ML19290A420
| ML19290A420 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 09/04/1975 |
| From: | Arnold R METROPOLITAN EDISON CO. |
| To: | |
| Shared Package | |
| ML19290A421 | List: |
| References | |
| NUDOCS 7911070598 | |
| Download: ML19290A420 (11) | |
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- a METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 20_
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This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix B to Operating License No. DPR-50 for Three Mile Island Nuclear Station Unit 1. As a part of this request, proposed replacement pages for Appendix B are also included.
METROPOLITAN EDISON COMPANY By /s/ R. C. Arnold Vice President-Generation Sworn and subscribed to me this 4th day of September __, 1975
/s/ Richard I. Ruth Notary Public 1555 326 C
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET NO. 50-289 OPERATING LICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY This is to certify that a copy of Technical Specification Change Request No. 20 to Appendix B of the Operating License for Three Mile Island Nuclear Station, Unit 1, dated September 4,1975, and filed with the U.S. Nuclear Regulatory Commission September 4,1975, has this 4th day of September,1975, been served on the chief executives of Londonderry Township, Dauphin County, Pennsylvania, and of Dauphin County, Pennsylvania, by deposit in the United States Mail, addressed as follows:
Mr. Weldon B. Arehart, Chairman Mr. Charles P. Hoy, Chairman Board of Supervisors of Board of County Commissioners of Londonderry Township Dauphin County R.D. #1, Geyers Church Road Dauphin County Courthouse Hiddletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120 METROPOLITAN EDISON COMPANY By /s/ R. C. Arnold Vice President-Generation 1555 327
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Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Licensee requests that certain changes , as hereinafter described, be made in Appendix 3 of the TMI-l Technical Specifications. A copy of the affected pages with these changes indicated is attached.
TECHNICAL SPECIFICATION CHANGE REQUEST NO. 20.a.
Chance Request Page 40, Section h.l.1, Specificatien, Item E. , Method of AnayLsis. Change
" Net and dredges" to " Nets or dredges".
Reason for Chance Recuest In the case of TFE, the benthic (i.e. , dredged) members of the macroinverte-brate pcpulation are better indicators of the effect the plant's heated discharge is having on the environment than are the floating (i.e., netted) members, and so there is no need to sample floating macroinvertebrate species. On the basis of this, it had been assumed that the intent of the subject specification was to require the use of either nets or dredges, and not nets and dredges; hcVever, upon review it has been determined that a strict interpretation of the subject specification as it presently reads gives rise to sufficient question regarding compliance so as to warrant this request for a change in the Technical Specifications. Accordingly, the reason for this change request is to eliminate any potential questions which could exist regarding the requirements for sampling the macroinverte-brate population.
Environmental Analysis Justifyine Prorosed Chance Implementation of the preposed change would allev licensee to conduct either a benthic macroinvertebrate sampling program or a ficating =acroinvertebrate sampling program. In the case of TMI, limiting macroinvertebrate sampling to benthic species only would not have any adverse impact en th. environment because at TMI it is these benthic species which are the bette ' indicators
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of the effect the plant's heated discharge is having on the environ =ent, as evidenced by the following:
- a. drifting macroanvertebrate species are only transient members of the macroinvertebrate population and so are not continually subjected to the plant 's heated -discharge;
- b. the temperature differential across the thermal plume at TMI is too small to have any measurable effect en drifting macrc-invertebrate species; and c.
the thermal plume at TMI is too small and shifts too frequently to allow sa=pling of floating sacroinvertebrate species at fixed locat ions .
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Cost-Benefit Analysis Justifying Preposed Change As explained above, implementation of the proposed change would not have any adverse impact on the environment, yet it would result in a cost savings of approximately $35,500 annually. This cost savings would be derived primarily from removal of the need to perform floating macroinvertebrate studies in addition to benthic macroinvertebrate studies.
TECH?iICAL SPECIFICATIO:1 CHANGE REQUEST NO. 20.d.
- Change Request Page 43, Section h.l.2.2, Specification, First Paragraph. In the first line change " vegetational analysis" to " vegetational-type mapping analysis".
Reason for Change Request The reason for requesting the prcposed change is to improve the wording of the subject specificatien so that it more accurately reflects the type of analysis being performed.
Envirermental Analysis Justifying Precosed Change The proposed change would not revise or delete any existing requirements of the Technical Specifications; therefore, its adcptien vill not have any adverse impact on the environment.
Cost-Benefit Analysis Justifyine Proposed Change There are no additional costs associated with the proposed change and there are no practical or cost-savings benefits likely to result from its adoption, in that it involves only the reverding of an existing requirement and does not revise or delete that requirement.
TECHNICAL SPECIFICATION CHANGE REQUEST NO. 20.e.
Chance Request Page 51, Table 3, Sample Type - Air, Type of Analysis - Gross Beta. Change the Sensitivity from "5 x 10-15 uci/ce" to 5 x 10-1" pCi/ce".
Reason for Change Request The subject sensitivity is incorrectly given in the Technical Specifications due to a typcgraphical error; therefora, the reascn for requesting the proposed change is to correct this error.
Envircnmental Analysis Justifying Prceosed Change 5ecause the proposed change would not actually affect the detecticn capability of the instrument used to measure gross beta activity and because this detection capability has in the past been shcvn to be adequate, adoption of the proposed change vill have no adverse impact en the environment.
Cost-Benefit Analysis Justifyine Proposed Change There are no additional costs associated with the proposed change and there are no practical or cost savings benefits likely to result frc= its adoption, in that it involves only the correction of a typcgraphical error and does not revise or delete any existing requirements.
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TECICIICAL SPECIFICATICN CHANGE REQUEST NO. 20.b.
Chance Request Page 57, Section h.h, Specification, Item d, First Paragraph. Change "every six months (during the beginning and midpoint of the crazing season)" to "during the midpoint of the grazing season".
Reason for Chance Recuest The cost of having to conduct more than one cow census a year can not be justified, in that one cow census a year has been shown by past experience to be adequate for detecting changes in cow population; therefore, the reason for requesting the proposed change is to re=cve this unjustifiable cost.
Environmental Analysis Justifying Proposed Change As already stated above, one cow census a year has been shown by past experience to be adequate for detecting changes in cov population; therefore, implementation of the proposed change vill not have an adverse impact on the environment.
Cost-Penefit Analysis Justifyine Pronosed Chance Implementation of the proposed change would not have any adverse effect on the environment, yet would result in a cost savings of approximately $1,200 annually. This cost savings vould result primarily f rom a reduction in the number of cow censuses which would have to be performed in the course of a year.
TECHNICAL SPECIFICATION CHANGE REQUEST NO. 20.c.
Chance Request Page 59, Figure 8, Change " Manager-Generation Statica" to " Manager-Ge- ration Operations - Nuclear," and change " Radiological Protection" to "Radiativn Safety", and change Station Superintendent to Unit Superintendent.
Page 60, Section 5.1, Item D., First Paragraph. In the last sentence change
" Radiological "rotection" to " Radiation Safety".
Reason for Chance Request The reason for requesting the proposed change is to make all of the position titles referenced in the Technical Specifications consistent with current titles.
Environmental Analysis Justifyine Proposed Chance The proposed change vould not revise or delete any existing requirements of the Technical Specifications; therefore, its adoption vill not have any adverse impact on the environment.
Cost-Benefit Analysis Justifying Prop sed Change There are no additional costs asscciated with the proposed change and there are no practical or cost savings benefits likely to result from its adoption, in that it involves only the updating of some position titles.
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C. Entrainment Semi-monthly at Intake and Pumping Counting and determi-of Plankton, 4-hour intervals Discharge nation of extent of over a 24-hour mortality identifica-period during tion to the lowest April thru '
October feasible taxon. A continuing record will be maintained to allow comparison of variation of numbers with time.
A continuing aquatic population surveillance program (D and E) shall be conducted during the first three years of operation. The results vi.ll be reviewed at the end of the first 30 months and the program terminated at the end of three years unless the results of the review indicate the need for additional data.
D. Fish Every Two weeks, At locations Trap nets Counting, identifica-March through indicated on and tion to the lowest October Figure 1. Shoreline feasible taxon, weighing.
Seining determination of repro-duction status and condition. A continuing record will be maintained
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to allow comparison of variation of numbers with time. Replicate samples will be taken
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both inside and out-side the ther=al plume.
E. Macro- Semi-monthly At locations Nets or Counting and identifi-Inverte- April thru indicated on dredges l brates October Figure 1.
cation to the lowest feasible taxon. A continuing record will be maintained to allow comparison of variation of numbers with time.
Replicate samples will be taken both inside 1555 331
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and the ground around the base of each tower out to a distance of 100 feet from the base. Any dead or injured birds found will be collected, identified, and the numbers and locations will be recorded. On days in which incidents of mortality or injury occur, description of meteorological conditions of the previous day and/or night will be included in the daily log. This program will be con-tinued for one year.
Bases Since some potential exists for bird injury and mortality due to impaction on the natural draf t cooling towers, and since the pos-sible levels of this i=paction are not known, specific report levels, protection limits or the need for such measures cannot be established at this time. The study described herein will provide information needed to establish a protection limit or report level or to establish that the measurement of bird impaction is not necessary due to an insignificant impact.
The documentation of bird mortality and injury due to impaction will allow an estimate to be made of the effect of the cooling ,
towers on migrating birds.
4.1.2.2 Effects of Cooling Tower Salt Drif t on Crops and Natural Vegetation Objective The purpose of the cooling tower salt drift study is to determine if damage to natural vegetation and crops is occurring from salt drift.
Specification The study areas, at locations indicated on Figure 2, which were used in a vegetational-type mapping analysis during preoperation will be checked I annually to detemine if measurable changes are occurring in species composition, relative abundance and relative dominance of naturally occurring vegetation due to salt drift. Sampling will be done near the station in the predicted area of drif t influence and also in control areas removed from the station.
Monthly visual examination of natural vegetation and agricultural crops will be made in these areas during the growing season (April through October) to detect if any physical damage is occurring.
Samples of any suspected drif t-damaged vegetation found will be 1555 332 4
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TABLE 3 - Environmental Sampling No. of Sample Stations Sample Type Indicator Background Type of Analysis Sensitivities Collection Frequency Collected Site Air 3 1 131 1odine Charcoal lx10 13 pCi/cc Charcoal Cartridge- See Fig. 3 & 4 Cart. Weekly
- 14 8
8 1
1 GB CS 5x10 (4)
Ci/cc Particulate Weekly Quarterly
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Precipitation 3 1 GB 7x10~8 pCi/ml Monthly See Fig. 3&
(if available)
CS (4) Quarterly (if available) 89 Strontium 5x10~9 pCi/ml Semi-Annually 90 Strontium 1x10~9 pCi/mi Semi-Annually Radiation T1.D 15 5 (amma 20 mrem /yr Quarterly See Fig. 5&6 Milk 4 1 131 Iodine 5x10 10 pCi/ml Monthly
- See Fig. 7 89 Strontium 5x10~9pC1/ml Quarterly
- 90 Strontium 1x10 '3 pC1/ml Quarterly
- Creen I.cafy 3 1 131 Iodine 1x108 pCi/gm(4) Annually (at harvest) See Fig. 7Q Vegetables CS (4) Annually (at harvest)
River Water 2 1 CS (1) (4) Monthly (3) Sec. Fig. 3 Tritium 2x10_4 pCi/ml Quarterly (3)
City of Columbia 1 - CS (4) Composite Sample See Fig. 4 Analyzed Monthly
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Tritium 2x10~4 pCi/ml Composite Sample m 89 Strontium Analyzed Quarterly u lx10_9 pCi/ml Composite Sample
'J1 Analyzed Quarterly 90 Strontium lx10~9 pC1/ml Composite Sample Analyzed Quarterly
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will be reported, with associated calculated error, as pico-
- curies of I-131 per liter of milk at the time of sampling, in accordance with Reporting Requirements for Environmental Radiological Monitoring.
Special attention will be paid to those locations where milk is produced for direct consumption by humans - e.g. , the family farm.
- d. A census will be conducted during the midpoint of the grazing season to deter =ine the location of cows in potentially affected areas within a five-mile radius of the plant.
If it is learned via the census that there are a considerable number of additional locations where milk is produced in the vicinity of the plant, the location (s) may be chosen which serves as a valid indicator of other locations in that meteorological sector, rather than sampling every location.
Bases The number and distribution of sa=pling locations and the various types of measurements described in Table 3, together with the pre-operational backgrounc data, will provide verification of the effectiveness of plant effluent control and indication of measurable changes in the activity of the environment.
Weekly sa=ples may be missed in the event of adverse conditions such as weather, equipment failure, etc. It is not intended that these missea samples be resampled prior to the next scheduled sample date. Monthly and longer perioo samples, if missed due to these conditions, will be taken within a reasonable time after the adverse condition no longer exists. All deviations from the sampling schedule shall be described in the semi-annual report.
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FIGURE 8 ORGANIZATION FOR IMPLEMENTATION OF
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. ENVIRONMENTAL TECHNICAL, SPECIFICATIONS PRESIDENT MET ED MANAGER GENERATION DI VISION MANAGER GENER ATION MANAGER GENERATION OPERATICNS NUCLEAR
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UNIT IATIM SUPERINTENDENT ENVIRbNMEbTAL ENGINEERING SECTION I
- ASST. STATION SUPERINTENDENT 1555 335 SUPERVISOR TECHNICAL SUPPORT TECHNICAL ENGINEER
- WHEN ASSIGNED
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D. , . Reports are submitted and records are kept in accordance with 5.6 and 5.7 of the Environ = ental Technical Specifications.
Violations of these Environmental Technical Specifications are investigated and appropriate corrective action taken to prevent recurrence. Responsibility for the independent audit and review functions concerning environ = ental matters as defined in section 5.2 of these Environmental Technical Specifications has been assigned by the Manager-Generation to the Manager-Generation Engineering. When the review function is performed by the Radiation Safety and Environmental Engineering Section, the Manager-Generation Engineering shall ensure that necessary audits of those review functions are performed independently of the Radiation Safe ty and Environmental l Engineering Section.
When organizations other than Metropolitan Edison Company are utilized to establish and execute portions of these Environmental Technical Specifications, compliance with the Environmental Technical Specifications in such instances shall remain the responsibility of Metropolitan Edison Company.
5.2 organization Organization of the personnel responsible for implementation, audit and review of these Environmental Technical Specifications including the Corporate level is as shown on Figure 8 of these Environmental Technical Specifications. In all matters pertaining to compliance with these Environmental Technical Specifications, the Station Superintendent shall report to and be directly responsible to the Manager-Generating Stations.
5.3 Audit and Review Independent audit and review functions for en'vironmental matters will be performed under the direction and control of the Manager-Generation Enginee ring. Independent review of environmental matters and auditing of station activities relating to these Environmental Technical Specifications will be conducted by the Radiation Safety and Environmental Engineering Section, reporting to the Manager-Generation Engineering. Their review will be audited by or under the direction of the Manager-Generation Engineering. These audits and reviews will encompass:
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