ML20212A478

Application for Amend to License DPR-73,consisting of Tech Spec Change Request 56,deleting Current Restrictions on Disposal of Accident Generated Water & Associated Requirements Imposed in Listed Tech Specs

ML20212A478
Person / Time
Site:	Three Mile Island
Issue date:	02/25/1987
From:	Standerfer F GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20212A456	List: ML20212A450 ML20212A478 ML20212A512
References
NUDOCS 8703030359
Download: ML20212A478 (4)

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METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR THREE MILE ISLAND NUCLEAR STATION UNIT II Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Reauest No. 56 This Technical Specification Change Request is submitted in support of Licensee's request to change Operating License No. DPR-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

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UNITED STATES OF AMERICA  !

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. 56 to Operating License DPR-73 for Three Mlle 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 of the Commonwealth of Pennsylvania by deposit in the United States mall, addressed as follows:

Mr. Jay H. Kopp, Chairman Mr. Fred Rice, 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 i GPU NUCLEAR By .

' Director, TMI-2 V l

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% D6, R11 l Dated l

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• . Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. OPR-73 Docket No. 50-320 Technical Specifications Chance Reauest (TSCR) No. 56 The Licensee requests that the attached changed pages (i.e., page V of the index, 1-4, 3.9-3, and 3/4 9-1) replace the corresponding pages and page 3/4 9.2 of the TMI-2 Technical Specifications.

Description of Chance This proposal deletes the current restrictions on disposal of Accident Generated Water and associated requirements imposed in Specifications 1.17, 3.9.13, and 3/4.9.13. Additionally, this proposal revises the Technical Specification index to reflect the above change.

Reason for Change GPU Nuclear letter 4410-86-L-Oll4 dated July 31, 1986, " Disposal of Processed Water" requested NRC approval for disposal of the TMI-2 Accident Generated Water by the evaporation option. This submittal also evaluated the need for a revision to the TMI-2 Technical Specifications and concluded that it was not required. However, based on Section 2.3.5 of the Draft Supplement 2 to the Programmatic Environmental Impact Statement - Three Mile Island, Unit 2 (PEIS), GPU Nuclear understands that the NRC will require the TMI-2 License to be amended prior to disposal of this water.

' Safety Evaluation Justifying Chance Technical Specification 3.9.13 " Accident Generated Water," prohibits the discharge of Accident Generated Water, as defined in Technical Specification 1.17, until approval has been obtained from the NRC. Additionally, Technical Specification 3.9.13 requires that Accident Generated Water be discharged in accordance with procedures approved by the NRC pursuant to Specification 6.8.2. The basis for this requirement is provided in Technical Specification Basis 3/4.9.13, " Accident Generated Water," which states:

"These specifications are provided to ensure compliance with the l

Commission's Statement of May 25, 1979, and the Commission's Statement of

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Policy and Notice of Intent to Prepare a Programmatic Environmental t

Impact Statement of November 21, 1979, which prohibit these actions pending evaluation of the environmental impacts of such actions. The PEIS issued in March, 1981, deferred a decision on the ultimate disposal of processed water. Further Commission action is necessary prior to j release of ACCIDENT GENERATED WATER.

However, the Commission has recognized that there may be emergency situations, not at this time foreseen, which could require rapid action.

!. In these situations, the Commission has indicated its intention to

! consult with the Council on Environmental Quality to the extent practicable."

As stated above, the primary basis for requiring NRC approval prior to discharge of Accident Generated Water is to ensure compliance with the Prograndnatic Environmental Inipact Statement (PEIS). On July 31, 1986, GPU l

l Nuclear letter 4410-86-L-Oll4, " Disposal of Processed Water," provided GPU l Nuclear's technical and environmental justification and requested NRC approval to dispose of Accident Generated Water. This submittal has been supplemented by GPU Nuclear letter 4410-86-L-0178 dated October 21, 1986, which responded to NRC comments on this subject and GPU Nuclear letters 4410-87-L-0018 dated

, February 3, 1987, and 4410-87-L-0023 dated February 18, 1987, which provided additional information on the radiochemistry of the processed water.

GPU Nuclear believes these submittals provide sufficient justification to demonstrate that the disposal of the Accident Generated Water as proposed can be performed safely and that Technical Specifications 1.17, 3.9.13, and 3/4.9.13 should be deleted. Furthermore, the effluent releases from the proposed disposal of Accident Generated Water will be maintained within the limits imposed by TMI-2 Appendix B Technical Specification 2.1.2, " Gaseous Effluents."

Significant Hazards Consideration 10 CFR Paragraph 50.92 provides the criteria which the Commission uses to evaluate a No Significant Hazards consideration. 10 CFR 50.92 states that an amendment to a facility license involves No Significant Hazards if operation of the facility in accordance with the proposed amendment would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated; or

2. Create the possibility of a new or different kind of accident from any accident previously evaluated; or

3. Involve a significant reduction in a margin of safety.

Although the disposal options for the TM1-2 Accident Generated Water differ from the disposal options for liquid wastes outlined in previous evaluations (e.g., THI-2 FSAR), the consequences of these activities are bounded by existing analyses as discussed in Section 7.1 of GPU Nuclear letter 4410-86-L-0114.

GPU Nuclear letter 4410-86-L-0114 further concluded that the disposal options considered would not increase the probability of an accident previously evaluated nor would it create the possibility of a new or different kind of accident. Further, it concluded that the disposal of the Accident Generated Water does not involve a significant reduction in a margin of safety. The analyses presented in GPU Nuclear letter 4410-86-L-Oll4 also demonstrated that i the off-site exposures from the disposal of the Accident Generated Water were l well within the regulatory limits of 10 CFR 50, Appendix I and the limits imposed by Appendix 8 to the TMI-2 Technical Specifications.

Thus, based on the evaluation provided in GPU Nuclear letter 4410-86-L-0114, it is concluded that the changes proposed in this Technical Specification Change Request involve No Significant Hazards as defined by 10 CFR 50.92.

Amendment Class j Pursuant to the requirements of 10 CFR 170, Licensing Fees, an application fee of $150.00 is enclosed.

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