ML20023C903
| ML20023C903 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 05/06/1983 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20023C898 | List: |
| References | |
| NUDOCS 8305180249 | |
| Download: ML20023C903 (10) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION DOCKET NO. 50-320 THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 2 It.troduction By letter dated August 25,1982,(4400-82-L-0127) as amended by letter dated January 24,1983,(4410-83-L-0009) the General Public Utilities Corporation (GPUNC) requested changes to the Technical Specifications of Operating License No DPR-73 for the Three Mile Island Nuclear Station Unit No. 2 (TMI-2). The requeste'd changes to Appendix B of the Operating License No. DPR-73 pertain to the ~ following:
(1) Eliminate activities that are duplicated in the licensee's National Pollutant Bischarge Elimination System (NPDES) permit; (2) Eliminate those programs that have been satisfactorily completed (Section 4 special studies);
(3) Eliminate those programs that are not related to monitoring the integrity of the river system in relation to the cleanup; (4) Modify the General Ecological Survey (Section 3.1.2.a.1);
(5) Eliminate the erosion control inspection section, and (6) Eliminate the discussion on herbicide use.
Discussion and Evaluation Because of the number of changes proposed by the licensee, the staff has addressed each type of modification separately.
8305180249 830506 PDR ADOCK 05000320 P
. 1 Editorial Changes 3.1.a Nonradiological Monitoring (In Part) 3.1.1.a (4) Water Quality Analysis (In Part) 3.1.2.a (1)(b) Ichthyoplankton 3.1.2.a (1)(c) Fish The licensee has requested modificaticns to the above sections to modify the bases or to correct spelling. The wording that discusses the duration of environmental monitoring program has also been revised. As discussed in attachment 1, page 3 of this document, the paragraph discussing fish capture has been retained. Because these changes do not affect the ability of the licensee to monitor the environment as applicable to TMI-2.in its present state, the staff finds them acceptable.
3.1 Nonradiological Monitoring I
The staff has added section C, " Bases for Continued Monitoring." The new section explains the reasons that the staff is continuing to require certain aspects contained in the environmental monitoring programs of the ETS.
3.1.1.a (1) Thermal Characteristics of Cooling Water Discharge 3.1.1.a (2) p)[
3.1.1.a (3) Biocide The licensee has requested the deletion of the subject sections in their entirety. The TMI-2 reactor presently has a decay heat rate low enough that
-the loss of heat to the containment building atmosphere is sufficient to keep the reactor coolant system at an acceptable temperature. Therefore the systems that would be used at a normally operating plant are not necessary to J
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. maintain this temperature level. The decay heat rate decreases with tims with the only credible mode that could reverse this trend being re-criticality.
Numerous analyses have been performed by the licensee and the NRC to verify that with the present level of boration, criticality will not occur. Without a -decay heat source that is magnitudes higher than what presently exists, the use of cooling systems that discharge into Susquehanna will be minimal.
i Also, these requirements are activities that are duplicates of what is required in the facility's National Pollutant Discharge Elimination System (NPDES) Permit.
The NRC has stated in previous correspondence that where duplications occur between i
the NPDES permit and the Environmental Technical Specifications, the ETS require-ments may be deleted. (Reference 1)
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f Therefore unless the licensee requests the restart of TMI-2, significantly alters the use of cooling systems that discharge into the river or modifies the require-ments of the NPDES permit, the staff finds these changes acceptable.
3.1.1. a (4) Water Quality Analysis
' 3.1.1. a (5) Chemical Release Inventory The licensee has proposed the deletion of Turbidity, Alkalinity, Copper (total and dissolved), Zinc (total and dissolved), and Sulfate from the list of physical and chemical characteristics that must be raeasured at the times and sampling locations of the Benthic Macroinvertebrates survey of ETS Subsection 3.1.2 a (1)(a).
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As stated in the previous discussion, unless the licensee requests the restart of l
l TMI-2 or modifies the comparable requirements in the facility's NPDES permit, the staff finds this change acceptable.
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o' 4-3.1.2.a (1)(a) Benthic Macroinvertebrates The licensee has proposed to delete the biomass requirement from the reporting requirements. Additional explanatory wording was also proposed for the bases.
Biomass determination is a standard method of estimating macroinvertebrate abundance and 'has been performed at TMI since the inception of the environ-mental monitoring program. A reduction in sampling stations, sampling frequency and biomass determination would in the opinion of the staff seriously threaten the integrity of the program. Therefore the requested deletion of the biomass requirement is denied. The additional wording for the bases is approved.
3.1.2.a (2) Impingement of Organisms 3.1.2.a (3) Entrainment of Ichthyoplankton The licensee has requested the deletion of-the subject sections in their entirety.
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The staff agrees that based on nine years of data, minimal impacts have been seen at both intakes. Also small fractions of ichthyoplankton have been entrained l
- at TMI-2. Therefore it is the licensee's opinion that additional impingement and entrainment studies are not necessary to monitor clean-up activities. The staff agrees with this assessment and therefore approves the deletion.
4.1 Residual Chlorine Study Program 4.2 Thermal Plume Mapping 4.3 Hydraulic Effects The licensee has requested the deletion cf these sections in their. entirety.
These programs are a duplicatesof the requirements presently contained in the NPDES permit and as stated in reference 1, no longer falls under the juris-diction of the NRC.
In addition, it is the staff's opinion that these parameters need not be monitored by NRC because of the present shutdown status w
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. of TMI-2.
The staff therefore finds the above deletions acceptable.
4.4 Erosion Control Inspection 4.5 Herbicide Applications The licensee has requested the deletion of the above sections because of the historical data that has indicated no significant impact on the environment.
Additionally, the use of herbicides is regulated by the U.S. Environmental Protection Agency and the Pennsylvania Department of Environmental Resources (PaDER). PaDER clso regulates soil erosion control.
1 The staff agrees with the licensee's assessment and therefore finds the proposed changes acceptable.
Environmental Consideration We have determined that the amendment does not authorize a change in effluent typer. or total amounts or an increase in~ power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that the amendment involves an' action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 51.5 (d)(4),
that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.
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. Conclusion Based on the considerations discussed above, we have concluded that:-
f (1) Because the amendmeht does' not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant reduction in a margin of safety, it does not l
involve a significant hazards consideration.
(2) There is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner.
(3) Such activities will be conducted in compliance with the Commission's 1
regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
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l REFERENCE PAGE l
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(1) Memorandum;Shapar, ELD to Denton, NRR, dated December 7,1979;
" Deletion of Limiting Conditions for Operation as to Water Quality l
Requirements and Other Aquatic Monitoring Requirements from Existing Construction Periliits and Operating Licenses" i
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.go ATTACHMENT 1
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REQUIRED CHANGES TO THE GPU/TMI-2 AQUATIC MONITORING PROGRAM i
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2.l' Ben'thic Macroinvertebrates The proposed program of sampling three stations on a monthly basis, April -
November, is acceptable.. This encompasses the period of major biological activity of the River invertebrates. Prior to April and after November, the biological activity is reduced and sampling is difficult due to incle-ment weather and hazardous River conditions.
2.3 Ichthyoplankton l
The proposed program to sample 4 stations along the west shore of TMI does not meet the intent of the monitoring program. Three of the four additional
-stations (Nos. 5, 6, 7) suggested by the licensee should be added. The I
licensee's proposed station No. 8 (1081) should be deleted and replaced -
l with station 1082 located at the southwest tip of Shelley Island. Station 10B2 has been a high density area for ichthyoplankton of important fish species (perch, channel catfish, carp, shiners). Station 1081 located on the upstream portion of Bashore Island has little spawning habitat and low
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planton densities. These four additional stations are located in important fish spawning and nursery areas of the York Hayan Pond. Sampling of these areas is necessary for an assessment of the overall integrity of the Pond in relation to the cleanup of TMI-2.
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This program is acceptable with eight stations, sampled at night on a weekly l
I basis, from April through August. This encompasses the spawning season of the important fishes of the York Haven Pond. Night sampling has been very effective and has provided the ~ historic data used for resource description and impact analysis.
-2.4 Fish Electrofishing The proposal to sample six stations during April through November is accept-a bl e.
Semi-monthly sampling during August and September is acceptable.
Semi-monthly sampling also should occur during the peak spawning months of l
May and June. Monthly sampling during the remaining months of April, July, October, and November is acceptcble. This stratified sampling scheme is acceptable because it is designed to sample more frequently during periods of increased biological activity and appearance of young fish.
Seine Monitoring of the Pond fish resource by seine should be retained. The five stations proposed by the licensee are acceptable. A sixth station (No. 983) should be added at the southwest portion of TMI. This area will be in the L
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- downstream effluent plume area.
It is a productive area for channel catfish, walleye, and darters, and is relatively undisturbed by high river flows. The sampling frequency for monitoring by seine should be the same as for electro-fishing, in order to sample more frequently during periods of increased biological activity.
i Creel Survey The proposal to reduce the sampling frequency of the creel survey program to once per month is unacceptable. The proposed survey year should be April through November. Sampling during December through March may be terminated due to the general absence of angler activity during those months.
This program examines the fishery resource at the human level - people as harvesters and predators, whose perceptions and behavior affect their harvests and consumption. A reduction of sampling frequency by 50% seriously would affect across-year comparisons of fishery data.
General Requirements Sampling methods should continue to be consistent with those currently in effect. The Annual Report should continue to provide the same treatments of data and discussion of findings. A reduction in sampling effort should not result in reduced quality of information, as presented in the Annual Report. Across-year comparisons of data will be more difficult now due to fewer data points, thus more effort will need to be applied in comparing stations with corresponding time periods during previous years. Attention should be given to the key factors noted in the 1980 Annual Report (Section 6.2.3).
Enumeration of diseases, parasites, and anomaly conditions of fishes taken by seine should continue.
Inspection of fishes caught by electrofishing for these conditions also should cccur.
For fishes captured by seine, the ooserved conditions should be presented in the Annual Report by species, condition type, station location, and percent occurrence by species and station.
The fish movements program has been terminated, but any recaptures of tagged fish by seine, electrofishing, or anglers should continue to be reported and discussed in the Annual Report.
The licensee cited the destructive nature of sampling by seine as one reason for terminating this program. The reduced level of sampling now permitted should alleviate much of the problem. Additionally, examination of recent Annual Reports showed that only small portions of the many thousands of fish of some species (that were preserved upon capture) actually were examined in the laboratory. The February 1978 ETS contained the following requirement
, in Section 3.1.2.a. (1)(c) Fish:
"When large numbers of fish are captured which may be in excess of those required for proper analysis, a subsample shall be taken which is representative of the sample as a whole (e.g., by species, size classes, reproductive status). The excess shall be returned."
The above requirement will be retained in the Appendix 8 ETS.
If fishes are returned as excess, gross examinations should be performed for. the presence of disease, parasite, and anamaly conditions.
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