ML19220B032
| ML19220B032 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/09/1977 |
| From: | Ballard R Office of Nuclear Reactor Regulation |
| To: | Norris J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7904250214 | |
| Download: ML19220B032 (10) | |
Text
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ME'!0RANDt.N FOR: Jan A. Norris, Project Manager Environental Projects Branch 2. DSE FRCH:
Ronald L. Ballard, Chief Environ::x!ntal Specialists Branch, DSE
SUBJECT:
TMI UNIT 2 PROGPJUt DESCRIPTION DOCLSENT The Environmental Specialists Branch staff has reviewed the second draft of the above cited doc =ent that was informally submitted to you by Courtney Smyth of 'rtet-Ed.
In general, we find this version to be consirtent with the intent of the ETS, provided the specific cenaents attached are incorporated. Please fonvard our coments to the applicant. The task group is available to met with you and the applicant as necessary to resolve any outstanding questions, should it be necessary.
ors =: 3.cm: a r.J cc2ra Ronald 1.. Ballard, Chief Envirer..aental Specialists Scanch Division of Site Safety and Environmental Analysis Attach:::ent:
Coments cc:
H. Denten M. Ernst V. Moore W. Regan J. Lehr C. Hickey G. Geats H. Bertson
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Specific Comments - Hil, Unit 2, Program Description Document Temperature, pH, Siacide, and Chemical Release Inventory - GP 1448 General Comments For each of the procedures in this grouping include a " References" section that cites:
1.
The additional Met-Ed TMI General Practice Programs that are applicable.
2.
The references to be used for sample treatment and chemical analyses, including identi fication of commercial instrument instruction manuals and model numbers as applicable.
3.
The applicable TMI, Unit 2, Environmental Technical Specifications.
4.
For analysis techniques that are not specifically referable to an accepted methods document (e.g., Standard Methods, EPA Manual of Methods for Chemical Analysis of Water and Wastes), provide the descriptive name of the technique and the detection limits, accuracy, and precision.
Temoe ra tur a 1.
The cooling tower operation limits described in 2.2.4 and 2.2.5 of TMI, Uni t 2, Operating Procedure 2104-3.8 (submitted previously) must ce modified to be consistent with the currently applicable NPDES permit number PA-C::'920. These limits should be included in this Program Description
.; ment (PDD) fc,r NRC r.eview.
^~
_ 2.
Specify location, sensitivity, accuracy of the temperature sensors and their frequency of calibration.
3.
Specify methods of temperature measurement to be used when automatic temperature sensing system is inoperative or out of calibration limits.
Speci fy the locations and frequency of temperature measurements.
4 Modi fy statement concerning results to be consistent with the reporting requirements stipulated in the ETS.
P 72-288
- Specific Cc==ents on GP 1448 Rev. O.
For the section addressing pH:
1.
Add "at all times during dischatge" to che end of the first sentence.
2.
In the second sentence, indicate the type of sa=ple to be taker, where it will be taken fro =, when it will be collected in reference to the discharge sequence, and how of ten samples will be taken (if more than one sa=ple is casen during a given release period, indicate the ti=ing or frequency of sampling in relation to the initiation of neutralizing tank discharge).
3.
In the second sentence, indicate the method of =easure=ent to be used or provide the applicable reference (e.g., ASTM or Std. Methods), the accuracy and the precision of the =ethod.
4 Indicate the corrective action to be initiated if measurement shows an out-o f-co=pliance condition.
If this is addressed in OP 2104-2.11, a referring to the corrective action therein would be appropriate.
state =ent For the section addressing Biocide:
1.
Delete "shall be" in the first sentence and. replace with "is".
2.
In the first sentence, indicate when, in relation to the initiation of chlorination, the sa=ple is to be taken. Also, indicate that the sa=pling referred to will coincide with tha sa=pling and analysis for free available
- hlorine under the requirements of the NPDES per=it.
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. 3.
In the third sentence, provide a reference for the amperometric titration technique to be used, the accuracy and precision of the method and the detection limit applicable.
4.
In the fourth sentence, indicate that all non-routine reports shall be submitted to the NRC and that the date, TRC concentration measured and method of analysis shall be indicated in these reports.
5.
The criterion established for the submittal of the procedures for conduct of the chlorir.e mapping program is more stringent than that condition stated in ETS 4.1.
However, the criterion as stated here is acceptabic to the staff.
For the section addresssing Chemical Release Inventory:
1.
The restriction on record keeping to only caustic, acid and chlorine in the first sentence is not consistent with the intent of the ETS.
Other identified chemical uses at the plant are to be included in the inventory reporting (e. g., NALCO 41-1).
2.
Surveillance Procedure 2325-MI must be expanded in scope to accomodate the above comment. A " general" category for miscellaneous chemicals could be used.
3.
Indicate that the tabulation of release data to be maintained in the plant operating records will show dates, duration, amount and types of chemicals released (see ETS 3.1.1.a. (5), paragraph d2).
7c ' 90 4
. 4 Indicate the annual summary report of releases to be prepared for the Annual Operating Report (tabulation content to be described in this procedure).
5.
Indicate the proposed reporting interval for the su ary for each chemical type ant.icipated to be reported under this program (e.g., NaOH-monthly, NALCO 41 weekly).
em 74-291
1 Specific Cem=ents on GP 1449 Rev. O, '4ater Quality Analysis 1.
Include the " Discussion and Responsibilities" seccion as previously submitted.
2.
Include the " Precautions" section as previously submitted which identifies the procedures to be used in handling and preserving water quality samples.
For "A.
Field Measuremeats":
1.
Insert "proceduces and frequency" af ter " calibration" in the second sentence.
2.
In I.l., indicate the detection limits and the accuracy of the field the rsc7e te rs.
3.
Delete I.2.
4 Delete "i=cediately" in I.3.
5.
Under II. pH, indicate the method to be used for pH determination and give the accuracy, precision and detection limits of the method.
6.
Delete II.2 through II.5.
7.
For III.
Dissolved Oxygen, same comment as 45, above.
8.
Delete III.1, III.2, and III.3.
9.
In III.4, delete the first clause, up to'and including the' word "and".
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For C.
Sample Analyses:
1.
velete I.1, I.2, and I.3.
2.
In I.4, indicate the limits of detection, accuracy and precisica of the instru=ent.
3.
Delete II.1, II.2 and II.3.
4 In II.4, same ce= ment as #2, above.
5.
Delete III.,
IV., V.
and VI.
See general cocaents.
For D.
Data Handling:
1.
In the list of data to he recorded on GPF 1449.003, add "=ethod of analysis if different than that ses.ed in the procedure":
F r F.
Quality Control:
1.
Add "during each sampling interval" to the end of the first sentence.
2.
Indicate for each duplicate sample taken, which analyses are to be performed.
3.
Indicate the corrective action and reporting to be taken in the event that the = essure =ents perfor ed on the split sa ples indicate widely different results.
e 7W 233
e Benthic Macroinvertebrates - GP 1450, 8/31/77 No comments.
Ichthyoplankton - GP 1451, 8/31/77 1.
Add tne needed references.
Fish - GP 1452, 8/31/77 1.
Add the needed references.
2.
Add maps and descriptions of station locations for seine and electro fi s hi n g.
3.
There is a problem with the seining procedures as stated on page 9, paragraph a:
" Size and habitat of seine stations vary and effort is based on complete coverage of the area rather than a specific number of hauls at each station."
This means unequal effort at seine stations and thus a potential noncomparability of the data collected. Data analysis should accomodate for catch per effort so affected and non-affected stations can be more adequately compared.
Impingement of Organisms - GP 1453, 8/31/77 1
Page 3, last paragraph - modi fy to read:
Sampling shall be conducted semimonthly throughout the year except during fiay and June when i t shall be weekly.
Entrainment of Ichthyoplankton - GP 1454, 8/31/77 No comments.
, Aerial Remote Sensing - SP 1456, 9/3/77 1.
Add references.
2.
Add the following information from the previous submission:
Accaratus and Attachments Paragraph 1.
b, c, d Paragraph 3.
Attachments GPF 1456.001, Ground Truth Data Sheet, GPF 1456.002, Plant Field Tally Sheet Paragraph 4 Attachment GPF 1456.005.
3.
Celete the rest of this procedure exceot for the following:
Procedure A.
1 through 7 B.
1,2,3 C.
l a, b E.
1,2,3,4,6 F.
All 4
Page 8, insert after paragraph 1:
" Complete sets of color photographs or color slide transparencies and field records shall be made available to NRC upon request."
Thermal Plume Mapping - GP 1458 1.
Use in full the description of this program submitted previously.
e 7E 295
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- Hydraulic Effects - GP 1459, 9/12/77 1.
Use the description of this program submitted previously e ceot:
Delete the section " Apparatus and Attachments".
Erosion Control Inspection - GP 1460, 9/1/77 1.
Add the following information from the previous submission:
Accaratus and Attachments A.
All 3.
GPF 1460.003 2.
Page 2, delete the paragraph "The transmission line...GP 1460.002."
3.
Delete attachments GPF 1460.001 and GPF 1460.002.
herbicide Applications - GP 1 61 1.
Add the following information from the previous submission:
Apparatus and Attachments A.
All B.
GPF 1461.003 Precauti ons All Prereouisites and Requirements All 2.
Page 3, delete paragrapn A under Procedure.
3.
Deleta attachment GPF 1161.00! and GPF 1461.002.74-29G