ML19210A650

Tech Spec Change Request 14 Supporting Licensee Request to Change DPR-50,App B Re Method of Analysis Requiring Zooplankton,But Not Phyloplankton,Mortality Studies. Certificate of Svc Encl

ML19210A650
Person / Time
Site:	Three Mile Island
Issue date:	06/13/1975
From:	Arnold R METROPOLITAN EDISON CO.
To:
Shared Package
ML19210A644	List: ML19210A643 ML19210A650
References
NUDOCS 7910300680
Download: ML19210A650 (4)

Text

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METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY A9D PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATI0lt UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 14 This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix B to Operating License No. DPR-50 for Three Mile Island Nuclear Station Unit 1. As a part of this request, proposed replacement pages for Appendix B are also included.

METROPOLITAN EDISON COMPANY ATTEST:

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Vice PrFsident-Generation Sworn and subscribed to me this /3 d A

, 1975 day of _%

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Three Mile Island Nuclear Station Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Licensee requests that certain changes, as hereinafter described, be made in Appendix B of the TMI-1 Technical Specifications. A copy of the affected Pages with these changes indicated are attached.

- TECHNICAL SPECIFICATION CHANGE REQUEST NO. 1ha -

Change Request Page 40, h.1.1.E, Method of Analysis. Insert the word " Zooplankton" in the third line before " mortality."

Reason for Change Request It is the Licensee's belief that the intent of Environmental Technical Specifi-cation 4.1.1 C. , " Method of Analysis," is to require zooplankton, but not phytoplukton, mortality studies. The reason for the Change Request, therefore, is to better state what is believed to be the intended meaning of the subject specification.

Environmental Analysis Justifying Proposed Change It should be noted chat there presently exists no approved method of analysis for determining phytoplankton mortality. Better stating what is believed to be the intended meaning of the specification, therefore, would have no adverse environmental impact in that no matter what the actual intent of the specification, it vould not be possible to perform the subject studies.

Cost-Benefit Analysis Justifying Proposed Change There is no cost associated with this change request in that it serves to only more clearly state what is believed to be the intended meaning of the subject specification. The benefit that would be derived is that any ambiguity that may exist within the Commission, regarding interpretation of the subject specification, would be eliminated, and thus serve to avoid potential questions regarding compliance.

- TECHNICAL SPECIFICATION CHANGE REQUEST NO. Ihb -

Change Request Page 63, 5.6.1, second paragraph: change". . .(25% above background for external dose, or twice background for radionuclide content) . .." to "which were reported in accordance with 5.6.2.b.3."

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Reason for Change Request It is the Licensee's position that deleting the requirement to make the subject 25% above background and twice background presentations would not degrade the effectiveness of the environmental monitoring /contrci program, yet would serve to cut costs. The reason for the proposed change, therefore, is to eliminate the unwarranted costs of having to make the subject presentations.

Environmental Analysis Justifying Proposed Chance No. 28, (Rev. 1)

It is believed that deleting the requirement to make the presentations in question vould have no adverse effect on the environment in that the environmental monitoring / control program would not be degraded. Reasons for having made this determination are as follows:

a. Plant operations which would result in exceeding either the 25%

above background or twice background levels would most likely result in exceeding either h ti=es the control station value, or both h times and 10 times the control station value, which levels require reporting in accordance with sections 5.6.2.b.3) and h), and

b. for those situations in which either the 25% above background or twice background levels are exceeded, but the h times level is not exceeded, it is believed that these levels are usually the result of variations in background levels.

Further, it should be noted that recent draft regulatory guidance has served to confirm the lack of relevance of the presentations in question in that they are not specified requirements, that such requirements have not been imposed on more recent licensees, that these same types of presentations will, as a result of this change, be made at the ten times the control station value in conjunction with specification 5 6.2.b.3, and that non-routine reports vill continue to be made at h times and 10 times the control station value in accordance with sections 5 6.2.b.3) and h).

Cost-Benefit Analysis Supporting Proposed Change No. 28 (Rev.1)

Deletion of the requirement to make the two subject pres-ntations muld not cause detrimental effects to the environ =ent, yet would recult i- *

ost savings of at least $1,000 per year (this cost savings votld be c f'.<ed primarily frcm a reduction it. the total number of man-hours required to prepare reports).

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...ange Request No.lk h0 - -

C. Entrainment Semi-monthly at Intake and Pumping Counting and determi-of Plankton h-hour intervals Discharge nation of extent of over a 24-hour Zooplankton mortality l period during identification to the April thru lovest feasible taxon.

October A continuing record vill be maintained to allow comparison of variation of numbers with time.

A continuing aquatic population surveillance program (D and E) shall be conducted during the first three years of operation. The results vill be reviewed at the end of the first 30 months and the program terminated at the end of three years unless the results of the review indicate the need for additional data.

Every Tu veeks, At locations Trap nets Counting, identifica-D. Fish March tL.augh indicated on and tion to the lowest October Figure 1 Shoreline feasible taxon, weighing, Seining determination of repro-duction status and condition. A continuing record vill be maintained to allow comparison of variation of numbers with time. Replicate samples will be taken both inside and out-side the thermal plume.

1492 292 E. Macro- Semi-monthly At location Notes and Counting and identifi-Inverte- April thru indicated on dredges cation to the lovest brates October Figure 1. feasible taxon. A contituing record will be maintained to allow comparison of variation of nu=bers with time.

Replicate samples vill be taken both inside

Change Request No. 10

j. Liquid and gaseous release operating procedure.

k. Reactor trip emergency procedure.

1. Loss of reactor coolant or reactor coolant pressure etergency procedure,

m. Post accident H2 purge procedure.

5.5.3 All procedures described above and all changes thereto will be reviewed periodically under the cognizance of the Manager-Generation Engineering; however, temporary changes to these procedures which do not change the intent of the or'ginal procedure may be made providing such changes are approvem by two members of the Plant Management Staff. Such procedure change approval vill be documented.

5.6 P)an? Reporting Reouirements 5.6.1 _ Routine Reports A report on envirom= ental surveillance programs for the previous six months' operations vill be submitted as part of the Semiannual Operating Report within 60 days after January 1 and July 1 of each year. The first such period vill begin with the date of initial criticality. The report vill be a su= mary of results of the environmental activities for the six month period and an assessment of the observed impacts of the plant operation on the environment.

Individual environmental samples which show significantly higher than nor al levels which were reported in accordance with 5.6.2.b rill oe i.vted in the report. Results of all radiological environmental samples taken shall be su==arized for inclusion in the semiannual report. In the event that some results are not available within the 60 day period, the report vill be submitted noting and explaining the reasons for the missing data. The missing data shall be submitted as soon as possible in a. supplementary report.

The report vill include a su==ary of the quantities of radioactive effluents released from the plant as outlined in USAEC Regulatory Guide 1.21 vith data summarized on a monthly basis following the format of Appendix A thereof. If statistically significant variations of offsite environmental radionuclide concentrations with time are observed, a comparison of these results with effluent releases shall be provided.

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N DOCKET NO. 50-289 OPERATING LICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY This is to cert!.fy that a copy of Technical Specification Change Request No.14 to Appenc'.x B of the Operating License for Three Mile Island Nuclear Station, hit 1, dated June 13, 1975, and filed with the U.S .

Nuclear Regulatory commission June 13, 1975, has this 13th day June,1975, been served on the chief executives of Londondcrry Township, Dauphin County, Pennsylvania, and of Dauphin County, Pennsylvania, by deposit in the United States Mail, addressed as fo]1ows:

Mr. Weldon B . Arehart, Chairman Mr. Charles P. Hoy, Chairman Board of Supervisors of Board of County Commissioners of Londonderry Township Dauphin County R.D. #1, Geyers Church Road Dauphin County Courthouse Middictown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120 METROPOLITAN EDISON COMPANY By Vice Fresident-Generation 1492 294

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DOCKET NO. 50-289 OPERATING LICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY This is to certify that a copy of Technical Specification Change Request No.14 to Appendix B of the Operating License for Three Mile Islar.d Nuclear Station, Unit 1, dated June 13, 1975, and filed with the U.S .

Nuclear Regularory Comission June 13, 1975, has this 13th day June,1975, been served on the chief executives of Londonderry Township, Dauphin County, Pennsylvania, and of Dauphin County, Pennsylvania, by deposit in the United States Mail, addressed as follows:

Mr. Weldun B. Arehart, Chairman Mr. Charles P. Hoy, Chairman Board of Supervisors of Board of County Comtissioners of Londonderry Township Dauphin County R.D. #1, Geyers Church Road Dauphin County Courthouse Middletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120 METROPOLITAN EDISON COMPANY By M / _

Vice P' resident-Ceneration 1492 295