ML20245A489
| ML20245A489 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/15/1989 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20245A480 | List: |
| References | |
| NUDOCS 8906220040 | |
| Download: ML20245A489 (10) | |
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METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY-i GPU NUCLEAR THREE MILE ISLAND NUCLEAR STATION UNIT II 1
Operating License No. DPR-73
. Docket No. 50-320 Technicial' Specification.1 Change Reauest No. 63 '
The Technical Specification Change Reauest is submitted in support of-Licensee's reauest 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 B are also included.-
GPU NUCLEAR-l l
By Mh Director, TMI Swom and subscribed to me this I5* day of %#
, 1989.
O M >d.NL N Y l
Notary Public NOTARIAL SEAL ERN MCHELLELEBo,NoTARYPUBUC LoNDoNDERRYTWP., DAUPHIN COUNTY MYCOMMIS810N EXPIRES SEPT.11,1989 Member,PenneyhensAssociationofNotaries,
8906220040 890615 DR-ADOCK 05000320
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PDC g
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
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. 63 to Operating License DPR-73 for Three Mile Island Nuclear Station Unit 2 has been filed with the U.3. Nuclear Regulatory Commission and served to the chief executives of 1) Londonderry Township, Dauphin County, l
Pennsylvania; 2) Dauphin County, Pennsylvania; and'3) the designated official i
of the Commonwealth of Pennsylvania by deposit in the United States mail, addressed as follows:
Mr. Jay H. Kopp, Chairman Ms. Sally Klein, Chairperson Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Court House j
Middletown, PA 17057 Harrisburg, PA 17120 i
Mr. Thomas M. Gerusky, Director i
Bureau of Radiation Protection PA Dept. of Environmental Resources P.O. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR Mb By Director, TMI-2 Tont. \\5 M l'\\
Date
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License DPR-73 Docket No. 50-320 Technical Specification Change Request (TSCR) No. 63 The Licensee reouests that the attached changed pages of the Appendix B Technical Specifications (Tech. Specs.) (i.e., pages 3-1, 4-1, 5-3, 5-4, 5-5, 5-6, 5-7, and 5-8) replace Sections 3.1 and 4 and the corresponding pages of Section 5 in the Appendix B Tech. Specs.
Description of Change Sections 3.1, 3.1.1.a.(4), 3.1.2.a.(1), 4.6, 5.4, 5.5.1, 5.5.4.C and D, 5.5.5, 5.5.6, 5.6.1. A.(1), 5.6.1.B, 5.6.2.b, and 5.7.2 have been deleted in their entirety.
Sections 5.5, 5.5.2, 5.5.3, 5.5.4, 5.5.4.A, and 5.6.2 were revised to reflect these deletions.
Reason for Change This change is reouested to delete those pages of Appendix B which consist of non-radiological monitoring requirements, studies, and reporting requirements. The decision by the licensee to dispose of the accident-generated water (AGW) by controlled evaporation obviates the need to continue the non-radiological monitoring that the river discharge alternative would have reouired. In addition, the licensee has completed 15 years of non-radiological monitoring [i.e., ten (10) years s nce the 1979 accident]
with no findings of significant impact upon the env.ronment.
Environmental Evaluation Justifying Change The primary reason for reauiring continuance of the non-radiological monitoring program is stated in Reference 1 as follows: "Those studies (General Ecological Survey of the York Haven Pond] are necessary to document the continuing health and status of the biotic community and the impacts of radiological effluents, should the river alternative be chosen for disposal of the processed accident water." Further:
"These studies should continue at least until a decision is reached on the ultimate disposal of the PAW
[ Processed Accident Water]." The decision by the licensee to dispose of the AGW by controlled evaporation obviates the necessity to continue the non-radiological studies that have continued for over 15 years.
These studies originated in 1974 as a " discovery" program designed to build the aouatic sampling program.
In 1977, TMINS commenced a pondwide survey of York Haven Pond with a scope that remained unchanged through 1982.
A reduced scope, implemented in 1983, continued the pondwide survey by sampling stations consistent with prior sampling programs.
In essence, TMI has performed a pondwide aauatic monitoring program consistent in scope for over 12 years and, for varying degrees, for over 15 years. The over 15 years of non-radiological monitoring have confirmed the continued absence of adverse environmental impact from the TMINS on the aouatic biota of the Susouehanna River. Aquatic sampling of fish and sediments will continue for radiological sampling.
The following is a section by section justification for deleting the non-radiological technical specifications contained in Sections 3, 4, and 5.
1 i
Section 3.1 Non-radiological Monitoring The bases for continuing the non-radiological monitoring program include the following statements:
A.
The Programmatic Environmental Impact Statement (PEIS) states:
"These programs monitor the aauatic biota and sport fishery in that segment of j
the Susauehanna River where the TMI effluent first enters, in the last
[ sic] dilute, and where effects, if any, would be seen first."
i B.
A fishery is made of three essential components: (1) the fish, (2) their environment or habitat, and (3) the people who exploit or depend on the biota. A disruption of any of the components could affect the fishery.
j C.
Knowledge of the effects of TMINS operation on aquatic biota "will be j
invaluable in allaying the fears of resource users downstream, including the Cheasapeake Bay."
Justification of Change i
A.
As previously stated, the TMINS Aouatic Monitoring Program has continued in varying degrees for over 15 years. In that time, changes to the aouatic ecosystem generally reflected changes in environmental conditions 1
and the dynamic interactions of organisms and their habitats. The wealth of data collected failed to establish any adverse environmental impact resulting from the operation of the TMINS. The NRC acknowledged this j
lack of impact in their written bases for Amendment 21 of the TMI-2 Tech.
Specs.
B.(1) The fish: With over 15 years of sampling data, fish and macroinertebrate populations in the vicinity of TMINS are well 1
documentrd. Population estimates, condition factors, movement studies, thermal alume response and impingement /entrainment effects were studied to a deg.ee that greatly exceeds typical requirements in the nuclear industry. These studies documented the natural variations in the I
aouatic ecosystem and failed to demonstrate an adverse impact from the j
TMINS.
I (2) Their environment or habitat: Similarly, the historical data failed to i
establish habitat variability or adverse impact resulting from THINS i
operation. Natural phenomenon such as river flow, depth, substrate and velocity determine the type and diversity of the habitat. Aquatic organisms respond to the habitat conditions created by these natural phenomenon.
(3) The people who exploit or depend on the biota: Creel survey results collected since 1975 indicate a healthy and thriving fishery in f.he 1
THINS vicinity. Four species dominated the catch and harvest dJring the study period: channel catfish, rock bass, smallmouth bar, and walleye. Their relative abundance in creel data appear unrelated to TMINS operation. After the TMI-2 accident, 7.6% of the anglers surveyed reported a change in use of their catch because of TMI. This number, though never large, steadily declined over the years.
In 1988, i
none of the anglers interviewed reported a change. This indicates that anglers exploiting the fishery near TMI are not significantly impacted by the operation of the TMINS.
i C
',
- The enormous amount of data collected since 1974 provide a wealth of C
scientific knowledge unequalled for most aquatic systems. Adult
~
population estimates and movement studies showed no relation to TMINS operation. Larval fish densities are only minimally impacted by TMINS operation and no significant, adverse impact to adult populations were measured as a result of impacts to larval fish. Juvenile fish densities and movements correspond to habitat preferences and natural environmental conditions, not to TMINS operation. Thermal and physical impacts of the TMINS liquid effluent are minor, extremely localized and do not result in adverse impact to the benthic or fish populations near the TMINS.
In addition, monitoring programs conducted by the Maryland Power Plant and Environmental Review Division have never detected evidence of the TMINS liauid effluents in the lower Susauehanna River.
In short, the wealth of knowledge gathered to date on the effects of the TMINS operation is sufficient and shows no adverse impact to the aquatic environment.
Section 3.1.1.a.(4)
Water Quality Analysis The bases for examination of the water ouality cite a need to obtain pH, temperature, dissolved oxygen and total dissolved solids data to evaluate trends and unusual occurrences suggested by biological observations.
Justification of Change Aouatic monitoring conducted since 1974 has shown strong relationships between fish populations and select water cuality parameters.
These relationships are well documented and further reflect the dynamic interactions of aquatic systems. No adverse impacts on water quality were documented resulting from the TMINS operation. Rather, natural weather and river conditions dictate water quality variables.
It is noteworthy that all National Pollutant Discharge Elimination System (NPDES) water auality measurements at the site discharge to the Susouehanna River will continue in accordance with the TMINS permits issued by the Pennsylvania Department of Environmental Resources (PA DER).
3.1.2.a.(1)(a) Benthic Macroinvertebrates The bases state that benthic organisms are sedentary and, therefore, cannot avoid potential impacts of the TMINS effluents.
Justification of Change In the bases to Amendment 21, the NRC acknowledged that data collected through 1982 failed to show evidence of significant, adverse impacts from TMINS operation on the benthic community. Data collected since 1982 verify this conclusion.
These data document the high variability in bentnic populations resulting from natural fluctuations of environmental phenomena, i
l l
3,1*.2.a.(1)(b)
Ichthyoplankton, The bases state that THINS operation may impact ichthyoplankton populations in Lake Frederick.
Justification of Change The bases of Amendment 21 also state: "All studies have indicated that no significant, adverse inpacts resulted from the activities at the TMINS."
Additional studies since Amendment 21 confirm the absence of adverse impacts.
These data strongly correlate variability of ichthyoplankton densities to natural spacial and temporal distributions of species rather than to any influence of the TMINS discharge.
3.1.2.a.(1)(c) Fish The bases state that TMINS operation may impact fish populations by impinging on adult and juvenile fish and by entraining eggs and larvae.
Justification of Change Impingement and entrainment studies were deleted by the NRC in Amendment 21.
The NRC also stated in the amendment that all studies indicated that no significant, adverse impacts on adult and juvenile fish result from the TMINS operation. Additional studies since Amendment 21 confirm this lack of impact. The electrofishing and seine data show fish abundance is affected by seasonal changes in river flow, water temperature, habitat difference and the natural variations inherent in fish populations. Creel surveys, conducted since 1975, indicate a healthy sport fishery in the TMINS vicinity. Based on these studies there is little evidence that TMINS has significant, adverse impact to fish populations in the Susouehanna River.
4.6 Exceptional Occurrences 4.6.1 Unusual or Imoortant Environmental Events The unusual or important environmental events identified in this section are "those that cause or could cause potentially significant environmental impsct casually related with station operation." The bases for this requirement state that the ability of the NRC to respond to inquiries and the news media concerning potentially significant environmental events at nuclear power stations must be maintained.
Justification of Change This requirement is redundant since TMI-2 must adhere to the immediate notification requirements of 10 CFR 50.72.
In particular, 10 CFR 50.72(b)(2)(vi) reauires a 4-hour report for "Any event or situat ion, related to... protection of the environment, for which a news release is planned or notification to other government agencies has been or will be made."
~
4.6'.2 Exceeding Limits of Other Relevant Dermits As stated, this requirement applies only to topics of National Environment.al Policy Act (NEPA) concern within the NRC area of responsibility as identified in the TMI-2 Environmental Tech. Specs.
Justification of Change The purpose of this Tech. Specs. change reauest is to delete the non-radiological environmental monitoring requirements from the NRC area of responsibility. Therefore, deleting Section 4.6.2 is a direct result of the overall Tech. Spec. change reauest.
GPU Nuclear will continue to document occurrences which exceed specified limits of the appropriate Federal, State, and local regulations, as reouired.
5.4 State and Federal Permits and Certificates This section requires the licensee to comply with the requirements of Section 401 of PL-92-500, the Federal Water Pollution Control Act Amendment of 1972.
Justification of Change Deletion of the non-radiological monitoring requirements from the TMI-2 Appendix B Tech. Specs, abrogates NRC jurisdiction over these matters. The licensee will continue to comply with the Section 401 certification issued to the licensee by the PA DER.
5.5 Procedures The sole revision is to specify that this section refers to " radiological" procedures.
Justification of Change The purpose of this change is clarification.
5.5.1 Environmental Program Description Document This section details the contents of the environmental program description document necessary to implement the environmental monitoring and special programs requirements of Sections 3.1 and 4.
Justification of Change Sections 3.1 and 4 are being deleted in their entirety; therefore, this section should also be deleted.
5.5".2 Quality Assurance of Program Results The sole revision is to specify that this section refers to " radiological" procedures.
Justification of Change The purpose of this change is clarification.
5.5.3 Compliance With Procedures The sole revision is to specify that this section refers to " radiological" procedures.
Justification of Change The purpose of this change is clarification.
l 3.5.4 Changes in Procedures, Station Design or Operation l
The changes proposed in this section are comprised of the following:
l a.
Specifying that this section refers to " radiological" procedures; and l
b.
Deleting the references to Sections 4, 5.5.1, and 5.5.5.
Justification of Change a.
The purpose of this change is clarification, b.
Sections 4, 5.5.1, and 5.5.5 are being deleted in their entirety; therefore, references to these sections should also be deleted.
5.5.5 Consistency With Initially Approved Programs, This section is concerned with mooirications or changes to the environmental prograni description document discussed in Section 5.5.1.
Justification of Change Section 5.5.1 is being deleted in its entirety; therefore, this section should also be deleted.
5.5.6 NRC Authority to Reouire Revisions This section is concerned with modifications or revisions to the environmental program description document discussed in Section 5.5.1.
Justification of Change Section 5.5.1 is being deleted in its entirety; therefore, this section should also be deleted.
l
5.6*.1.A.(1)
Annual Environmental Operating Report Part A Nonradiological This section details the contents of the non-radiological environmental monituring program report reauired by Sections 3.1 and 4.
Justification of Change Sections 3.1 and 4 are being deleted in their entirety; therefore, this section should also be deleted.
5.6.1.B Data Reporting Formats This section is concerned with the results of analysis of non-radiological environmental data collected in accordance with Section 3.1.
Justification of Change Section 3.1 is being deleted in its entirety; therefore, this section should also be deleted.
5.6.2 Nonroutine Reports The changes proposed for this section include the following:
8.
Editorial clarification; and b.
Deleting the reference to Section 4.6.
Justification of Change Section 4.6 is being deleted in its entirety; therefore, reference to this section should also be deleted.
j 5.6.2.b Thirty Day Event The change proposed for this section is to delete the reference to Sections 401 and 402 of PL-92-500.
Justification of Change Section 5.4, which discussed PL-92-500, is being deleted in its entirety; i
I therefore, reference to PL-92-500 should also be deleted.
5.7.2 Changes in Permits and Certifications This section is concerned with changes or additions to permits and certifications issued pursuant to Sections 401 and 402 of PL-92-500.
Justification of Change Section 5.4, which discussed PL-92-500, is being deleted in its entirety; therefore, reference to PL-92-500 should also be deleted.
1 i
No significant Hazards Consideration 10 CFR 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.
The proposed change to delete non-radiological monitoring requirements from the TMI-2 Recovery Technical Specifications has no impact on the safety of the evolutions occurring at TMI-2. Over 15 years of non-radiological monitoring have confirmed the continued absence of significant adverse environmental impact on the aouatic biota of the Susauenanna River from the TMINS. In addition, the clecision to dispose of AGW by controlled evaporation removed the major mechanism for potential environmental impact used as a basis in License Amendment 21 to continue the non-radiological monitoring program.
Therefore, the proposed changes do not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated. In fact, the licensee decision not to discharge AGW directly into the Susauehanna River reduces the potential for environmental impact; the proposed changes incorporate that decision into the TMI-2 Tech. Specs.; or 2.
Create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed changes only involve deleting non-radiological studies that are unnecessary considering the AGW decision; or 3.
Involve a significant reduction in a margin of safety. There is no impact on any margin of safety.
In fact, with regard to the aquatic biota of the Susauehanna River, the licensee decision to evaporate the AGW obviates the need to continue the non-radiological monitoring that the river discharge alternative would have required.
Based on the above analysis, it is concluded that the proposed changes involve no significant hazards considerations as defined by 10 CFR 50.92.
References 1.
Memorandum from Ronald L. Ballard, Chief, Environmental Engineering Branch, DE, to Oliver D. T. Lynch, Jr., Section Leader, Environmental Review Section, TMI Program Office, NRR, " Review of GPU' Technical Specifications Change Reauest No. 38, Re: TMI-2 Aquatic Monitoring Program,' dated October 1, 1982.
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