ML19326C917

Objects to Draft Amend 3,Change 3 to ETS Forwarded by NRC 750515 Ltr.Objections Involve Frequency of Impingement Sampling,Threadfin Shad Population Density,Diel Changes in Impingement Levels & Fish Grinding Operations

ML19326C917
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/02/1975
From:	Cavanaugh W ARKANSAS POWER & LIGHT CO.
To:	Giambusso A Office of Nuclear Reactor Regulation
References
NUDOCS 8004290549
Download: ML19326C917 (6)

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NRC ntSTRIGUTION FO*3 PART 50 DOC"T MATERI AL (TEMPdRARY FORM) )

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CONTROL NO: Anoi

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FROM: Arkansas Power .6 Light Co. DATE OF DOC "

DATE REC'D 'TR TWX RPT OTHER' Little Rock, Ark ,

. William Cavanaugh III 6-2-75 6-4-75 xxx ,

TO: .7 ORIG CC OTHER SENT AEC PDRx . . ]

Mr. A. Giambusso ) 1-signed SENT l.OCAL PDR v -vv CLASS UNCLASS PROPINFO INPUT NO CYS REC'D DOCKET NO:

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50-313 DESCRIPTION: ENCLOSURES: l

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Ltr ref our 5-15-75 Itr ... trans the follo# wing : Attachment t.o " Letter Cavanaugh* to' diamb.u June 2,

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1975...... O' o jsetior, to 5 item of the draft Amdt No. 3, ching'e No. 3 THIS DOClJMENT CONTAINS-- to the Envii o Tech- Specs . . <. ._< . .

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• H EL PIN G B Li t L D AHKANSAS ARK ANS AS POWER & LIGHT COMPANY 97H & LOUISIANA STF-e6ETS . LITTLE AOCK. A AK ANGAS 72203 f 501) 372-431 June 2, 1975 b

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Mr. A. Giambusso, Director 2- k -

Division of Reactor Licensing A b/$ l8 U. S. Nuc1 car Regulatory Commission Washington, D. C. 20555 f/$,fy, 4:Q*<r

Subject:

Arkansas Power 6 Light Company S 6 Arkansas Nucicar One-Unit 1 ~~

Docket No. 50-313 License No. DPR-51 Environmental Technical Specifications

Dear Mr. Giambusso:

Mr. Muller's letter of May 15, 1975 transmitted a draft of Amendment No. 3, Change No. 3, to the Technical Specifications of Operating License DPR-51.

We taka definite objection to 5 items that are a part of that Amendment.

We have aircady First, we object to impingement sampling 3 times per week. submittal of prop stated in our April 11, 1975 Technical Specifications that, among other things, hard data shows only a 2%

• difference in results obtained from 3 times per weekWe sampling as the feel that oppesed hRC staff to the existing practice of twice per week sampling.

has failed to properly justify a 3 times per week sampling schedule and that the cost far outweighs the benefit.

Second, we object to Specification 6.4 regarding the absolute Numerous population reasons for our objections density determination of threadfin shad.

were voiced in our April 11 submittal including the position voiced by state agencies. We feel that the NRC staff has not considered adequately all of the facts presented, has failed to properly justify their requirement for this program, and that the cost far outweighs the benefit.

Third, we object to Specification 6.5 regarding the labora of threadfin shad. Again, our April 11 submittal includes numerous reasons In for our objections which have not yet been addressed to our knowledge.

addition our February 14, 1975, submittal, referenced in our April 11 sub-mittal, cited other studies which have already been done to determine these l

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b MEMBER MlODLE SOUTH UTILITIES SYSTEM T AX P AYlNG. INVESTOR OWNED

June 2, 1975

. , , Mr.'A. Giambusso temperature effects. We feel that the NRC staff has failed to properly justify their requirement for this study based on the facts we have presented, and that the cost far outweighs the benefit.

Fourth, we object to Specification 6.3 regarding diel changes in impingement 1cvels. ' Again, our April 11 submittal includes our reasons for considering this of no use._ To our knowledge no attempt has been made to refute our contentions. We feel that the NRC staff has failed to properly justify theig requirement in this area and that the cost far outweighs the benefit.

Fifth, we object to ceasing all fish grinding operations. Our April 11 sub-ndttal proposed a program to detect any deleterious effects caused byWe fish grinding and to stop grinding only when these effects were detected.

have also cited strong objections by a state agency to ceasing fish grinding operations. We feel that the NRC staff has failed to properly justify their requirement to cease all fish grinding operations.

We also object, in general, to the unilateral decisions of the NRC in imposis arbitrary provisions in our Environmental Technical Specifications which may be incompatible with current EPA directives relative to the NPDES ceedings.

before new provisions are imposed. __

On a smaller scope we have other more detailed comments, questions, and ob-jections which are included as an attachment to this letter.

Mr. Muller's letter also stated that our previous submittals demonstrati..g that the inlet water box temperature is representative of the temperature existing in Illinois Bayou are incomplete. We have not as yet been told how they are incomplete nor exactly for what purpose they are needed. If we can be told how they are incomplete or exactly for what purpose they are needed we may be abic to supply further data that is sufficient.

In conclusion, we wish to take exception to the five points listed above and are prepared to meet with you or members of your staff to discuss our objecolons.

Ve truly yours William Ca augh III Manager, Nuclear Servi hC:ay l

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Attachment to Letter Cavanaugh to Giambusso June 2, 1975

1. General Unchanged ment to assurebacksides of change that the changedcan pages be should beinserted properly included in in the the amend exist Environmental Technical Specifications.

2. p. 2-3 Specification 2.1.4 There is a typographical error in the second word in the third from the last line in the first paragraph of the specification.

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3. p. 2-10 Specification 2.4.1.2 Dur letter to you of June 17, 1974, which requested this change, alsd requested that the wording be changed so that the releases would be totaled over a calendar quarter instead of averaged since this is a quarterly limit. To accomplish this, the word " averaged" in the secc ond line of this specification should be changed to " totaled".

4. p. 2-17 Tabic 2-2

a. Item 2 is covered in the A.ppendix A Technical Specifications and has nothing to do with liquid releases; therefore, it should not be in this table,

b. Strontium 89 and 90 determinations are done by chemical separatic Chemically, Strontium 89 and 90 are inseparable; therefore, one cannot be done without the other. We are required to account fo Strontium 89 and 90 in liquid releases monthly; therefore, item should be done on a monthly proportional composite sample compil from all liquid releases. We also have to report Strontium 89 E(

90 in gaseous efrluents monthly; therefore, the frequency of tne' analysis required by item 4.b.4 should be changed to monthly for both Strontium 89 and 90. Also, the filters are dissolved in th analysis; therefore Strontium 89 and 90 must be 'done at the same time.

c. There are now two items numbered 4.b. This should be rectified.1 .

d. Specificat_on 2.4.2.8 duplicates the requirements of item 4.c.1 '

with the exception that specification 2.4.2.8 is more restrictiv concerning frequency. Therefore, item 4.c.1 should be deleted Q Table 2-2 and, since footnote (5) only applies to item 4.c.1, fd note (5) should also be deleted.

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c. For clarification, the first line of footnote (1) should refer 8 j Specification 2.4.2.3.b and following the words " maximum releas '

! rate" in line 3 of footnote (1) a reference should be made to 12----- J ificatf an 2.4.2.3.a.  ;

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f. The words " Air Ejector" on item 6 are not applicable and should {

deleted.

g. Picase provide the bases for the sensitivity specified for item 4.b.3.

5. p. 4-11 G 12 Specification 4.1.2.a (2)

a. Objective The objective as stated is directed toward academic interest on1{

It should be reworded to address a qualitative assessment of en-<

vironmental impact.

b. Specification It was our impression that this specification applied to fish impingement. Including all impinged organisms creates difficule ties for our personnel. While these difficulties (mostly addi-i tional paperwork) are some that we could probably live with we

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feel that the benefit from including the occasional snakes, turtles, crawfish, etc., are not worth the additional effort.

The wording requires that we search the entire sample to find any single representative of any species. . Jhe third sentence should apply to the subsample only. Since this is already spece ified later, the third sentence should be deleted.

Our April 17 submittal attempted to clarify the relationship of-trash to the subsample. As stated in the draft Amendment No. 3, the wording is confusing as to what makes up the subsample. We believe our April 17 submittal is much better on this point.

Our April 11 submittal specified methods for subsampling within a species. Draft Amendment No. 3 simply states that "a random subsampic of at Icast 100 fish shall be used". The method fur taking a random subsample should be specified with a minimum mu?

lower than 100 fish. We believe the methods specified in our April 11 submittal are more appropriate.

The subjects' of fish grinding and the number of days of samplin; in each week have been addressed in the main body of this lettef

c. Reporting Requirement We need at least 30 days to supply the monthly _information re-quested. At times a 30 day requirement will be difficult to me:

d. No basis is given for this specification. One is definitely n9

c. As a general comment to tbis specification we feel that the vea we submitted on April 17, 1975, is much more specific and thers easier to implement and to enforce. The amendment 3 version iO poorly worded. As a result we again submit that our version be adopted.

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- 6. p. 4-12 f 4-12a Specification 4.1.2.a(3)-

he second sentence should be changed to read " Intake samples shall be

' taken in the intake . canal;. discharge samples shall be taken from the discharge canal." *%is will facilitate sampling the same water mass and enable use of the intake structure for intake sampling. The para-graph at the top of page 4-12a should be revised to make the metered ~

plankton net the first choice and the high capacity pump sampler the ,

alternative since the results of both methods should be essentially i  ;

- identical and the netting method is less expensive. H e reporting re- #

quirement should require the summary to be included in "the report j' required by Specification 5.6.1".

7. p. 4-15 Specification 4.2.10

. For the quantities of milk (2 liters) that we are able to put through

- a column in a reasonable amount of time (300 minutes), counting 21/2 l

days after sample collection, 70% chemical yield, and 33% detector

! efficiency, the overall error allowable in determining the radioiodine

• concentration should be raised to f. 35%. The last two lines on this page should be changed to read "after notifying the NRC in writing that milk.is not available at that location." We are not always able

~ to obtain milk even where milk animals are present. _

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p. 4-29 Table 4-3

a. The gill net survey sampling frequency should be changed to agree with the text.

j b. We would like an explanation of why the sampling points for the

trawling survey and the shoreline seine survey were not changed to j sampling areas. -We feel that areas are more meaningful on netting .

operations as we do not understand how nets cas. be pulled at a i single. point.

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9. p. 6-3 Specification 6.3 l What is the meaning of the word "diel"? We cannot provide an inter-

' pretive report within 30 days of the end of the program. We need at p least 60 days. No basis has been provided for this specification' and i no justificrtion as to the benefits and use of the results has been provided as noted in the main body of this letter.

[ 10. p.-6-4. Specification 6.4 Exception to this entire specification has been taken in the main body of this letter. In the continuing development that is being made of -  !

this program it has been determined that doubling the grids and deleting '

l the replicates will yield better results. Herefore this should specify l

-50 grids and.not require replicate samples. l l

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ll, p. 6-5 Specification 6.5  !

The control group is used to differentiate natural: mortality. Due l

to .a typographical error, we are now asked to differentiate natural

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morality. Exception to this entire specification' has been taken in the main body of this letter. l

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