

2. Nachod, F. and Schubert, J., Ion Exchan e'Technolo Acad. Press, New York (1956).

3. Martin, G. J., Ion Exchan e and Adsor tion A ents in Medicine, Little, Brown & Co., Boston (1955)'.

4. Pood and Drug Administration, Regulation No. 121. 1148, Subpart D, 'July 13, 1964.

III. Dis osal of Powdex Materials In view of the previous evidence on the lack of toxicity of the ion exchange resins contained in the Powdex formulations, any concerns over environmental problems associated with the disposal of such materials must limit themselves to the toxicity of the materials, adsorbed by the ion exchange resins or'part of the ion exchange complex.

When employed in a typical power utility, the Powdez usage rate wQ1 be approximately 75 lbs. per day with a discharge of 300 lbs in 8000 gallons of water every four days. Vlhen used,'he Powdex will adsorb a maximum of 0. 2 lbs. of corrosion products per lb.

of Powdex. These corrosion products are essentially iron and copper oxides and are present at- a ratio of approximately 95 parts iron /part copper. These oxides are very refractory or insoluble.

'I Their solubilities are such that they will impart far less than l part per million to the. waterways and levels well within the limits of EPA. The exchange complex of the "spent" Powdex material should probably be in the sodium and chloride ionic states. Some ammonium and bicarbonate ions may also be present; however, the ammonium and bicarbonate levels in the Pow¹x formulations should be negligible since the Powdex will have been exhausted prior to dis'charge.

Recognizing the cation exchange resin to have a capacity of 4. 5 milliequivalents per gram and the anion exchange resin to have

a capacity of 4 meq/g and the formulation to contain equal weights of cation and anion exchange resin, the daily discharge should contain no more than 3. 9 lbs of sodium and 5. 3 lbs of chloride.

However, since the estuary is brackish and already contains high concentrations of NaC1, very little of the sodium and chloride contained in the "spent" Powdex will be released. Even if it were aQ released, the quantity released would be insignificant when compared to the sodium chloride already present in the estuary or discharge basin.

The refractory iron and copper oxides contained in the spent Powdez will settle to the base of the estuary and contribute no significant levels of soluble iron or copper to the water in the estuary. If any traces of iron or copper are solubilized, these traces will be readily adsorbed by the ion exchange resin in exchange for sodium. Hence, one can be weQ-assured that the iron and copper should pose no threat to'the environment. In fact, the total quantities of iron and copper discharged with the spent Powdex probably will J

be beneficial to the environment, particularly in subtropical regions*

such as Florida, where it is well-known that the soils are deficient in iron and copper. It should also be noted that the addition of the spent Powdex to such soils would also be a benefit, since it would add to Ke exchange capacity of the soils which are Mown to be deficient in exchange capacity in Florida and. other subtropical regia s.

In view of the evidence in the foregoing discussion, it would appear that the spent Powdex material can be safely discharged to the

environment into either water bodies or even as landfill. From an overview, it would appear that the discharge would even be helpful to the environment. For a material as vrell defined as spent Povrdex,'o risks are entailed in the disposal of this material.

. Bobert Kunin Oct. 25, 19.79 BK!ck

DR. ROSERT KPilIN - SiOGRMHICAL SK. xCH Dr. Robert Kunin received his B.S. and Ph.D. degrees from Rutgers University in 1939 and 1942, respectively. He began his career as an Associate Chemist with the Tennessee Valley Authority in 1942 and served as a Senior Scient'st with the Manhattan District atom bomb project at Columbia University during 1944-45. Dr. Kunin has been with the Rohm and Haas Company from 1946-197o as a Laboratory Head, Research Associate, a Senior Staff Associate, and a Development Manager of the, Fluid Process Chemicals and Industrial. Chemicals Departments. Dr. Kunin is now a consultant specializing in ion exchange, adsorption, water treatment, pollution control, and chemical processing. In the area of chemical process.ng he has special expertise in the pharmaceutical, sugar, and chemical process industries.

I Dr. Kunin's main az'eas of research have been in ion'xchange, catal.ysis, adsorption, and liquid-liquid extzaction. He has,written three books and approximately 250 articles, and 30 patents in these fields are accredited to him Dr. Kunin has been a Lecturer at the University of Pennsyl.vania and the American Un'versity. He is a member of the American Chemical Society, American institute of Chemists, Amezican Association for the Advancement or Science, American Institute of Chem-'cal Engineers, and tne American Society for Testing and Materials (ASTi~l).

One of the major contributions of Dr. Kunin has been the deveI.opment of ion exchange systems for the treatment of water. One of his inventions, the MOZOBED or Mixed Bed technique, is now used universally throughout the wor'd and has been shown to be indispensible for the production or the ultra-pure water that is so necessary for the powe- field. Without this technique it would be difficult to achieve the purity of water and steam required for supezcritical. boilers. The MOYtOBED technique now serves a most important function in nuclear-powered submarines and in the new nuclear-powered surface vessels. Dr. Kunin has recentl.y developed a new MONOBED system that is capable of removing the last traces of collo'cs from de'on'ed water enabling one to achieve the "ultimate" qua'ty water demanded by the electronics industry. The MOLXOSED technique is also now universally employed for thc commercial production of high qua'ity su"ar syrups. Some of thc other water tzcatmcnt -cchniqucs he dcve'oped are now being used for thc removal of fluorides from water and for the dcalkalization of process water. He has also been a pioneer in the development of new adsorbents for the treatment of water and waste effluents.

During the course of his work a" Rohm and Haas Company, Dr. Kunin has served as a consultant to the Blood Preservation Laooratory a" Harvard University and the Atomic Energy Commission at Oak Ridge. During the course

of this activity, many of the principles and techniques he developed inspired further research in the use o~ ion ewe'..ange a n d adsorbents for the treatment of blood and or the deve1.opmen" of arti=ic-'al jdney dev'ces. This techn'que is now being used in var.'ous hosoitals through-out the world for treating patients who have absorbed lethal dosages oi var'ous drugs and toxic chemi.cals. His work with, the Atomic Lnergy Commission and at Roin. and Haas Company on the use of ion exchange for recovering and purifying uranium was instrumental in establishing t s technique commercially throughout the world.

Dr. Kunin's studies on ion exchange led to the commercial use of ion exchange for the production of such antibiotics as streptomycin and neomycin.

Dr. Kun'n's books, publications, and lectures throughout industry and at many universit'es, colleges, and schools have served to educate

.and instruct many in the use of ion exchange in many fielcs of study

'and applicati.on.

In recent years, Dr. Kunin's efforts have been di-ected towards the areas or desalination and pollutibn control and abatement. The has now reached the commercial stage and is now being used inDES'rocess the U. S". and Italy for the desalination of brackish water. He has

~ .odified his process for reclaiming -cid mine drainage waters emanati.ng

=rom coz1. mines. The Commonwealth of Pennsylvania has recent3.y erected a Large plant based .upon this'process to treat the water emanating from the coal m'nes and the water will be supplied to the, co-.munity of Phi.lipsburg, PennsyLvania.

In 1966, Dr. Kunin was awarded the Howard N. Potts Gold Med'al of the Franklin Institute for his, work in, the field of ion exchange. In 1979 he was the recipient of the International XVater Conference Award of 3:Ierit.

E ' 'll discharge.

I I I <<h ANSWER: The point of discharge is expected to be on the discharge side of the facility.

E P I: Ih 1 11 I 111 I I d I I I h immediate area o f the di scharge.

ANSWER: Under FPL's current plans for handling condensate polisher wastes, only high quality supernatant liquid would be discharged into the facility cooling canal system. The discharge point would be at the facility's discharge basin. The discharge stream is not expected to exceed 150 gpm. Flow rate through the facility discharge basin due to forced pumping is approximately 1.8X106 gpm with all circula-ting water pumps running. Due to the high quality of the discharge, FPL has no minimum requirement for circu'lating flow during the discharge.

h li>>,h d prior to release.

ANSWER: FPL's current plan for the handling of condensate polisher waste is as follows:

Spent resins would be backwashed as a resin-water slurry (using condensate quality backwash water) into a backwash receiver tank. Powdex resin and other solids would then be separated from the slurry leaving a high quality supernatant liquid for discharge into the facility cooling canal system. He plan to dispose of the solid resins by land burial.

EPEETIP 9: II h f1 1 p I I 1 <<11'I 1 I d.

ANSHER: It is presently estimated that there will be no environmental degradation caused by the effluent release as a result of the operation of the full flow condendate polishing demineralizer system. The water quality of the polishing demineralizer system effluent discharge is expected to be superior to the water quality of the cooling canal system, Biscayne Bay, or Card Sound.

FPL has been issued a National Pollutant Discharge Elimination System (NPDES) permit for Turkey Point Plant, NPDES PFL001562

by the United States Environmental Protection Agency (EPA) on June 14, 1978.. That..permit authorizes discharges to the circulating water cooling canal system without limitations or monitoring requirements provided that there is no s rface discharge to Biscayne Bay or Card Sound. The effluent dis-charge from the full flow condensate polishing demineralizer system will be consistent with the terms and conditions of this permit. The permit requires FPL to monitor the water quality of the circulating water cooling canal system.

Grab samples must, be taken quarterly at the outlet from

.Lake Warren and must include the following parameters:

salinity; total suspended solids; and total zinc, iron and copper. Results are submitted in reports annually on January 31 of each year.

In the event of indications of primary to secondary leakage, samples will.be -collected from the backwash receiver tank

, and tested for radioactivity prior to disposal of the wastes.

Liquid radioactive releases are controlled by Appendix A of the Turkey Point operating licenses (Technical'Specifications, Section 3.9), as well as by written procedures., Both quantity and concentrations are controlled. The releases are'equired to and do meet the restrictions imposed by 10 CFR Part 20 and Part 50, Appendix I.

Disposal of any radioactively contaminated polisher wastes will be in accordance with applicable NRC. regulations concern-ing the discharge and/or disposal of solid radioactive wastes and radioactive .effluents.

EIIEEEIIIE I: P .Id 11 I 111 I P receiving. waters near the point of discharge.

p I t ANSWER: Lists of organisms likely to be present in the. cooling canal.

system have been compiled from published and unpublished sources. The lists of organisms are presented in the following tables, Table A-1 and Table A-2.

EUEEIIIEEI: E'I tE IP fdf*t E t I f inants present in the waste stream on the aquatic organisms found near the plant.

ANSI JER: FPL's current plans call for discharging only high quality supernatant liquid to the facility cooling canal system.

The supernatant will be of higher quality than the water in the cooling canal system. The supernatant will therefore

have no deleterious effect on the organisms. living in the cooling canal system.

UESTION 12: Describe the biological monitoring programs that will be conducted to assess the environmental impacts associated with operation of the demineralizer system.

ANSWER: The existing biological monitoring program (Environmental Technical Specification (ETS) for FPL Turkey Point Units 3 and 4) which is implemented for the Turkey Point Plant cooling canals will be used. Plankton (ETS Section 4. 1. 1.

1.1), fish (ETS Section 4.1.1.1.2), and benthos (ETS Section

4. 1.1. 1.3) monitoring will provide enough information to assess the environmental impacts associated with operation of the demineralizer system.

UESTION 13: Describe the status of all relevant permits required by other state, local and Federal agencies.

ANSWER: FPL has applied for and received all required relevant permits for the Turkey Point Plant from state, local or Federal agencies.

Any net application or amendments required as a result of changes or additions to current operating practices will be made at the appropriate time.

UESTION B: Provide the design details and exact location of the storage building (referred to in contentions 6* and lid). Include the structural design details to the extent necessary for the staff to determine the adequacy of the building to withstand hurricanes and floods. Also include the weight and dimensions of the steam generator lower assemblies to be stored in the building.

Provide the details of the method of sealing the steam generator lower assemblies; weld design, weld material, cap material and dimensions, corrosion protection, and any related information that will be needed to evaluate the possibility of radioactive material leaking out of the stored assemblies.

• Contentions referred to in this request are to be taken as given in the Atomic Safety and Licensing Board's "Order Relative to Contentions and Discovery" dated September 25, 1979.

ANSWER: The conceptual design and nominal dimensions of the storage compound are shown on the attached f'igure. The final design might change depending on the outcome of ongoing engineering studies and evaluations. Each steam generator lower assembly with steel support saddles will rest on reinforced concrete

bean ng pads. The compound will be designed and constructed in accordance with the South Florida Building Code, ACI 318, A'HS Dl.l and AISC Hanual of Steel Construction.

The approximate location of the storage compound in the laydown area is also shown on the attached figure. The current elevation of the laydown area ranges from +6 to +9 feet HLM. The approxi-mate subsurface profile in the vicinity of the storage compound consists of 4 feet of limerock fill over 6 feet of muck under lain by Hiami limestone. The existing fill and muck will be excavated to a minimum distance of 15 feet beyond the edge of the storage compound. The entire compound and lay down area will be backfilled or filled as required with compacted '.imerock fill to + 17'" HLM with perimeter slopes of 1-vertical on 3-horizontal. Heavy equipment transport, laydown storage, lift crane implacements in support of repair and storage operations will require a and'eavy minimum of 65 feet around the storage compound.

The limerock 110 pounds per fill will be compacted to a minimum dry density of cubic foot which based on laboratory tests yields allowable bearing capacity of approximately 15 kips per square foot, strength of cohesion of approximately 3 kips per square foot, and an internal angle of friction of approximately 39.

A steam generator lower assembly is approximately 39 feet long and 127 inches in diameter except for the last 6 feet 4 inches where the diameter expands linearly from 127 inches to 166 inches.

The volume is approximately 3620 cubic feet and the dry weight is approximately 205 tons which yields a total vessel density of about 113 pounds per cubic foot.

The top of the assembly (approximately 13'0" diameter) and the two channel head nozzles (approximately 31" diameter) will be provided with 3" steel shield plates. The two blowdown nozzles (approximately 2" diameter), one shell drain (1" diameter), and one instrument nozzle (3/4" diame'ter) will be provided with I" steel shield plates. The shield plate materials will be ASTN A36 or equivalent and will be welded to the lower assembly openings. Only carbon steel weld materials will be used and the weld throat will be 1" minimum. Since the storage compound will have a water tight roof the lower assemblies will be protected from industrial corrodent and salt spray deposition, hence special corrosion protection will not be required.

FPL is presently evaluating the effects of a postulated design basis hurricane upon the steam generator storage facility and its foundation. The results of this evaluation will be made available upon completion.

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<<d ANSWER: The estimated costs for installing a condensate polishing demineralizer system for Turkey Point Units 3 and 4 is $ 9. 1 million.

g to in contention lie).

ANSWER: The cost involved in retubing the Turkey Point Units 3 and 4 condensers was approximately $ 1 million per ivater box; or a total of $8 million.

to the present time (discussed in contention llf).

ANSWER: The repair of the Turkey Point Units 3 and 4 steam generators is estimated to be $ 119.3 million (1979 dollars).

TABLE A-1 ORGANISHS OCCURRING IN THE TURKEY POINT COOLING CANAL REPORTS, ABI 1974-1980)

SYSTEI'ANNUAL ANNELIDA tlOLLUSCA Polychaeta Gastropoda {continued)

F-..phictei s gunneri floridus Pzunum api ci num Ruto2,ytus brev'ci rzata Retusa eburnea Capi tell a capi tata Cauli eri ella killaziensi s f li Ci rri ormi a fi gera Dorvil2,ea soci abilis HOLLUSCA Pelecypoda Fabricia Sp.

Glycera americana Astarte nana Haploscoloplos foliosus Chione cancellata Laonorre salmici c7i s Chione gl us Lumbri naris SP. Diplodonta nuclei formis Baldane sarsi Goul di a ceri na Barphysa sanguinea Lucina multilineata Nereis succinea Lyonsia Xloridana Odontosyllis enopla modul us carchec7oni us Paraoni des lyra Pitar albida Pista cristata Pseudocyrene flozidana Platynereis dumeri 1 l ii Tellina Sp.

Podarke obscura Tellina alterata Polydora ligni Pol yophthalmus, pi ctus ARTHROPODA Prionospio h terob anchia texana Pycnogonida Scni stomeri ngos rudolphi Scyphoproctus .Sp. Moplodactylus lentus Syllis SP.

Terebellides stro mi ARTHROPODA 2'zichobranchus glacialis Crustacea Typosyllis SP.

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ORGAN)ISHS OCCURRING IN THE TURKEY POINT COQggffG CANAL SYSTEfi (ANNUAL REPORTS, A8I 1974-l~

ARTHROPODA FISHES (continued)

Crustacea (continued)

Centropomus undecimalis Lysianopsi s alba Fundulus grandi s Hi czodeutopus Sp. Haemulon sci urus Pysis stenolepis Arius felis Ta ohrozysi s bovmani Stzongyl ura notata Alpheus azmillatus li hfeni di a b ryl na Hippolyte pleuracantha Diapterus pic,. 'eri Palaemonetes pugio Lagodon rhomoboi des Thor floridanus Caranx hippos Pinnixia sayana Haemulon parrai Atherinomozus sti pes ECHINODERNATA Bugil cephalus Ophiuroidea Slops saurus Chaetodi pterus faber Amphi pholi s squamata Syngnathus Sp.

Gobionellus Sp.

MISCELLANEOUS Selene vomer Strongylura marina Echiuroi d vorms. Hi ppocampus erectus Pziapulid vorms Echenei s naucrates Sea squirts Caranx crysos Trachinotus falcatus SHELLFISHES P1enti ci rrhus li t torali s Archosargus probatocepha2us Ca2li nectes sapi dus DozIttltator macu2atus penaeus Spp. Hicrogobius microlepis ileni ppe mezcenari a Sphoeroi des testudi neus Panu2irus argus Hegalops atl anti ca Limulus polyph mus Carcharhinus leucas FISHES Floridichthys carpio Cyprinodon vari egatus Poe ilia latipinna Lophogobi us cyprinoi des Cezzes ci nereus Fuci nostomus gula Bel onesox beli zanus Eucinostomus argenteus Lucania parva Albula vulpes Sphyraena barracuda Opsanus beta Fundulus confluentus Lutjanus griseus Lutjanus apodus

TABLE A-2 ORGANIS."1S OCCURRING EN THE TUPZEY PO'K?7T COOLXHG CA'HAL SYSTEM (FPL, 1975) 31ue Green Algae Lyng'bya. sp.

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~ V Attachment 2 Condensate Polishin Demineralizer S stem The new condensate polishing demineralizer system is planned for installation in the condensate/feedwater system at the discharge of the condensate pumps between the pumps and the No. 1 low pressure feedwater heater. The system's function is to purify the condensate by filtration and demineralization to assure high quality feedwater to the steam generators.

The condensate polishing demineralizer system control is independent from the existing condensate/feedwater system. Hhen in use, the system treats full condensate flow from the condensate pumps. A full flow bypass system has been provided to assure continuous uninterrupted condensate/feedwater system operation.

Loss of normal feedwater flow due to pipe break, pump failures, valve malfunctions or loss of outside AC power, is discussed in Section 14. 1.11 of FSAR, Chapter 14.

Technical specification 3.8 discusses the steam and power conversion system.

The condensate/feedwater system is not a safety related system.

10 CFR 50.59 (a) (2) defines an unreviewed safety question as follows:

"A proposed change, test, or experiment shall be deemed to involve an unreviewed safety question (1) if the probability of occurrence or the consequences of an accident or mal-function of equipment important to safety previously evaluated in the safety analysis report may be increased; or (2) if a possibility for an accident or malfunction of' different type than any evaluated previously in the safety analysis report may be created; or (3) if the margin of safety as defined in the basis for any techn'ical specification is reduced."

A summary of the review of the planned addition of the demineralizer system against the foregoing definition of an "unreviewed safety question" follows.

1 1hth respect to the probability of occurrence of an accident previously evaluated in the FSAR: As discussed previously, a full flow bypass line is provided for the condensate polishing demineralizer system. The probability of a loss of feedwater (LOFH) accident due to a failure in the'condensate polishing demineralizer system and a concurrent failure of the bypass control valve to open is extremely small. This probability is not significant when considered in light of the frequency of feedwater transients (2 to 3 per year) as documented in Section '3.1 of NUREG-0560 "Staff Report on the Generic Assessment of Feedwater Transients in PMR's designed by Babcock and Wilcox," Nay 9, 1979. Therefore, the probability of occurrence of this accident is not increased by the addition of this system.

Mith respect to the consequences of an accident previously evaluated in the FSAR:

The addition o the condensate polishing demineralizer .system has no effect on

the severity of any of the accidents discussed in Chapter 14 of the FSAR. The LOFW accident, which is the most severe accident for the feedwater system, has already been evaluated in the FSAR.

With respect to the probability of malfunction of equipment important to safety previously evaluated in the FSAR: The only system affected is the condensate/

feedwater system, which is not required to mitigate the consequences of a LOFW accident. The addition of the condensate polishing demineralizer system will have no effect on the auxiliary feedwater system since the. systems are totally independent of each other.

With respect to the consequences of the malfunction of the equioment important to safety previously evaluated in the FSAR: For the reason stated above, the addition of the condensate polishing demineralizer system will have no effect on the consequences of malfunction of equipment important to safety.

With respect to the probability of an accident of a different type than analyzed in the FSAR: As discussed earlier, the most severe accident for the condensate/

feedwater system is the LOFW. 'This accident has already been evaluated in the FSAR. The addition of the condensate polishing demineralizer system does not create the possibility for a different type of accident.

With respect to the possibility of malfunction of a different type than any analyzed in the FSAR: For the reason discussed in 2.a above, the addition of condensate polishing demineralizer system would not create the possibility of a malfunction of a different type than considered in Chapter 14 of the FSAR.

With respect to the margin of safety as defined in the basis for any Technical Specification: The addition of the condensate polishing demineralizer system would not decrease any margin of safety discussed in the Facility Technical Specifications.

Conclusion For the reasons di.scussed above, addition of the condensate polishing demineralizer system does not involve an "unreviewed safety question" as defined in 10 CFR 50.59 (a) (2). The planned addition of the condensate polishing demineralizer system has also been reviewed against the .Facility Technical Specifications. The addition of the condensate polishing demineralizer system does not require a change to Facil.ity Technical Specifications.

March 20, 1980 Neil Chonin, Esq.

New World Tower 8uilding 30th F'loor 100 N> Biscayne Boulevard Miami, Florida 33132 In the Matter of Florida Power and Light Company (Turkey Point Nuclear Generating Unit Nos. 3 and 4)

Docket Nos. 50-250 5 50<<251 (Proposed Amendments to

'Facilit 0 er.atin Licenses to Permit Steam Generator Re air Dear Mr Chonin'.

Per our discussion, I have enclosed a l:ppy of a letter from R. E. Uhrig, Florida Power and Light Company (FPL), to D. G. Eisenhut, NRC, dated March 11, 1980, requesting an additional month (until May 1, 1980) of operation of Turkey Point Unit 4 prior to performing the next steam generator inspection.. An NRC Staff written summary of a meeting held between representatives of the NRC, FPL, and Westinghouse on March 4, 1980 to discuss the steam generator inspection program has been served on you under separate cover.

If you have any questions on this matter, please feel free to contact me.

Sincer ely,

/s/

Steven C. Goldberg Counsel for NRC Staff

Enclosure:

As stated cc w/o enclosure: Harold F. Reis,. Esq.

NRC Central Fi:le w/DISS 8'PDR (7)

Shapar/Engelhardt 'MGrotenhuis, 316 Phi.l.

Christenbury/Scinto WJOlmstead/MKarman SCGoldberg/Chron (2)-

JEMoore OFFICE 0ELD g SUANAME SCGoldberg d W ad DATE P 3/20/80' 3/E6 /80 ~ 4K r 4 ~ ~ ~ 14 ~

NAC FOAM 313 (9 7E I NACM 0240 4 V.S GOVCANI/IENTPAINTING OFFICE: 1979 289.389

4ECy (4gpss P 0 UNITED STATES

~i NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555

~w*w+ March 20, 1980 Neil Chonin, Esq.

New World Tower Building 30th Floor 100 N. Biscayne Boulevard Miami, Florida 33132 In the Matter of Florida Power and Light Company (Turkey Point Nuclear Generating Unit Nos. 3 and 4)

Docket Nos. 50-250 5 50-251 (Proposed Amendments to Facilit 0 eratin Licenses to Permit Steam Generator Re air

Dear Mr. Chonin:

Per our discussion, I have enclosed a copy of a letter .from R. E. Uhrig, Florida Power and Light Company (FPL), to D. G. Eisenhut, NRC, dated March ll, -1980, requesting an additional month (until May 1, 1980) of operation of Turkey Point Unit 4 prior to performing the next steam generator inspection. An NRC Staff written summary of a meeting held between representatives of the NRC, FPL, and Westinghouse on March 4, 1980 to discuss the steam generator inspection program has been served on you under separate cover.

If you have any, questions on this matter, please feel free to contact me.

Sincerely,

~(.~ ~ucy Steven C. Goldber g Counsel for NRC.Staff

Enclosure:

As stated, cc w/o enclosure: Harold F. Reis, Esq.