ML20198A300

Application for Amend to License DPR-73,consisting of Tech Spec Change Request 52,changing ETS for Consistency W/Rev 3 to NUREG-0472 & Rev 1 to Radiological Assessment Branch Technical Position on Environ Monitoring

ML20198A300
Person / Time
Site:	Three Mile Island
Issue date:	05/16/1986
From:	Standerfer F GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20198A290	List: ML20198A286 ML20198A300 ML20198A305
References
RTR-NUREG-0472, RTR-NUREG-472 NUDOCS 8605200411
Download: ML20198A300 (6)

Text

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ETROPOLITAN EDISON COWANY JERSEY CENTRAL POWER AND LIGHT COWANY PENNSYLVANIA ELECTRIC COW ANY GPU NUCLEAR THREE MILE ISLAND NUCLEAR STATION UNIT II Operating License No. OPR-73 Docket No. 50-320 Technical Specification Change Request No. 52 This Technical Specification Change Request is submitted in support of Licensee's request to change Operating License No. OPR-73 for Three Mile Island Nuclear Station Unit 2. As a part of this request, proposed replacement pages for Appendix A are also included.

GPU NUCLEAR By VicePrehident/0irpbor Sworn and subscribed to me this /d day of h4t.L , 1985.

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//tyk Notary Public CO~lTTAllCE H. MENGEL MTARY Pt8BtlC M100ltTOWN BOR0. DAUPXit! COUNTY ET COM5t$310N (XPIRES MARCH 20,1989 Waabet, Pemsyhuna Assodeuen of Coleries 8605200411 860516 PDR P

ADOCK 05000320 PDR L.

UNITED STATES OF AERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET NO. 50-320 LICENSE NO. DPR-73 GPU NUCLEAR This is to certify that a copy of Technical Specification Change Request No. 52 to Operating License DPR-73 for Three Mile Island Nuclear Station Unit 2, has been filed with the U.S. Nuclear Regulatory Commission and served to the chief executives of 1) Londonderry Township, Dauphin County, Pennsylvania, 2) Dauphin County, Pennsylvania, and 3) the designated official for the Commonwealth of Pennsylvania by deposit in the United States mail, addressed as follows:

Mr. Jay H. Kopp, Chairman Mr. John E. Minnich, Chairman Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Court House Middletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection PA Dept. of Environmental Resources P.O. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR By A Vic~ePresident/Dirf6 tor,TMI-2 141A / b, ///4

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Three Mlle Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Technical Specifications Change Request (TSCR) No. 52 The licensee requests that the attached pages 3.2-1, 3.2-2, 3.2-3, 3.2-4, 3.2-5, 3.2-6, 3.2-7, 3.2-8, 3.2-9, 3.2-10, 3.2-11, 3.2-12, 5-7, 5-8, and 5-9 replace the existing pages 3.2-1, 3.2-2, 3.2-3, 3.2-4, 3.2-5, 3.2-6, 3.2-7, 3.2-8, 3.2-9, 3.2-10, 3.2-11, 5-7, 5-8, and 5-9 of Appendix B (Environmental Technical Specifications).

The purpose of this revision is to correct typographical errors in the existing specifications, delete non-essential monitoring requirements, and to make the Environmental Technical Specifications consistent with the Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors (NUREG-0472, Revision 3, 1983). Justification for deviations from the guidance of NUREG-0472 are provided herein.

Reason for Change The licensee is proposing the following changes to make the TMI-2 Environmental Technical Specifications consistent with Regulatory Guidance and t,o update the Technical Specifications to reflect current TMI-2 operations.

Section 3.2.1 - This section is modified to be consistent with the requirements as specified in NUREG-0472, Revision 3 and other internal requirements.

Table 3.2 The table is being modified to be consistent with the requirements of NUREG-0472. Specifically frequencies of samplir: and analysis have been changed from a specific number of days to a cu endar period (e.g., 7 days has been changed to weekly).

The number and location of sample locations are being changed to reflect THI-2 practices and current regulatory requirements.

Iodine-131 analysis requirements are being deleted to reflect the fact that Iodine-131 is no longer present in detectable quantities at TMI-2.

Table 3.2 This table is being modified to be consistent with current regulatory format. Additionally, Iodine-131 LLDs are being deleted since it is no longer present in detectable quantitles at TMI-2.

Table 3.2 Iodine-131 is being deletad from this table since it is no longer present in detectable quantitles at TMI-2.

Section 3.2.2 - This section is being modified to be consistent with NUREG-0472. Specifically, changes to the land use census will not be submitted to the NRC via a 30-day special report. Instead, the changes will be identified and justified in subsequent Semiannual Effluent Release Reports.

Section 3.2.3 - This section is being modified to incorporate editorial type changes.

Section 5.6.1 - This section is being modified to be consistent with the requirements of NUREG-0472. Specifically, the change deletes the requirements to submit the Annual Radiological Environmental Operating Report as a separate report. Other changes are editorial and reflect current THI-2 conditions.

Section 5.6.2 - This section is being modified to be consistent with the requirements of NUREG-0472. Specifically, reports required in Section 5.6.2.d are being deleted from this section since the requirements are previously stated in Section 3.

Safety Evaluation Justifying Change Section 3.2.1 - The proposed change is administrative and does not effect the current monitoring or reporting requirements. Reference to the ODCM was deleted to make the words consistent with NUREG-0472. Table 3.2-1 still specified the ODCH as the listing for sample locations.

Changes to reporting requirements from 30 to 60-days for effluents exceeding reporting levels of Table 3.2-3 is a reasonable reporting period since Strontium analysis takes up to 45 days to obtain results. Maintaining the requirements at 30 days could result in incomplete reports. Additionally, 60 days is consistent with filing requirements for the Quarterly Dose Reports required by Section 5.6.1 of these Technical Specifications.

Table 3.2 The proposed deletion of Iodine-131 analysis requirements have no effect on the health and safety of the public since Iodine-131 does not exist in detectable quantities at THI-2. Iodine-131 has decayed approximately 320 half-lives since cessation of operation at TMI-2.

Proposed changes to the sampling analysis terminology are administrative and do not effect the monitoring program.

The proposed changes to portions of the sampling program differ in some areas from the guidance of NUREG-0472. Justification for these variances are as follows:

Fish and Invertebrate Sampling

1. There are no commercially important fishes or invertebrates available in the TMI reach of the Susquehanna River. Hence, this designation is deleted.

2. The sampling of groups rather than individual species is preferred based on prior collection experience. Individual species sampling typically results in insufficient quantities to meet analysis requirements. (At a minimum, a 2 Kg sample is required to perform all analyses and meet the analytical sensitivities.) Fishes which are typically consumed by the public are grouped (composited) into samples based en their method of feeding, i.e., bottom feeders and predators.

3. No fishes in the TMI reach of the Susquehanna River are seasonal.

Therefore, this designation should be deleted. Sampling will be performed twice per year. Spring and fall are recommended because these are the most biologically active times of the year.

Sediment Sampling

1. The requirement for sediment sampling at both an indicator and control location has been retained. Only the sampling of an indicator location is recommended by NUREG-0472 and the BTP.

2. The sampling and collection frequency for sediments should be the same as that of fish. By doing so, a comparative study of radionuclides detected in both media can be performed. Sediments may be a source of radionuclides to aquatic biota.

Food Product Sampling

1. Both the BTP and NUREG-0472 recommend food product sampling from areas that are irrigated by water in which 11guld plant wastes have been discharged. This requirement should be deleted because no irrigation with river water is practiced in the TMI area.

2. Sampling of broad green leafy vegetation (at one indicator station and one control station during the harvest season) has been retained even though NUREG-0472 and the BTP recommends sampling only if milk samples are not collected. The TMI REMP does include routine sampling of milk samples.

Groundwater Sampling

1. GPU Nuclear letter LL2-81-0041 dated May 22, 1981, G. K. Hovey to L. H. Barrett addresses the potential of TMI-2 groundwater reaching offsite residential wells. Figure 1, attached, shows the profile of the groundwater basin in the TMI-2 areas. As can be seen from the Figure, the preferred flow is towards TMI-2. Thus, it is unlikely that THI-2 groundwater could affect offsite groundwater supplies. Therefore, offsite groundwater monitoring is not necessary.

Table 3.2-2 and 3.2 The proposed deletion of Iodine-131 has been previously addressed. Other changes are editorial and have no effect on the TMI-2 environmental monitoring program.

Section 3.2.2 - The proposed changes are administrative and do not effect.the TMI-2 environmental monitoring program. The change of reporting requirements is consistent with the requirements of NUREG-0472 and do not affect the health and safety of the public.

Section 3.2.3 - The proposed changes are administrative and do not affect the TMI-2 environmental monitoring program.

Section 5.6.2 - The proposed changes in this section address changes in reporting requirements to be consistent with the requirements of NUREG-0472.

Deletion of reporting requirements in this section have no effect on the THI-2 monitoring program or health and safety of the public since these requirements are stated elsewhere in the Environmental Technical Specifications.

Stanificant Hazards Evaluation

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In accordance with the requirements of 10 CFR 50.91(a)(1), the licensee has evaluated the proposed Technical Specification Change Request against the standards of 10 CFR 50.92 in order to determine if the proposed change constitutes a significant hazard. This change constitutes administrative changes to achieve consistency with other portions of the Technical Specifications and changes to conform the existing Technical Specifications to current regulations. None of the proposed changes affect the operation of facility nor do they affect the amount and/or types of any effluents.

Therefore, the proposed change does not constitute a significant hazard.