ML19220B357
| ML19220B357 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/19/1978 |
| From: | Berkson H Office of Nuclear Reactor Regulation |
| To: | Norris J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7904250668 | |
| Download: ML19220B357 (10) | |
Text
1' o
JAN 1a T3 F.EMCF%iCUP. FOR: Jan :4crris, Project !'anager, Environmental Frojects Branch #2, Division of Site Safety and Environmntal Analysis FRCH:
Earold Berkscn, Senior Enviremental Specialist, Environe ntal Specialists Branch, Division of Site Safety and Environmental Analysis ThFu:
Ronald Ballard, Chief, Environtental Specialists Branch, Civision of Site Safet/ and Envircreental Ar.alysis
SUBJECT:
TMI UNIT 2 ETS - TE1.EC0!4 WITH /PPLICANT On Decc52:er 14,1977 I received cc:ments by telephone frua Courtney Scyth of Metropolitsa Edison concerning the proposed non-radiological envircreentai technical specifications for the :,oeration of TMI Unit 2
In tne main, his, coc=ents dealt with editorial changes. l'est have t,een incorporated into tne ETS though there are several still unresolved. A su:x:ary of his cca::ents and my imediate reactions reflecting our discussion is attached.
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enw Harold Eerkson, Senter Envirenantal 5:nu:ialist Environmntal Specialists Branch Division of Site Safety and Environe: ental Analysis Attachant:
DISTRIBUTION:
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SUMMARY
OF TMI CCMPEliTS Oil ETS INOVEMBER 17, 1977 VERSICil) -
RECEIVED BY TELEPH0iiE FROM C. SMYTH TO H. BERKSCfl CECEMBER 14, 1977 The page references apply to the flavember 17, 1977 version of TMI-2 ETS.
1.
p.i.
Change table of contents to provide for radiological ETS.
Resconse: This document is exclusively concerned wit;; non-radiological ETS. The radiological ETS will be spliced in by the EPM at the time of final issuance of the ETS and coerating license.
2.
p.i.
Change page numbe. ing system to a format which will a facilitate subsequent amendments without re-numbering all folicwing pages.
Msronse: The page numbering system has been changed as indicated in the Cecember 29, 1977 version.
3.
p.a. Line 19. Typographic error-change " Spectral Branch" to " Spectral Band."
Resconse: Agree. Corrx *icn made.
'<ir 2.19
e Suma r; 4 p.6.
First paragraph.
It should be explicitly stated that the environmental monitoring programs required under these ETS would become effective as of the date that tne operating license is issued.
Resconse:
Insert the following af ter "ETS" on line 3, "The environmental monitoring requirements shall beccme effective as of the date that the operating license is issued."
5.
p.6. Fi rst paragraph, line 7.
Change " plant" to " station
Resconse: Agree.
Change made.
6.
p.6. Last line. Typographic error.
" data" should be "date" Resconse: Agree. Correction made.
7.
p.3. Last paragrapn, line 6.
Change " stream" to "diecharge" in order to conform with NFCES.
Rescanse: Agree. Change made.
8.
p.10, second paragraph, See comment number 4 Resconse:
Insert the following after " Unit 2" in line 2:
" subsequent to issuance of the operating license."
'ib 220
e Summa ry 9.
p.12. Second paragraph. See comment number 4.
Rescense:
Insert the follcwing af :er " systems" in line 2:
" subsequent to issuance of the operating license."
10.
p.15. Second paragraph, line 3.
Typographic error, Delete the final
'k' f rom " Lake Frederick."
Resocnse: Agree. Change made.
'l.
p.15. Paragraph 2, line 6.
Change the word " plant" to " station" for clarity.
Response: Agree. Change made.
12.
p.16. First paragraph, line 4 and 5.
Typographic error. Delete redundant phrast :
"the system from which the chemical name."
Resconse: Agree. Deletion made.
13.
p.16. Third paragraph, line 2.
Typcgraphic error.
" Unit 1" should read " Unit 2."
Response: Agree. Correction made.
14 p.16. Third paragraph. See coment number 4.
Resocnse:
Insert the follcwing af ter " Unit 2" in line 2:
"sub-sequent to issuance of the operating license."
Yb-221
~
9 Suma ry 15.
p.17. Third paragraph, line 4 Typographic error.
" data" should be "date."
Resoonse: Agree. Correction made.
16.
p.21. Second paragraph, line 4.
Request clarification of precise meaning cf the word " validly" as used here.
Rescanse: Change wording. Delete the word " validly" and insert the words "and related" betweel "ccmpared" and "with" on line 4 17.
p.21. Third paragraph, last line. Objection to use of the tem "etc."
because it is imprecice.
Resoonse: Agree. Delete the term "etc" and the parenthesis.
Insert the term "e.g.," between the words, "whole" and "by species."
18.
p.22. First paragraph, line 9. Missing words make the sentence unclear.
Resoonse: Agree.
Insert a period af ter " impact" and start the following sentence with the words "hese scecies are..."
19.
p.22. Second paragraph, line 2.
Typograpnic error.
The second "in" should be "or."
Resoonse: Agree. Correction made.
20.
p.23. Last ::aragraph, line 2.
The word " plant" should be changed to " station."
Res::cns e : Agree. Change made.
<b'222
i h
Suma ry 21.
- p. 24 First paragraph, line 6.
Change the word " plant" to read
" Unit 2*.
Resoonse: Agree. Change made.
22.
- p. 30.
Thi rd paragraph, line 1.
Typographic error.
" Data" should read "Date."
Resconse: Agree. Correction made.
23.
- p. 30.
Fi fth paragraph, line 2.
See comment numcer 4 Resoonse:
Insert the following after the word " discharges" in line 2: "from Unit 2 subsequent to issuance of the operating license".
24, p. 31. Third paragraph, line 3.
Change the word " plant" to "s ta ti on ".
Resconse: Agree. Change made.
25.
- p. 32.
Thi rd paragraph. Language dealing with the duration of this program is not consistent with
- 1* used elsewhere in the ETS.
Response. Agree. Replace the wcr ~ "for the li fe of the station" in line 2 with "until approval for modification or ternina. ion of the Requirement is obtained from the NRC in accordance with Subsection 5. 7.1. "
2 ti.
- p. 32.
Last paragrapn, line 2.
Typographic error
" insure" is nisspelled.
Resoonse: Agree. Chang, "i ns ure" tc " ens ure".
'& 223
S umna ry 27.
- p. 3a.
First paragraph, lines 3 and 4 Request deietion of the phrase "or that could be of public interest... station operaticn."
on the basis that it does not provide adequate guidance to the licensee as to what would be included.
Resconse: Disagree.
It is necessary for effective regulation responsive to public concerns that NRC be informed prceptly of unusual or important events that are of public interest.
It is unlikely that normal operation of the station would cause so many events that could be of public interest that an unnecessary burden would be placed on the licensee by possible excessive reports.
If many reports are necessary, it is even more importa.it that NRC be alerted to the problem. Further, it is doubtful that reasonable and responsible managers of the station would be confounded as to what constitutes an unusual or important event that is of public interest.
28.
- p. 3a.
First paragraph, last line.
Request r-1
]m the requiremant to report violations of relevant permics and certi fica-tions because NRC woulc at be interested in all the violations that might occur.
Resconse.
Disagree.
It is essential that NRC be noti fied of violation of t permits and certi fications issued by other agencies because some of the ETS requirements are coucned in terms of compliance with 3pplicable permits, sucn as the NPDC:.
If the W
i
~
e S umma ry NRC were not to receive such notice of violations, there would be no way of knowing whether the requirements of the ETS were being me t.
The reports of violations also alert the staff to environmental problems that might require action.
29.
- p. 35.
Second paragraph, line 1.
Change " plant" to " station".
Resconse: Agree.
Change made.
30.
p.
35.
Thi rd paragraph.
Combine this paragraph with the last paragraph on the page.
Resconse: Delete paragraph because it is redundant with last paragraph on page.
31.
- p. 35.
Fi fth and sixth paragraphs. Delete reference to Quality Control Section and refer to the responsible review and audit authority as the Quality Assurance Department. This change is necessary because of an error in the original TMI submission of the Review and Audit subsection.
Resconse: Agree.
Change made.
32.
- p. 37. Last paragraph, last sentence.
Revise language concerning currently applicable 401 certificate to reflect the fact that the Commonwealth of Pennsylvania did not amend the original 201 certificate but reolaced it with a new one on November 9,1977.
Res con se_: Agree. Amend the sentence to read "
. set forth in the 401 certification dated Novemcer 9,1977, or its currently acplicable revision, issued.
Y$3'225
9 Summa ry 33.
- p. 38. Second paragrapn, line 2.
Delete the pnrase "for all...
Carrying out" because it is too broad.
Resocnse: A gree. The phrase is removed and replaced with the words "to i mplemen t".
34
- p. 38.
Third paragrapt ines I and 2.
Change the word " plant" to
" station".
Resconse: Agree.
Ch...
m,ce 35.
- p. 39. Last parco apa.
"b.n re ret aal numcering system frca roman to arabic numera:s 'or cnnsi~;mtcy with other parts of the ETS.
Resconse: Agree. Chargas made.
35.
- p. 39.
Last paragraph, line 5.
Identi fy the body
'.o whom testimony was presented.
Response. Agree.
Delete "at the hearing" and replace it with "to the Atomic Sa fety and Licensing Board".
37.
- p. 40.
Second paragraon, line 1.
Replace "those procedures" with "the Program Cescription Document" for clarity.
Rescense: Agree.
Change made.
38.
- p. 40. Last paragraph, line 1.
See comment and response number 37.
33.
- c. 41.
First paragraph, lines 4 and 5.
Replace the word " plant" wi th s ta ti on ".
Resconse: Agree. Change made.
's~226
Summary 40.
- p. 41.
Second paragraph, line 4.
See comment number 4 Resconse: After the word " criticality" insert the following:
" subsequent to issuance of the operating license."
41.
- p. 41.
Second paragraph, last sentence. Modify language to be less all-inclusive concerning action taken by the licensee per Sections 2 and 5 of the ETS.
Resconse: Delete the phrase " include full information concerning all" and replace it with " identify and discuss" pending.'4RC receipt of suggested new language from TMI.
42.
- p. 42.
Fourth paragraph. Th '. paragraph seem out of place under Subsection 5.5.2.c.
Resconse: Agree. Delete this paragraph because it is redundant to Subsection 5.6.1.A.
43.
- p. 43.
Line 'a' of the last paragraph. Relate the requirement more scecifically to environmental effects.
Resconse:
Insert the following af ter the word " equipment:"
"which could potentially affect ne environment."
,