ML19220B967

Provides Comments on Second Draft of Program Description Document

ML19220B967
Person / Time
Site:	Crane
Issue date:	12/14/1977
From:	Morris J Office of Nuclear Reactor Regulation
To:	Casey Smith METROPOLITAN EDISON CO.
References
NUDOCS 7904280016
Download: ML19220B967 (10)

Text

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J DISTRIBUTION DEC 1 ' 5 77 occkets(ENVIRON)

DSE Reading EP-2 Reading JANorris Docket No. 50-320 Mr. Courtney byth Vetropolitan Edi:cn Camany P. O. Cox 542 Readi ne;, Pennsylvania 19603

SUBJECT:

TMI-2, Program Description Doctment The Environmental Specialists Branch staff has reviewed the seccnd draft of the Program Gescription Document for THI-2.

In general, this version is consistent with the intent of the ETS, provided that the attached cmments are incorporated. Our revieters are available to caet with you to resolve any outstanding questions.

sbould it be necessary.

Sincerely, W9@tili17 N.'. :M Jan A. Norris, Project Manager Environmental Projects Branch 2 Division of Site Safety and Environmental Analysis

Enclosure:

As stated

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Specific Comments - T?iI, Unit 2, Program Description Document Temperature, pH, Siccide, 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 identification 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 Metbods for Chemical Analysis of Water and Wastes), provide the descriptive name of the technique and the detection limits, accuracy, and precision.

_Tempe ra ture 1

The cooling tower operation limits described in 2.2.4 and 2.2.5 of TMI, Unit 2, Operating Procedure 2104-3.8 (submitted previously) must be modified to be consistent with the currently applicable NPDES permit number PA-0009920. These limits should be included in this P'ogram r

Description Document (PDD) for NRC review.

84 199

f.

Specific Cc==ents on GP 1448 Rev. J.

For the section addressing pH:

1.

Add "at all ti=es during discharge" to the end of the first sentence.

2.

In the second sentence, indicate the type of sa=ple to be taken, where it will be taken f rem, when it will be collected in reference to the discharge sequence, and how of ten samples will be taken (if more than one sample is taken during a giren release period, indicate the timing or frequency of sa=pling in relation to the initiation of neutralizing trak discharge).

3.

In the second sentence, indicate the method of weasurement to be used or provide the applicable reference (e.g., ASTM or Std. Methods), the accuracy and the precision of the method.

4.

Indicate the corrective action to be initiated if measurement shows an out-of-compliance 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 31ocide:

l.

Delete "shall be" in the first sentence and replace with "is".

2.

La the first sentence, indicate when, in relation to the initiation of chlorination, the sa=ple is to be taken. Also, indicate that the sampling referred to will coincide with the sampling and analysis for free available chlorine under the requirements of the NPDES per=it.

84 200

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_4 3.

In the third sentence, provide a reference f r the amperceetric 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 chlorine mapping program is more stringent than that condition stated in ETS 4.1.

Howe ve r, the criterion as stated here ia acceptable to the staff.

For the

.cticn addresssing Chemical Release Inventory:

1.

';he restriction on record keeping to enly caustic, acid and chlorine in the first sentence is not consistent with the intent cf 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 cct=ent.

A " general" category for miscellaneous chemicals could be used.

3.

Indicate -5at the tabulation of release data to be maintained in the plant operating ecords will show dates, duration, amount and types of chemicals released (see ETS 3.1.1.a. (5), paragraph i/2).

84 201 O

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. 4 Indicate the annual su==ary report of releases to be prepared for the Annual Operating Report (tabulation ecntent to be described in this precedure).

5.

Indicate the proposed reporting interval for the su==ary for each chemical type anticipated to be reported under this progra= (e.g., NaOH-monthly, NALCO 41 weekly).

84 202

< Specific Cc==ents on GP 1449 Rev. O, Water Quality Analysis 1.

Include the "Discussien and Responsibilities" section as previously submitted.

2.

Include the "Prceautiens" section as previously suacitted which identifies the procedures to be used in handling and preserving water quality sa=ples.

For "A.

Field Measurements":

1.

Insert " procedures and frequency" after "calibratian" in the seccnd sentence.

2.

In I.l., indicate the detection ll=its and the accuracy of the field the r=o=e t e rs.

3.

Delete I.2.

4.

Delete "i =ediately" in I.3.

5.

Under II. pH, indicate the =ethod to be used for pH determination and give the accuracy, precisien and detection li=its of the =ethod.

6.

Delete II.2 through II.S.

7.

For III. Dissolved oxygen, same cec =ent as #5, 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".

84 203 h

t For C.

Sample Analyses:

1.

Delete I.1, I.2, and I.3.

2.

In I.4, indicate the limits of detection, accuracy and precision of the instru=ent.

3.

Delete II.1, II.2 and II.3.

4.

In II. 4, s ame cc==en t as #2, above.

5.

Delete III.,

IV., V. and VI.

See general coc=ents.

Fo r D.

Data Handling:

1.

In the list of data to be recorded on GPF 1449.003, add "=ethod of analysis if different than that stated in the procedure":

For F.

Quality Centrol:

1.

Add "during 'each sa=pling interval" to the end of the first sentence.

, 2.

Indicate for each duplicate sa=ple taken, which analyses are to be performed.

3.

Indicate the core trive action and reporting to be taken in the event that the measure =ents perfor=ed on the split sa=ples indicate widely different results.

84 204

Senthic Macrainvertebrates - GP 1450, 8/31/77 No comments.

Ichthyoolankton - GP 1451, 8/31/77 1.

Add the needed re ferences.

Fish - GP 1452, 8/31/77 1

Add the needed references.

2.

Add maps and descriptions of statinn locations for seine and electro fis hi ng.

3.

There is a problem with the seining precedures 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 soecific 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 - codify to read:

Sampling shall be conducted semimonthly throughout the year except during liay and June when it shall be weekly.

Entrainment of Ichthycplankton - GP 1454, 8/ 31/ 77 No comments.

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. Aerial Remote Sensing - GP 1456, 9/8/77 1.

Add references.

2.

Add the following information from the previous submission:

Accaratus and Attachments Faragraph 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.

Delete the rest of this procedure exceot for the following:

Procedure A.

1 through 7 B.

1, 2, 3 C... la, b E.

1,2,3,4,6 F.

All

_4 Page 8, insert after paragraph 1:

" Complete sets of color photographs cr 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.

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t e Hydraulic Effects - GP 1459, 9/12/77 1.

Use the description of this program submitted previously except:

Delete the section " Apparatus and Attachments".

Erosion Control Inspection - GP 1460, 9/1/77 1.

Add the folicwing information from the previous submission:

Accaratus and Attachments A.

All B.

GPF 1460.C03 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 1461 1.

Add the following information from the previous submission:

Accaratus and Attachments A.

All B.

GPF 1461.003 Precautions All Prereouisites and Recuirements All 2.

Page 3, delete paragraph A under Procedure.

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3.

Delete attachment GPF 1461.001 and GPF 1461.002.

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