ML17209A338

Proposed ETS Sections 5.1,5.2,5.3 & 5.7.1.a Re Organizational Changes of Environ Affairs Dept

ML17209A338
Person / Time
Site:	Saint Lucie
Issue date:	10/27/1980
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17209A337	List: ML17209A336 ML17209A338
References
NUDOCS 8011120512
Download: ML17209A338 (15)

Text

5.3.4 Proposed changes or modifications to plant systems or equip-ment, which would require a change in the procedures described in 5.5 below, or which have been determined by the Plant Manager to affect the licensed facility's environmental impact.

5.3.5 Proposed tests or experiments which have been determined by the Plant Manager to affect the licensed facility's environ-mental impact.

.5.3. 6 Coordination of Environmental Technical Specification (Appendix B to the facility license) development with the Safety Tech-nical Specifications (Appendix A to the facility license) to avoid conflicts and for consistency.

5. 3.7 Proposed sampling analyses, calibration and alarm check procedures, as specified in 5.5.1, and any other proposed procedures or changes thereto as determined by the Plant Manager to affect. the licensed facility's environmental impact.

5.3.8 Investigation of all reported instances of ETS violations including appropriate recommendations to prevent recurrence.

5.4 Actions to be Taken if a Limitin Condition is Exceeded 5.4.1 When a Limiting Condition is exceeded, action shall be taken as permitted by the applicable specification until the condi-tion can be met.

5.4.2 Exceeding a Limiting Condition shall be investigated by the Company Environmental Review Group or by the Facility Review Group.

5.4.3 All reviews and actions taken, with reasons therefor, shall be recorded and maintained as part of the permanent records.

5.4.4 Each instance 'whereby a Limiting Condition is exceeded shall be reported to the Company Nuclear Review Board.

I 5.5.5 A report for each occurrence shall be prepared as specified in Section 5.6.2.

5.5 Procedures

5. 5.1 Detailed written procedures, including applicable check lists and instructions, shall be prepared and followed for activities involved, in carrying out the environmental technical speci-fications. Procedures shall include sampling, data recording and storage, instrument, calibration, measurements and analyses, and actions to be taken when limits are exceeded. Testing frequency of any alarms shall be included.

5-3 10-27-80

'8ZX Za0 Q /2

t

%i EXECUTIVE VXCE PRESXDHNT VICE PRESXDHNT COMPANY NUCLEAR ADVANCED SYSTEMS REVIEW BOARD AND TECHNOLOGY DIRECTOR DXRECTOR yXCE PRESIDE NT ENVZ RONMENTAL NUCLEAR POWER .

AFFAIRS AFFAIRS ~ RESOURCES COtG'ANY ENVXRONtKNTAL REVIEW GROUP MANAGER OP POWER RESOURCHS-NUCLEAR PLANT MANAGER FACILITY .REVIEWS GROUP eoeoo eeoc la meooeeowwmwmwoeeoeoeoweooeoeoem'LORIDA POWER 5 LXGHT COMPANY CORPORATE ORGANIZATION ENVXRONllHNTAL AFFAIRS FXGURE 5.2-'l AU2HORXTY COMlUNXCATXOH

P 4~

r, A

5.0 Administrative Controls The purpose of this section is to describe the administrative and management. controls necessary to provide continuing protection to the environment, and to implement the environmental technical specifications (ETS).

5.1 Res onsibilit The Director, Environmental Affairs Department has the ultimate )

responsibility for the implementation of the ETS. He may delegate to other departments and/or organizations the work of establishing and executing portions of the ETS, but shall retain responsibility thereof. The Environmental Affairs Department is responsible for executing the non-radiological biotic and special studies sections of the ETS.

The Vice President of Power Resources is responsible for executing the non-radiological abiotic, radioactive effluents, and the Radiological Environmental Surveillance sections.

The Director of Nuclear Affairs shall be responsible for periodic audits, conducted according to the corporate Quality Assurance program, to insure compliance with the ETS.

5.2 Or anization The corporate organization involved in environmental matters is depicted in Figure 5.2-1.

5.3 Review and Audit Administrative measures shall provide that the individual or group assigned the responsibility for auditing or otherwise verifying that an activity has been performed is for independent of the individual or group directly responsible performing the specific activity. The review function shall be performed by the Company Environmental Review Group (CERG), as described in the Topical Quality Assurance Report, with an audit conducted at least once per year. Contractor operations shall also be audited once per year.

CERG is responsible for management review of items 5. 3. 1 through 5.3.8 below. Independent audit functions for 5.3.1 and 5.3.8 below will be provided through the Quality Assurance Program.

5.3.1 Environmental Technical Specifications for the facility.

5.3.2 Results of the environmental monitoring programs prior to their submittal in each Annual Environmental Monitoring Report.

5.3.3 Proposed changes to the Environmental Technical Specifications in effect for the facility and the evaluated impact of the changes.

5-1 10-27-80

P ~ ~ s 0\

P I

I,'

5-17

a. Records and drawings detailing plant design changes and modifications made to systems and equipment as described in 5.3.4 ..

b+ Records of al3. environmental surveillance data.

c. Records to demonstrate compliance with the limiting conditions in Section 2.

Ai'ther records and logs relating to the environmental technical specifica-tions shall be ret~~ ed for five years following logging or recording. These she~~ mi elude {but are not limited to) the following:

a.'et~4 'or en'~~-,a"y~"abnormal operating conditions having an effect. on actions taken to correct those conditions.

the

b. P~te"""" activities to environm nt monitoring. equipment, including bu.t not ~~" '" d to:

1) routi e ~~tenanca and component replacement,')

equip= " failures,

3) replacement of principal items of equipment.

c. Records of radioactivity levels in liquid and gaseous wastes released to the env'ro~-ent.

d. All reviews, including actions taken and reasons therefor, required in Sections 2, 3, and 4 of this specification.

10-27-80

STATE OF FLORIDA )

) ss.

COUNTY OF DADE )

Robert E. Uhrig, being first duly sworn, deposes and says:

That'e is a Vice President of Florida Power & Light Company, the Licensee herein; 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.

Robert E. Uhrig Subscribed and sworn to before me this

~<<P- day of l9 FD NOTARY PUBLIC, in and for the county of Dade, State of, Florida Notary Pubgc. State of Ronde et Large thy CornrnLss1on Expires Octobor 30, -1983 Ny COmmiSSiOn eXpireS: 8onded thru Maynard 8onding Agency

A (I

I

( ~~

'I p g

'E4

,I gk -~

J '4

)P

we.'-6'p.

FLORIDA POWER & LIGHT COMPANY October 27, 1980 L-80-354 Office of Nuclear Reactor Regulation Attn: Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Eisenhut:

Re: St. Lucie Unit No. 1, Docket No. 50-335 Proposed Amendment to Facility Operating License DPR-67, A endix B In accordance with 10 CFR $ 550.90 and 50.30 Florida Power G Light Company (FPL) herewith submits three originals and 40 copies of a request to amend Appendix B to Operating License DPR-67 for St. Lucie Unit No. 1. The amendments are described below and where appropriate are shown on the attached Technical Specification pages bearing the date of

,.this letter in the lower right hand corner.

By its, letters dated April 12, 1979 (L-79-88) and September 10, 1979 (L-79-248), FPL requested certain deletions from Appendix B of the St. Lucie Unit No. 1 operating license pertaining to chemical and thermal limits and monitoring requirements.

These requests were made on the basis of ALAB-515 (Yellow Creek), since all of the items for which deletion was requested were contained in the unit's NPDES permit. The initial request "noted that deletion of the biotic monitoring requirements contained in Section 3.1.B and the Special Surveillance and Special Study Activities contained in 'Sections 4.1 and 4.2 of Appendix B was not being requested at that time pending dis-cussion with EPA regarding inclusion/clarification in the NPDES permit. Although these requests have still not received formal NRC approval, Section 4.2, "Impingement of Aquatic Organisms,"

had been previously deleted by NRC on its own accord. (Amend-ment No. 29 to DPR-67, dated January 24, 1979).

On April 3, 1980, FPL submitted to EPA an application for renewal of the NPDES permit for St. Lucie Unit No. l. A copy of that

Mr. Darrell G. Eisenhut Page Two application was forwarded to you at that time. Included as Appendix B to this application, and to be incorporated into the permit, was a revised operational biological monitoring program for St. Lucie Unit No. 1, which would also comprise the preoperational program for St. Lucie Unit No. 2. An application for an NPDES permit for St. Lucie Unit No. 2 will be submitted to EPA in the near future, with a request that a single plant NPDES permit covering both units be issued.

On the basis of the above discussion, FPL hereby requests that Sections 3.1.B and 4.1 of Appendix B to Operating License DPR-67 be deleted upon issuance by EPA of an NPDES permit which contains the proposed biological monitoring program for either St. Lucie Unit No. 1 or both units.

The following additional Sections of Appendix B are being submitted for amendment:

Section 5.1 The Licensing and Environmental Planning Department is now the Environmental Affairs Department. The Director of Quality Assur-ance is now the .Director of Nuclear Affairs.

Modifications to reflect these changes have been made on the affected ETS page.

Section 5.2 Figure 5.2-1 has been modified to reflect the organizational changes noted above.

Section 5.3 - Numerous changes in the titles of those persons comprising CERG membership have occurred.

Organizations are continually evolving and it is likely that changes in the designated CERG membership will again occur in the future.

To preclude the necessity of subsequent up-dating of the ETS to reflect organizational changes, FPL is proposing the adoption of wording for this section which references organizations and titles as little as possible.

The Review and Audit section of FPL's Turkey Point Plant ETS appears to provide this flexibility and, has been the adapted to replace the St. Lucie Unit existing Section 5.3 in No. 1 ETS. Procedural details regarding CERG activities have been, and will continue to be contained in the CERG charter.

Mr. Darrell G. Eisenhut Page Three Section 5.7.l.a Reference to 5.3.3.F.5 is changed to reflect the proposed modifications to Section 5.3.

The proposed amendments have been reviewed by both the Company Environmental Review Group and the Company Nuclear Review Board of FPL. They have determined that the proposed amendments are administrative in nature and will result in no adverse effects on the environment.

FPL has determined that this is a Class II amendment in accord-a check for ance with 10 CFR 170.22 and accordingly encloses

$ 1,200.

Very truly yours, M7 Robert E. Uhrig Vice President REU:TCG:cf cc: Mr. James P. O'Reilly, NRC Region II Harold F. Reis, Esquire Mr. Howard D. Zeller, EPA Region IV Attachment

5.0 Administrative Controls The purpose of this section is to describe the administrative and management controls necessary to provide continuing protection to the environment, and to implement the environmental technical specifications (ETS).

5.1 Res onsibilit The Director, Environmental Affairs Department has the ultimate I responsibility for the implementation of the ETS. He may delegate to other departments and/or organizations the work of establishing and executing portions of the ETS, but shall retain responsibility thereof. The Environmental Affairs Department is responsible for executing the non-radiological biotic and special studies sections of the ETS.

The Vice President of Power Resources is responsible for executing the non-radiological abiotic, radioactive effluents, and the Radiological Environmental Suxveillance sections.

The Director of Nuclear Affairs shall be responsible for periodic audits, conducted according to the coxporate Quality Assurance program, to insure compliance with the ETS.

5.2 Or anization The corporate organization involved in environmental matters is depicted in Figure 5.2-1.

5.3 Review and Audit Administrative measures shall provide that the individual or group assigned the responsibility for auditing or otherwise verifying that an activity has been performed is independent of the individual ox group directly responsible for performing the specific activity. The review function shall be performed by the Company Environmental Review Group (CERG), as described in the Topical Quality Assurance Report, with an audit conducted at least once per yeax. Contractor operations shall also be audited once per year.

CERG is responsible for management review of items 5.3.1 through 5.3.8 below. Xndependent audit functions for 5.3.1 and 5.3.8 below will be provided through the Quality Assurance Program.

5.3.1 Environmental Technical Specifications for the facility.

5.3.2 Results of the environmental monitoring programs prior to their submittal in each Annual Environmental Monitoring Report.

5.3.3 Proposed changes to the Environmental Technical Specifications in effect for the facility and the evaluated impact of the changes.

5-1

EXECUTIVE VICE PRESIDENT VICE PRESIDENT TEC1WOLOGY'OMPANY ADVANCED SYSTEMS AHD NUCLEAR PaVXEH aOARO DIRECTOR DXRECTOR 'VXCE PRESIDENT ENVIRONMENTAL NUCLEAR POHER AFFAIRS AFFAIRS ~ RESOURCES COMPANY EHVIRONMEHTAL REVXEH GROUP MANAGER OF POHER RESOURCES-Vl NUCLEAR I

PLANT MANAGER FACILXTY ~VXEH GROUF ~

&&W&MW&oOW&~

FLORIDA POHER 5 LXGHT COMPANY CORPORATE ORGANIZATION ENVXRONHENTAL AFFAIRS CD I

'FXGUBB 5.2-'3.

I AUTHORITY CO CD CON lUNICATIOH

5.3.4 Proposed changes or modifications to plant systems or equip-ment, which would require a change in the procedures described in 5.5 below, or which have been determined by the Plant Manager to affect the licensed facility's environmental impact.

5.3.5 Proposed tests or experiments which have been determined by the Plant Manager to affect the licensed facility's environ-mental impact.

5.3. 6 Coordination of Environmental Technical Specification (Appendix B to the facility license) development with the Safety Tech-nical Specifications (Appendix A to the facility license) to avoid conflicts and for consistency.

5. 3.7 Proposed sampling analyses, calibration and alarm check procedures, as specified in 5.5.1, and any other proposed procedures or changes thereto as determined by the Plant Manager to affect the licensed facility's environmental impact.

5.3. 8 Investigation of all reported instances of ETS violations including appropriate recommendations to prevent recurrence.

5.4 Actions to be Taken if a Limitin Condition is Exceeded 5.4.1 When a Limiting Condition is exceeded, action shall be taken as permitted by the applicable specification until the condi-tion can be met.

/

5.4.2 Exceeding a Limiting Condition shall be investigated by the Company Environmental Review Group or by the Facility Review Group+

5.4-3 All reviews and actions taken, with reasons therefor, shall be recorded and maintained as part of the permanent records.

5.4.4 Each instance whereby a Limiting Condition is exceeded shall be reported to the Company Nuclear Review Board.

5.5. 5 A report for each occurrence shall be prepared as specified in Section 5.6.2.

5.5 Procedures 5.5.1 Detailed written procedures, including applicable check lists and instructions, shall be prepared and followed for activities involved in carrying out the environmental technical speci-fications. Procedures shall include sampling, data recording and storage, instrument calibration, measurements and analyses, and actions to be taken when limits are exceeded. Testing frequency of any alarms shall be included.

5-3 10-27-80

4 ~

5-17";;

a. Recoxds and drawings detailing plant design changes and modifications made to systems and equipment as described in 5.3.4 .

Records of aI1 environmental suxvei11ance data.

Co Records to demonstrate compliance with the Bed.ting conditions in Section 2.

50702 A~~ othe records and logs relating to the environmental technical specifica-

~~ns sha3~ be retz~"ed for five years following logging or recording. These she~" ~elude (bu" are not limited to) the following:

a'et~4'or a"y abnoxmaI, op rating conditions having an effect on the en%~~=, ~" actions taken to correct those conditions.

b F~te"~" a"t'vities to ervrf.ronment monitoring, equipment, including but not ~~-~- d to:

1) xou ' ~tenance. and component replacement,')

equi"-.~t failures,

3) replan "ent of principal items of equipment.

c. Reco ds of radioactivity levels in liquid and gaseous wastes xeleased to the env'rodent.

'd. A11 reviews, including actions tiken and reasons therefor, required in Sections 2, 3, and 4 of this specification.

10-27-80