ML19259D468

Tech Spec Change Request 12 to DPR-50,App B.Certificate of Svc Encl

ML19259D468
Person / Time
Site:	Three Mile Island
Issue date:	05/20/1975
From:	Arnold R METROPOLITAN EDISON CO.
To:
Shared Package
ML19259D467	List: ML19259D466 ML19259D468
References
NUDOCS 7910240729
Download: ML19259D468 (4)

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lhtropolitan Edison Company Three Mile Island Nuclear Station Unit 1 Docket No. 50-289 Operating License No. DPR-50 Technical Specification Change Request 12 Licensee requests that the present text of Appendix B of the Technical Specifications, section 4.1.lA. , " Met. hod of Analysis" be changed to read as ,

follows:

" Counting, determination of reproductive status, condition of organisms, and identification to the lowest feasible taxon. Total weight and fork length ranges of each taxon identified will be recorded. A continuing record will be maintained to allow comparison of variation of nu=bers with time."

Reason for Froposed Chanee 12 In light of recent compliance questions that have been raised regarding the intended meaning of the subject " Methods of Analysis," this change has been proposed to eliminate any ambiguity that may exist regarding what constitutes the section 4.1.lA. " Method of Analysis" requirements. Note:

For additional information reg' ~.ing the subject compliance questions , please refer to the Nuclear Regulatory Commission (NRC) Region 1 Office's letter regarding Inspection No. 50-289/74-34 (dated February 10, 1975; attached as Appendix (1) ) , and to the NRC Headquarter's Office of Inspection and Enforcement letter regarding this same inspection (dated April 24, 1975; attached as Appendix (II) ).

I Environmental Analysis Justifying Proposed Change 12 The proposed change, if implemented, would not degrade the present environmental monitoring program in that the change would not alter the present program, but only serve to eliminate any ambiquity that may exist regarding the requirements of the subject " Methods of Analysis." Further, it should be noted that Licensee feels that the NRC's stated desire to require that impinged fish be weighed individually (ref: App.1) , if implemented, would not add anything to the presently existing program with regard to being able to predict the effects of impingement (ref: the " Bases" statements on page 42 of the Technical Specifications , Appendix B) .

In addition, information regarding the insignificance of what would be derived from weighing fish individually is provided as follows:

a. Impingement data collected at TMI-l reflects a minimal impact on the environment in that the number and biomass of impinged fish has been very low compared to fish populations in the vicinity of TMI. To substantiate this statement, the following background information is provided:

1. The results of 21 impingement surveys (February - December,1974) show a total of 1222 fish of 25 species impinged. These fish weighed a total of 1930.lg (4.3 -lbs) and most (~80%) were either young or juvenile, 1459 138 7910240 7 N

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2. the greatest number and greatest total weight of fishes per 24' hour sampling period were respectively, 316 specimens and 668.3 g, and

3. the mean nucher of fish impinged per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> survey was 58, and the mean weight was 91.9 g (0.2 lbs)

b. With regard to the specimens impinged at TMI:

1. Most are young and juvenile and weigh less than 1.0 g individually; therefore, little worth while data would be generated by taking individual weights,

2. water weight is an appreciable part of the weight of small fish, and though our consultants blot the fish to re=ove excess surface moisture, additional handling, such as that that would be required by individual weighings, could increase the chance of weight variations, and

3. data is presently collected so as to compile information on the number of fish, by taxon, falling within specified fork length ranges, and this data provides sufficient fish size information.

Cost / Benefit Analysis Suoporting Proposed Change 12 There is no cost associated with implementation of the proposed change other than adninistrative costs associated with processing it. The benefit that would be derived is that elimination of any ambiguity that may still exist regarding what constitutes the subject " Methods of Analysis" requirements would also serve to eliminate compliance questions that have been raised in this subject area. Further, it should be noted that if contrary to this request, a change were implemented whereby individual fish weights had to be takan, the cost of complying with such a requirement would

a. incredse about $100 - $500, due to having to procure a more accurate balance (accurate to ~0.01 g) , and

b. increase due to the increased man power required to weigh each fish individually .

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. - . Change Request No.12

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h.0 EUVIRONMEIITAL SURVEILLANCE A!!D SPECIAL STUDIES 4.1 Biolceical h.l.1 Acuatic Objective

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To define operational surveillance prograns to assess the impact of station operation on the aquatic flora and fauna in the near-site envirens. The folleving parameters will be checked during the progrc=: !=pingement of Organisms, Entrainment of Plankton, Fish Eggs and Fish Larvae. Fish Populaticns, and Macro-invertebrates.

Specificatien A continuing impinge =ent and entrainment biological surveillance pregram

( A, B, and C) shall be conducted. The results vill be reviewed at the end of the first year and the program codif!ed on approval of the staff. The program vill be ter=inated at the end c. the second year unless the review of the first year's data indicates the need for additional data.

Sample Sample Method of Methed of Frecuency Loc atien Sampling Analysis A. I=pingement Semi-senthly at Traveling Screen Removal Counting, determination h-hour intervals frc= in- of reproductive status over a 24-hour take screens and ccndition of period organisms, and identification to the lovest feasible taxon. Total weight and fork length ranges of each taxon identified vill be recorded. A continuing record vill be maintained to allow comparison of variatien of numbers with time.

B. Entrainment Semi-=0nthly Intake and Pu= ping Counting and determi-of Fish h-hour intervals Discharge naticn of extent of Eggs and over a 2h-hour mortality, identifica-Fish Larvae period during tien to the lowest April through feasible taxon. A October. continuing record vill be maintained to allow cc parison of variation of numbers with time.

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g a UNITED STATES OF AMERICA

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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. 12 to Appendix B of the Operating License for Three Mile Island Nuclear S tation, Unit 1, dated May 21, 1975, and filed with the U.S .

Nuclear Regulatory Commission May 21, 1975, has this 21st day of May,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:

Dr. 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 Middletown, Pennsylvania 17057 P.O. Box 1295 Harrisburg, Pennsylvania 17120 METROPOLITAN EDISON COMPANY By [

Vice Prisident-Gen'eration t

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'ech Spen Change Request 12

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UNITED STATES JW APR 2 8 iES

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NUCLEAR REGULATORY COMMISSION V/ ASH IN G TON. D. C. 20555 APR 2 4 G75 Metropolitan Edison Company .

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ATTN: Mr. R. C. Arnold j

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Vice President Post Office Box 542 ,

Reading, Pennsylvania 19603 i

Oca:1eceu.

This concerns a letta.r dated February 10,1975, (copy enclosed as Attachment A) to you from our Region I Office in King of Prussia Pennsylvania, which indica:ed that your response in a letter dated January 20, 1975, to Item 4 of a Notice of Violation which was sent

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to you on December 20, 1974, was not considered an adequate response and was being referred to this office for resolution. Iten 4 of the Notice of Violation concerns the canner in which fish were sampled as part of the fish impingecent study.

We have reviewed your reply of January 20, 1975, and have discussed the catter with respect to the require =ents of Section 4.1.1.A of Appendix B of the Technical Specifications for Three FEle Island Unit 1 with the Division of Reactor Licensing, Office of Nuclear Reactor Regulation. As a result of this revieu and discussion we I

understand that Mr. R. Bevan, of the Environmental Projects staff of f

- Reactor Licensing, has discussed this catter with Mr. S. Lauyer, a ce bar of your staff, and that action has been initiated to revise and clarify the requirements of Appendix B Technical Specification 4.1.1.A. *

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With the understanding that action is being taken to revise and c.1nrify  !

Technical Specification 4.1.1.A., we plan to take no further action I, at this time.

Sincerely, ,

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/ Jo . Davi h Deputy Director fo -

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Field Operations Off'ca of Inspetion and EnforedCent 1459 142

Enclosure:

As stated

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'r,X./ 9'110/60 797