ML19290A276

Discusses 770304 Meeting Re Util Ets.Disagress W/Proposed Implementation Measures Re Nonroutine Rept Time Period & Water Quality Limits.Recommends TMI ETS Not Be Issued Until NRC Agreement Reached

ML19290A276
Person / Time
Site:	Crane
Issue date:	03/28/1977
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	Grimes B Office of Nuclear Reactor Regulation
References
NUDOCS 7911010736
Download: ML19290A276 (2)

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4 MAR 2 8 ISil i

NOTE TO:

V. Stallo, Jr., Director, Division of Operating Reactors, DOR FROM:

B. E. Grimes, Chief. Environmental Evaluation Branch, DOR THRU:

D. G. Eisenhut, Assistant Director for Operational Technology, c, DOR

SUBJECT:

ENVIEDRMINTAL TECHNICAL SPECIFICATIONS y.

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. "In responsa to Ed' Case's March 17, 1977 note to you, we have reviewed the l

memo from R. Ballard to B. Rusche concerning the.results of the meeting i

inMr.Rasche'sofficeonMarch4andhaverevie[2dthesampletechnical specifications prepared for Three. Mile Island.

On March 17, B. Grimes met with R. Ballard to discuss a draft memo to

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B. Rusche. ~ We sgree that.the general points made are those decided by

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B. Rusche'in the March 4.1977 meeting (our objectices to this approach mi= but will not be further discussed here).

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l However, we have several disagreements with the implementation measures.

proposed by DSE which are noted below.

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1. ~The time period for non-routine reports should be less than the 30-day I

period suggested. Prompt reporting and action on our part could al-l leviate the magnitude of the environmental impact or place it into a

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j perspective broader than that available to tha licensee, local inter-i venor groups or a permitting state. NRC has an obligation to be re-l sponsive to public interests and sensitivities, and to satisfy

.inquirise from the public and the news media concerning violations at nuclear. power stations. We should, therefore, have notification when

. report levels are exceeded within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or, at a =4nt==,

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period for reporting violations used in the. NPDES permit (which is on o

the order of 5 days).

2.

Water quality limits that are of NEPA significance have been incorporated into the Environmental Monitering portion (Section 3) of the ETS. We belf sve that they should be made part of Section 2, Limiting conditions for Operation, but that Section 2 should be renamed Limiting Conditions for Operation and Report Levels. Putting the report levels in Section 3 allows the surveillance requirements for the report levels to be changed according to the " Procedures" section which means that a change can be made without prior notification or review (but with a 30-day notifica-tion of the change). Placing the report levels in section 2 would reautre

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pre-notification and review of changes to the surveillance require-For example, temperature surve111snee in the TMI-ETS is to ments.

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.be conducted continuously. If TMI decides to change the sampling frequency to quarterly and we are notified of the change 30 days later, we would have no temperature racords for 30 days which could j

.be serious if a fish kill or other unusual event occurred during this period. With the deletion of LCO's as report levels, the t

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I aurveillance of these levels becomes as important as the level itself.

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.-,, w.~ j Te recommand' that TMI-ETS not be issued until the Cowaniasion has approved

.The abandennent of LCO's on watwr quality matters is a this approach.

significant policy consideration. Eowever, the proposed specifications i

could be used as a working draf t with the utility (af ter the changes dis-cussed above have been made) but not formally issued until the TMI license

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other connannts on the THI-ETS have been noted and will be sent directly _

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