ML14204A368

Response to Request for Additional Information Regarding License Amendment Request No. 231, Application to Revise Technical Specifications to Revise Ultimate Heat Sink Temperature Limit

ML14204A368
Person / Time
Site:	Turkey Point
Issue date:	07/22/2014
From:	Kiley M W Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-2014-232
Download: ML14204A368 (7)

Text

0I IPL,10 CFR 50.90L-2014-232 July 22, 2014U.S. Nuclear Regulatory Commission ATTN: Document Control DeskWashington, DC 20555-0001 Turkey Point Units 3 and 4Docket Nos. 50-250 and 50-251Renewed Facility Operating License Nos. DPR-31 and DPR-41

Subject:

Response to Request for Additional Information Regarding License Amendment Request No. 231, Application to Revise Technical Specifications to Revise UltimateHeat Sink Temperature Limit

References:

1. Florida Power & Light Company Letter L-2014-216, "License Amendment Request No.231, Application to Revise Technical Specifications to Revise Ultimate Heat SinkTemperature Limit," July 10, 2014.2. Florida Power & Light Company Letter L-2014-226, "License Amendment Request No.231, Application to Revise Ultimate Heat Sink Temperature Limit -Request forEmergency Approval,"

July 17, 2014.3. Email from A. Klett (NRC) to R. Tomonto (FPL), "Turkey Point 3 and 4 Request forAdditional Information

-LAR 231 (TAC MF4392 and MF4393),"

July 18, 2014.Per Reference I and pursuant to 10 CFR 50.90, Florida Power & Light Company (FPL)requested an amendment to the Technical Specifications (TS) for the Turkey Point Nuclear Plant(Turkey Point), Units 3 and 4. The proposed amendment would revise the ultimate heat sink(UHS) water temperature limit from I 00°F to 104'F.Per Reference 2, FPL supplemented the July 10, 2014 application requesting NRC to review andapprove the amendment request as an emergency amendment.

By email from the NRC Project Manager dated July 18, 2014 [Reference 3], additional information was requested by the NRC staff to complete the review. The enclosure to this letterprovides the response to the request for additional information.

The additional information provided in the enclosure to this letter does not impact the nosignificant hazards determination and environmental considerations previously provided inL-2014-216

[Reference 1].Florida Power & Light Company C o9760 SW 344th St., Florida City. Fl. 33035 L-2014-232 Page 2 of 2There are no new commitments made in this submission.

If you have any questions or require additional information, please contact Mr. Robert Tomontoat 305-246-7327.

I declare under penalty of perjury that the foregoing is true and correct.Executed on: July ,2_?, 2014.Very truly yours,Michael KileyVice President Turkey Point Nuclear Plant

Enclosure:

Response to Request for Additional Information Regarding LAR No. 231, Application to Revise Technical Specifications to Revise Ultimate Heat Sink Temperature Limitcc: USNRC Regional Administrator, Region IIUSNRC Project Manager, Turkey Point Nuclear PlantUSNRC Senior Resident Inspector, Turkey Point Nuclear PlantMs. Cindy Becker, Florida Department of Health L-2014-232 Enclosure Page 1 of 5Response to Request for Additional Information Regarding Turkey Point Units 3 and 4License Amendment Request No. 231Application to Revise Technical Specifications To Revise Ultimate Heat Sink Temperature LimitEnclosure L-2014-232 Enclosure Page 2 of 5NRC RAI 4Pursuant to the Endangered Species Act (ESA) of 1973, as amended, the U.S. Fish and WildlifeService (FWS) issued the NRC a biological opinion for American crocodiles at Turkey Point onMay 5, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML061430174),

and this biological opinion was subsequently modified on August 1, 2006(ADAMS Accession No. ML0624201 11). In 2011, the NRC and FWS consulted under theESA's informal consultation procedures at Title 50 of the Code of Federal Regulations, Section 402.13 regarding the Turkey Point extended power uprate. In its October 25, 2011, letterconcluding consultation (ADAMS Accession No. MLI 1306A160),

the FWS stated thefollowing:

Because the effects to crocodiles from the possible slight increase in water temperature and salinity in the cooling canals due to the proposed power uprate are unclear, FPL willincrease their crocodile monitoring efforts in the project area... Should the monitoring reveal measurable, negative effects on the crocodile in this area, it will be considered additional information involving effects on a listed species and NRC (or FPL on theirbehalJf should contact the Service to reinitiate consultation.

Accordingly, the NRC staff are concerned that the LAR to revise the UHS water temperature limit from 100 degrees Fahrenheit

(°F) to 104 'F could adversely affect the population ofFederally threatened American crocodiles (Crocodylus acutus) living on the Turkey Point siteand the designated critical habitat on the plant site.Provide an analysis of the impacts to crocodiles that would result from the temperature increasethat addresses effects to crocodile growth, survival, abundance, and spatial distribution on theTurkey Point site. The analysis should also address any adverse modifications to designated critical habitat on the site. Both the direct impact of the LAR (i.e., increased cooling canalsystem temperatures) and any indirect impacts (e.g., increased salinity resulting from theincreased evaporation rate of higher temperature water) should be addressed.

FPL ResponseIn 2011, Florida Power & Light Company (FPL) increased the crocodile monitoring in thecooling canal system (CCS). FPL and University of Florida (UF) conducted several years of pre-Uprate crocodile monitoring to assess the spatial distribution, growth and survivorship of thecrocodiles.

FPL committed to a minimum of 2 years post-Uprate monitoring to ensure theincrease in temperature and salinity will have no impact to the crocodile population utilizing theCCS. Both Units have been operating in the Uprated mode since June of 2013. The surveysconsist of spotlight surveys every other month (2011-2013) and capture and tagging surveysthree times a year. In 2014, after approval of the Fish and Wildlife Conservation Commission, the spotlight surveys were reduced to quarterly.

The data indicate that the crocodiles aredistributed in the canals with the most concentrated area in the Southern and SW corner of theCCS.

L-2014-232 Enclosure Page 3 of 5The crocodiles utilize the CCS for courting, nesting and basking.

The data in the table belowindicate any increase in temperature and salinity has not had an impact to the crocodiles use ofthe CCS.Year Spotlight Surveys Number of Number ofObservances Captures Nest/Tagged Hatchlings 2011 747 117 15/2682012 675 93 18/2292013 646 102 25/4292014 223' 64 25/398-Through May 2013 and spotlight surveys.

In 2014, reduced from Bi-monthly toQuarterly 2Three more nest expected to hatchFPL has several stations that monitor temperature in the CCS on an hourly basis. Below is atime series temperature plot for 4 of those stations.

The attached map identifies the stationlocations.

Station CCS-3 is a station in the area that is utilized most by the crocodiles.

The dataindicates the temperature fluctuates throughout the year with temperature typically peaking in themonth of July. The factor that restricts American crocodiles across their range is access to freshwater for their hatchlings to develop salt excreting glands. The Turkey Point Nuclear PowerPlant Cooling Canal System is an ideal situation in order for the population to recruit moreindividuals.

Within the CCS there are numerous fresh water and lower saline ponds wherefemales place the hatchlings for the purpose of developing their salt excreting glands.Joe Wasilewski is a wildlife biologist that specializes in working on the natural history of apexpredators (crocodilians) within wetlands of south Florida.

FPL consulted with Mr. Wasilewski and he stated "Since 1978, the numbers of nests and hatchlings have steadily risen, there havebeen 424 successful nests at Turkey Point and 6,597 hatchlings

captured, processed and released.

The question remains as to carrying capacity of the cooling canal system. In April of 2005,American crocodiles were down listed from an Endangered Species to a Threatened Species.

Amajor factor in the down listing was the success of the crocodile nesting at Turkey Point. Eventhough the CCS has historically been a super saline environment, there has always been access tofresh water and less saline refugia.

During the normal course of the year the salinity andtemperature fluctuates on a seasonal basis. Although the CCS temperatures are rising, the interiorponds should be constant in terms of temperature and salinity content.

Crocodiles within theCCS have adapted to these changing salinities and temperature variations.

They have thecapability for access/egress on a daily basis. They typically use the CCS for feeding, nesting andrearing their young. Otherwise they move into and out of Biscayne Bay, C-107, C-106, theInterceptor Ditch." Based on the information provided by Mr. Wasilewski, a slight increase intemperature would likely have no effect on the Crocodile population using the CCS. FPL willcontinue to conduct the surveys described about to assess any potential impacts.

The next surveyis being conducted in August.

L-2014-232 Enclosure Page 4 of 51201101070 --CC5-160 60 -CC"501/1/11 7/20/11 2/5/12 8/23/12 3/11/13 9/27/13 4/25/14Time Series Temperature Plot L-2014-232 Enclosure Page 5 of 5Figure 1 -Turkey Point Cooling Canal Sample Locations earthmiles~ki I IIA