ML17340A751

Comments on Des for Steam Generator Repair.Strict Monitoring of Radioactivity in Marine Preserves Recommended to Insure Against Permanent Increases in Activity Due to Repairs

ML17340A751
Person / Time
Site:	Turkey Point
Issue date:	02/20/1981
From:	Hoffman C INTERIOR, DEPT. OF
To:	Varga S Office of Nuclear Reactor Regulation
References
ER-81-1, NUDOCS 8102250267
Download: ML17340A751 (8)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NOR: 8102250267 OC ~ DATE: 81/0?/20 NOTARI: NO DOCKET FACIL:50-250 Turkey Point Planti Unit 3i Florida Power and Light C 05000250 50-251 Turkey Point Planti Unit 4i Florida Power and Light C 05000251 AUTH'AME AUTHOR AFFILIATION HOFFMAN <

RECIP C.S.,

NAME Interior i Dept. of RECIPIENT AFFILIATION

~

VARGArS ~ AD Operating Reactors Branch 1 I

SUBJECT:

Comments on DES for steam generator repair. Strict monitoring of radioactivity in marine preserves recommended to insure against permanent increases in activity due to repairs, DISTRIBUTION CODE C002S COPIES RECEIVED LTR g 'NCL g SIZE ~

TITLE: Environ. Comments.

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME 'TTR ENCL ACTION: VARGAz8 ~ 17 7 .7 GROTENHUI 8 g M 05 1 1 INTERNAL: ACCIDNT EVAL, BR 1 EF TREAT SYS BR ENV ENG BR 09 1 HYD/GEO BR HYDRO-GEO BR 1 ILE 07 NRC PDR 02 1 RAD ASSESSMT BR 1 REG F 01 SIT ANAL BR 10 1 FINANCE BR EXTERNAL: ACRS LPDR 03 NATL LAB 20 NSIC 04 TOTAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL +7

4

/a

qV'

~gal Os >

~ 0 United States Department of the Interior 0

OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 ER 81/1 FE8 2 0 f983 Mr. Steven A. Varga Chief, Operating Reactors

~

Branch 81 Division of Licensing Nuclear Regulatory Commission Washington, D.C'. 20555

Dear Mr. Varga:

The Department of the Interior has reviewed the draft environmental statement for Steam Generator, Repair at Turkey Point Plant, Units 3 and 4, Dade County, Florida. We have 'the following comments and recommendations.

'l The Turkey. Point Plant is located less than 1/2 mile west of Biscayne National Park, less than 1/2 mile northwest of Key Largo Coral Reef National Marine Sanctuary, 5 miles northwest of John Pennekamp Coral Reef State Paxk, 10 miles north of the American Crocodile National Wildlife Refuge, and 13 miles east of Everglades National Park. All these areas are protected, nationally significant resources many of which contain species on the'are and Endangered Species List and. are dependent on an uncontaminated fresh and salt water environment.

'There is a definite connection between the water of Biscayne Bay and Card Sound with the water flowing thxough Turkey Point Plant's 168 miles of cooling canals. Although this is not direct because the canal system is closed off by earthen dams, there still exists into an exchange of water through the porous Miami Oolight Rock which 'the'anals were dug. The canals were not lined to prevent this exchange, which is most noticeable when the tide levels change and the water in the canals risers and falls accordingly.

With this in mind, we are concerned that the increased level of radioactive water in the canal system will increase the amount of radioactivity in the surrounding waters of the marine parks, sanctuary, and refuge mentioned above. In addition to this, there will be radioactive gases emitted that could contaminate water and land resources through rainfall. We, therefore, recom-mend strict monitoring of radioactivity in these marine preserves to insure against any permanent increases in current radioactivity levels due ta th45b!<'depairs.

M3fAJJ-S tf0,'3.<";.,'<Jig;c JV4 SA 9f 9 PM <3 833]86>

0 r

l I

O

' t V

k I

\

t 4 A f' "~

lt

It isfossil-fuel anticipated in the Draft Environmental Impact Statement that burning Units 1 and 2 'will have to be used more the during this repair. With this increased use, air qua'lity in the area will decrease. Everglades National, Park is designated a Class I air quality area and Biscayne National Park has been nominated as a potential Class I area.

This requires maintaining a high level of air quality in these national parks. All businesses, government bodies, and others are to insure that their actions are not reducing the'tandard of air quality established for Class I areas. The Nuclear Regulatorydo Commission should insure that the'urkey Point Plant repairs not cause the'owering of air quality for Ever'glades National Park and Biscayne National Park. Approved pollution control devices should be in place and functional in the exhaust stacks of Units 1 and 2.,

The water transportation route for moving each of the six generators was not specifically defined in the Draft Environmental Impact State-ment. The'en'erators will contain an amount of radioactivity and are scheduled for six separate. barge trips. No matter what route is to be used, the,,generators will ha've to pass through the center of Biscayne Bay and Biscayne National Park. It is preferred that the route used should be northeast along the Turkey Point access channel then north along the Intercoastal Waterway, then east through Biscayne Channel (south of Cape Florida), to the Atlantic Ocean. This'ould bypass the live coral reefs, which are prOtected in John Pennekamp Coral Reef State Park and Biscayne National Park.

I<

jI Coordination thr'ou'gh a. Memorandum of Agreement should be established among the Nuclear Regulatory, Commission, our National Park Service, the U.S. Coast Guard, and the State of Florida to clear, the area of boat traffic. thr'ough Biscayne Bay to the Atlantic Ocean, during transpo'rt of, contaminated generators by barge. In addition, barge movements should occur anly during good wave and weather conditions and only after r'eceiying clearance from the U.S. Coast Guard.

f We also recommend that the casing around the generators I

provide adequat'e 'shielding from radiation exposure to the resources of Biscayne National Park and that barges to be used are inspected and certified for seaworthiness prior to use.

The Department's National'Park Service contact for further coordination,and preparation of a Memorandum of Agreement is Regional Director,, Southeast Region, (Attention: Dr. Jay Gogue, Chief Scientist) 75 Spring Street, S.W., Atlanta, Georgia 30303, telephone (404) 221-3643, FTS: 242-3643.

I P

We hope 'this will be of assistance to your effort.

IcKGILU s. H FMpy Assistant S ECRETARY

f

-lt % g J ~a 4

A