ML19260A054

Tech Spec Change Request 33 to Amend DPR-50,App B Re Environ Monitoring.Certificate of Svc Encl

ML19260A054
Person / Time
Site:	Three Mile Island
Issue date:	06/02/1976
From:	Arnold R METROPOLITAN EDISON CO.
To:
Shared Package
ML19260A050	List: ML19260A049 ML19260A054
References
NUDOCS 7910290683
Download: ML19260A054 (11)

Text

a METROPOLITAN EDISON CCMPANY JERSEY CENTRAL PCWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Srecification Chance Reauest No. 33 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 replace = eat pages for Appendix B are also included.

METROPOLITAN EDISON COMPANY By /

Vice President-Generation M

Sworn and subscribed to me this day of , 1976.

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Metropolitan Edison Company Three Mile Island Nuclear Station Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 TECHNICAL SPECIFICATION CHANGE REGUEST No. 33 The licensee requests that the attached changed pages replace pages 57, 61,

, and 63 to 66 of the existing Technical Specifications, Appendix B.

TECHNICAL SPECIFICATION CHANGE REQUEST NO. 33 1 Change Request Page 57, Section h.h, Bases, Paragraph 2. In the last sentence change

" semi-annual" to " annual."

Page 61, Section 5 3, Item D. Change " Semiannual Environmental Monitoring Report" to " Annual Environmental Monitoring Report."

Page 633 Paragraph 1. Revord the paragraph to read as follows:

"A report on environmental surveillance programs for the previous twelve months' operations will be submitted within 90 days after January 1 of each year. The report vill be a summary of results of the environmental activities for the one-year period and an assessment of the observed impacts of the plant operation on the en.ironment."

Page 63, Section 5.6.1, Paragraph 2. Reword the paragraph to read as follows:

" Individual radiological environmental samples which are statistically different from normal levels which were reported in accordance with 5.6.2.2 vill be noted in the report. Results of all radiological environmental samples taken shall be su=marized for inclusion in the annual report. In the event that some results are not available within the 90 day period, the report vill be submitted noting and explaining the reasons for the missing data. The =lesing data shall be submitted as soon as possible in a supplementary report.

Page 63, Section 5.6.1, Paragraph 3 Reword the first sentence to read as follows:

"A Semiannual Effluent Report, to be submitted within 60 days after January 1 and July 1 of each year, will include a summary of the quantities of radioactive effluents released from the unit as outlined in USNRC Regulatory Guide 1.21 - Rev. 1 (June 1974)."

The basic effect of these changes would be to allow the licensee to report environmental surveillance data and radioactive effluent data on an annual and semi-annual basis, respectively, instead of only on a semi-annual basis and to allow an additional 30 days for preparation of the report on environmental surveillance data.

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Reason for Change Request The reason for requesting the proposed change request is to reduce the cost associated with reporting environmental surveillance data and to allow an additional 30 days for preparation of the annual environmental surveillance report.

Environmental Analysis Justifying Pronosed Change Past experience has shown that reporting the subject environmental sur-veillance data on a semi-annual basis does not increase the effectiveness of the environmental surveillance program; therefore, requiring that these reports be submitted on an annual basis vill not have any adverse impact on the environment. Further, with regard to reporting environmentai surveillance data 90 days, instead of 60 days, after the first of the year, there vill be no adverse environmental effects, in that we vill still be required to submit separate reports within 30 days whenever certain background levels of radiation are exceeded.

In addition, it should be noted that USNRC Regulatory Guide 10.1 recognizes the need to submit a report of environmental operating data annually and 90 days, rather than 60 days, after the first of the year.

The presentation of radioactive effluent data on a monthly basis in annual reports is not part of the format suggested by Appendix A, USNRC Regulatory Guide. This requirement is, therefore, deleted from this section.

Cost-Benefit Analysis Justifying Protosed Change There are no additional costs associated with the proposed change, in that it involves only a reduction in reporting require =ents. The principal benefit to be derived from implementation of the proposed change would be a cost savings resulting from a decrease in the number of man-hours normally required to prepare the subject reports. This cost savings would amount to about $20,000 annually.

TECHNICAL SPECIFICATION CHANGE REQUEST NO. 33.2 Change Request Pages 6h-66, Section 5.6.2. Replace all of the existing section with the new Section 5.6.2 presented in the replacement pages.

Rearon for Chance Recuest The reason for requesting the proposed change is to reduce the cost of reporting certain higher-than-background radiati a levels. This will be accceplished 1) by redefining the reporting requirement limits for certain higher than background radiation levels and 2) by requiring only an annual summary - instead of Individual reports - of those instances in which the investigation levels (ref sec. 5.6.2.2) are exceeded.

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A second reason for requesting the proposed change is to allow more time for reporting those instances in which the ten-times-background radiation limit (sec. 5.6.2.2.a.(1)) and Limiting Conditions for Operation (sec. 5.6.2.3) are exceeded.

Environmental Analysis Justifying Procosed Change That aspect of the proposed change relating to reporting of anomalous e radiation levels vould be consistent with recently proposed regulatory guidance on non-routine environmental reporting; therefore, its imple-mentation should have no adverse impact on the environment. Also, the proposed lengthening of reporting times vill not have any adverse impact on the environment in that every time a limiting condition for operation is exceeded it must be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> anyway and for the case in which a ten-times-background level is exceeded the additional allevance of three days vill enable a more thorough examination of causative factors.

Cost-Eenefit Analysis Justifying Pronosed Change There are no.additiona) costs associated with the proposed change in that it involves a general reduction in reporting requirements. The principle benefit to be derived from implementation of the proposed change would be a cost savings resulting from a decrease in the number of can-hours normally required to prepare the subject reports. This cost savings would amount to above $5,000 annually.

TECHMICAL SPECIFICATION CHANGE REQUEST NO. 33.3 Change Reauest Page 66, Section 5.7 1, Item a. Change the reference to "Section 5.6.2.d" to "Section 5.6.2.h."

Reason for Change Request The reason for requesting the proposed change is to make the Technical Specifications consistent with Change Request No. 33.2 above.

Environmental Analysis Justifying Proposed Change Since the proposed change only serves to make the Technical Specifications internally consistent, its adoption vill have no adverse effect on the environment.

Cost-Benefit Analysis Justifying Pronosed Cnange There vill be no costs or benefits resulting from adoption of the proposed change in that the change only serves to make the Technical Specifications internally consistent.

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vill be reported, with associated calculated error, as pico-curies of I-131 per liter of milk at the time of sampling, in accordance with Reporting Requirements for Environmental Radiological Monitoring.

Special attention vill be paid to those locations where milk is produced for direct consumption by humans - e.g., the family

. farm.

d. A census vill be conducted every six months (during the beginning and midpoint of the grazing season) to deternine the location of cows in potentially affected areas.

If it is learned via the census that there are a considerable number of additional locations where milk is produced in the vicinity of the plant, the location (s) nay be chosen which serv 6s as a valid indicator of other locations in that meteorological sector, rather than sampling every location.

Bases The number and distribution of sampling locations and the various types of measurements described in Table 3, together with the pre-operational background data, vill provide verification of the effectiveness of plant effluent control and indication of measurable changes in the activity of the environment.

Weekly sanplen may be missed in the event of adverse conditions such as veather, equipnent failure, etc. It is not intended that these nissed samples be resampled prior to the next scheduled sample date. Monthly and longer period samples, if missed due to these conditions, vill be taken within a reasonable time after the adverse condition no longer exists. All deviations from the sampling schedule shall be described in the annual report.

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A. Coordination of Environnental Technical Specifications develop-ment with the Safety Technical Specifications to avoid conflicts and maintain consistency.

B. Proposed changes to the Environmental Technical Specifications and the evaluated impact of the change.

• C. Evalu ,lon of proposed changes conducted in compliance with 5.lB and 5.lC.

D. Results of the Environmental Monitoring Programs prior to their submittal in each Annual Environmental Monitoring Report.

l E. Reports of investigations of reported instances of violation of Environmental Technical Specifications and associated corrective action.

5.h Action to be Taken if a Limitine Condition for Queration is Exceeded Follow any remedial action permitted by the Technical Specification until the limiting condition can be net.

All instances of exceeding a Limiting Condition for Operation vill be promptly investigated.

, A report of each occurrence of a violation of the provisions in specifications of the Limiting Conditions for Operation of these Environmental Technical Specifications vill be prepared as specified in Section 5.6.2.

5.5 Procedures 5.5.1 The following written procedures will be prepared to ensure compliance with various activities involved in carrying out the Environmental Technical Specifications. Procedures vill include applicable check lists and instructions, sampling, instrument calibration, analysis, and actions to be .taken when limits are approached or exceeded.

Testing frequency of any alarms vill be included. These frequencies will be determined frem experience with similar instruments in similar environments and fron manufacturers' technical manuals.

a. Operation of mechanical draft cooling towers,

b. Operation of chlorination systen, c_. a Disch'rge of neutralized regenerant vastes.

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j. Liquid and gaseous release operating procedure.

k. Reactor trip energency procedure.

1. loss of reactor ecolant or reactor coolant pressure energency procedure.

. m. Post accident H2 purge procedure.

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

5.6 Plant Reucrtine Recuirements 5.6.1 Routine Retorts A report on environmental surveillance programs for the previous twelve months' operations vill be submitted within 90 days after January 1 of each year. The report vill be a summary of results of the environmental activities for the one-year period and an assessment of the observed f.mpacts of the plant operation on the environnent.

Individual radiological environmental samples which are statistically different from normal levels which were reported in accordance with 5.6.2.2 vill be noted in the report. Results of all radiological environmental samples taken shall te rummarized for inclusion in the annual report. In the event that some results are not available within the 90 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.

A Semiannual Effluent Report, to be submitted within Cv days after January 1 and July 1 of each year, vill include a summary of the quantities of radioactive effluents released from the unit as outlined in USURC Regulatory Guide 1.21 - Rev. 1 (June 197h). If statistically signif_icant variationc of offsite environmental radionuclide concentrations with time are observed, a comparison of these results with effluent releases shall be provided.

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- 6h -

5.6.2 Non-Routine Reporis 5.6.2.1 Radioactive Discharce The non-routire reporting requirements for radioactive discharg(s are specified in Section 2 3 of the Environmental Technical Specifications.

5 6.2.2 Radiolocical Environmental Monitoring

a. Anenalous fieasurements (1) If a measured level of radioactivity in any environmental medium, other than those associated with gaseous radiciodine releases, exceeds ten times the mean of the ureoper ttlonal/

overational control station data, or lacking this salae, ten times the applicable control station data, a written notification vill be submitted within ten days, adviring the NRC of this condition.1 This notification should include an evaluation of any release conditions, environ-mental factors, or other aspects necessary to explain the anomalous reault.

(2) If a measured level of radioactivity in any environmental medium, other than those associated with gaseous radio-iodine releases, exceeds the Investigation level, (section (b) below), the following action vill be taken:

(a) C,onfirm data by:

(1) Recc .nt same sample (if possible)

(2) Count second half (duplicate) of sample (if possible)

(3) If (1) and (2) is greater than Investigation Level (or if (1) &

(2) are not feasible), then take a new sample (as representative as

. possible of the old sample) as soon as practicable.

lIn case of a tentatively ancmalous value for radiostrontium, a confirmatory reanalysis of the original, a duplicate or a new sample nay be desirable. In this in, stance the results of the confirmatory analysis shall be completed at the earliest time consistent with the analysis, and if the high value is real, the report to the NRC shall be submitted within ten days following this analysis report.

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(b) Investication Level Criteria for determining when a control station value has been exceeded:

(1) ' 'he c ontrol station value has not been exceeded if there is a 99 95 probability of its belonging to the background or control station data population distribution. This means that 0.1% of the time this value vill be said to be different from the background, when in fact. it is not different.

(2) The limit for this criteria is express-ed as: (la of X x 3.1)+X, where X is the mean and a = one standard deviation. If the data point is greater than background

+ 3.la of backgrcund , then the Investigation level has been reached.

b. ffilk Pathway ffeasurements If milk samples collected over a calendar quarter sh,v average concentrations of h.8 picoeuries per liter or greater, a plan shall be subnitted within 30 days advising the NRC of the proposed action to ensure the plant related annual doses vill be within the design objective of 15 = rem /yr. to the thyroid of any individual.

c. f no.nalous Measurements Unettributable to the Uca~ad Vlant If levels of radiation can be definitely shown to result from sources other than the licensed plant (e.g. from testing of nuclear devices) by similar concentrations found in " background samples that could not be affected by emission from the licensed plant" the reporting utions in items a and b need not be taken. Justification for assigning high levels of radioactivity to sources other than the plant shall be provided in the annual report.

5.5.2.3 Nonradialocical In the event a Limiting Condition for Operation is exceeded, a report vill be made within 2h hours by telephone and telegraph

'to the Office of Inspection and Enforcement - Region 1 followed by a written report within two weeks (cc to the Director of riuclear Reactor Regulation).

The written report and, to the extent possible, the preliminary telephone and telegraph report, vill:

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1) Deecribe, analyze and evaluate the occurrence including extent and magnitude of the impact; ,

2) Describe the cause of the occurrence; and }kfh h )

3) Indicate the corrective action taken (including any significant changes made in procedures) to preclude repetition of the occurrence and to prevent similar occurrences involving similar components or systems.

5.6.2.h Changes

1) When a change to the plant design, to the plant operation or to the procedures described in Section 5.5 is planned which would have a significant adverse effect on the environment or which involves an environmental matter or question not previously reviewed and evaluated by the URC, a report on the change vill be made to the URC prior to implenentation.

. The report will include a description and evaluation of the change including a supporting benefit-cost analysis.

2) Changes or additions to permits and certificates required by Federal, State, local and regional. authorities for the

, protection of the environment vill be reported. When the required changes are submitted to the concerned agency for approval, they will also be submitted to USNRC for infornation.

The submittal vill include an evaluation of the environmental impact of the change.

3) Requasts for changes in Environmental Technical Specifications vil.1 be submitted to the USNRC for prior review and authorization.

The request vill include an evaluation of the impact of the change, including a supporting benefit-cost analysis.

5.6.2.5 other If harnful effects or evidence of irreversible darage are detected by the monitoring programs, the licensee shall provide an analysis of the problem and shall develop a course of action to be taken to allesiate the problems. If the ecology of the river significantly changes at a future date as, for example, by major changes in water chenistry or reintroduction of shad, the licensee shall provide an analysis of expected impacts and a course of action to minimize the impacts.

5.7 Records Retention 5.7.1 Records and logs relative to the following areas vill be retained for the life o'f the plant.

a. Records and drawing changes reflecting plant design changes made to systems and equipment as described in Section 5.6.2.h.

b. Records of environmental surveillance data,

c. Records to demonstrate ecmpliance with the Limiting Conditions for Operation in Section 2.

5.7.2 All other records and logs relating to the Environmental Technical Specifications shall be retained for 5 years.

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g UNITED STATES OF AMERICA NUCLEAR REGULATORY C0!GIISSION IN THE MATTER OF DOCKET NO. 50-289 LICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY This is to certify that a copy of Technical Specification Change Request No. 33 to Appendix B of the Operating License for Three Mile Island Nuclear Station Unit 1, dated June 3,1976, and filed with the U. S.

Nuclear Regulatory Con.aission June 3, 1976, has this 3rd day of June, 1976, been served ca the chief executives of Londou try Township, Dauphin County, Pennsylvania and Dauphin County, Pennsylvania by deposit in the United States rail, addressed as follows:

Mr. Weldon B. Arehart, Mr. Harry B. Reese, Jr.

Board of Supervisors of Board of County Cor:missioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Court House Middletown, Pennsylvania 17057 Harrisburg, ennsylvania 17120 ME30POLITAN EDISON COMPANY

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By (b Vice Prdsident-Generation 1479 097