ML090690770
| ML090690770 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/10/2009 |
| From: | Paul Krohn Reactor Projects Region 1 Branch 4 |
| To: | Cuthbert D Alliance For A Clean Environment |
| KROHN P, RI/DRP/PB4/610-337-5120 | |
| References | |
| Download: ML090690770 (6) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA, PA 19406-1415 March 10, 2009 Ms. Donna Cuthbert, Vice President Alliance for a Clean Environment P.O. Box 3063 Stowe, PA 19464
Dear Ms. Cuthbert:
I have attached responses to your letters of December 15, 2008, and January 12, 2009, dealing with radioactive waste and fire protection issues at Limerick Generating Station, respectively.
I have not responded point-by-point to the questions you posed, but rather described the information in general, and provided publicly available references for more specific, detailed answers.
The documents referenced in the attachments can be accessed through the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
I trust that this information is responsive to your needs. If you should have any further questions or require additional information, please do not hesitate to contact us.
Sincerely,
/RA/
Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects Docket Nos. 50-352, 50-353 License Nos. NPF-39, NPF-85 Attachments: As stated
Ms. Donna Cuthbert, Vice President Alliance for a Clean Environment P.O. Box 3063 Stowe, PA 19464
Dear Ms. Cuthbert:
I have attached responses to your letters of December 15, 2008, and January 12, 2009, dealing with radioactive waste and fire protection issues at Limerick Generating Station, respectively.
I have not responded point-by-point to the questions you posed, but rather described the information in general, and provided publicly available references for more specific, detailed answers.
The documents referenced in the attachments can be accessed through the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
I trust that this information is responsive to your needs. If you should have any further questions or require additional information, please do not hesitate to contact us.
Sincerely,
/RA/
Paul G. Krohn, Chief Projects Branch 4 Division of Reactor Projects Distribution w/encl D. Lew, DRP P. Krohn, DRP R. Barkley, ORA N. Seiler, DRP, RI D. Roberts, DRS J. Rogge, DRS R. Fuhrmeister, DRP L. Pinkham, Resident OA J. Clifford, DRP D. Screnci, ORA T. Setzer, DRP P. Bamford, PM, NRR E. Cobey, DRS N. Sheehan, ORA E. DiPaolo, DRP, SRI E. Miller, NRR, Backup PM SUNSI REVIEW COMPLETE: ___PGK_____ (Reviewers Initials)
DOCUMENT NAME: G:\DRP\BRANCH4\Responses to 'Alliance for a Clean Environment'\ACE Response 09-01R1.doc After declaring this document An Official Agency Record it will be released to the Public.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/ DRP RI/ DRS RI/ DRS RI/DRP NAME RFuhrmeister JWhite/EHG for JRogge/KLG for PKrohn DATE 03/06/09 03/09/09 03/06/09 03/10/09 OFFICIAL RECORD COPY
Attachment 1 NRC Response to ACE Letter of December 15, 2008 Multiple questions relating to Radioactive Waste Disposal at Limerick Generating Station
RESPONSE
All nuclear power plant licensees are required to annually provide effluent release data generated during their operations to the U.S. Nuclear Regulatory Commission (NRC). This data includes details on disposing of solid, liquid, and gaseous waste.
For the Limerick Generating Station, the data, you requested, can be accessed through the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS).
The Annual Radioactive Effluent Release Reports can be reviewed for calendar years 2007 (ML081260683), 2006 (ML071210611), 2005 (ML061250292), 2004 (ML051230219), and 2003 (ML041180432). In each report, specific data regarding the types, quantities, and destinations for solid radioactive waste shipments can be found in Appendix B of these reports (for example, page 25 in the 2007 report, ML081260683). Data regarding liquid and gaseous releases can be found in the tables located in Appendix A (for example, page 11 in the 2007 report, ML081260683).
As part of our reactor oversight program, routine inspections are conducted of the Limerick effluent treatment/monitoring programs, radioactive waste processing/transportation programs, and radiological environmental monitoring program to assure that Limerick complies with Technical Specifications, applicable regulations, and regulatory commitments. These inspections are conducted in accordance with inspection procedures within the reactor oversight program, specifically: 71122.01, Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (ML083180411) conducted annually; 71122.02, Radioactive Material Processing and Transportation (ML020730765) conducted biennially; and 71122.03, Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program (ML020730768) also conducted biennially. From these inspections, Limerick was found to be in compliance with the relevant requirements. Additionally, it was determined that oil has not been incinerated for at least the past five (5) years at the station.
With respect to your questions regarding the renewal application for the Limerick Title V Operating Permit, you should direct your questions to the Commonwealth of Pennsylvania, Department of Environmental Protection, Air Quality Program. Please note that the Title V permit addresses Emission Limitations, Testing/Monitoring/Record Keeping/Reporting requirements for non-radiological matter (oil) incineration (waste derived liquid fuels typically consist of reclaimed/reprocessed oils - for example, used motor oil - and do not normally contain byproduct radioactive material from nuclear power plant operation). Only the NRC, in coordination with the US Environmental Protection Agency, regulates radiological wastes and effluents. Should Limerick decide to conduct oil incineration, the oil would be analyzed for radioactive contaminants, and any releases would be reported to the NRC in the Annual Radioactive Effluent Release Report.
1
Information related to the costs of processing and disposal of radioactive materials is not within the purview of the USNRC inspection program. This information, associated with operating costs and not nuclear safety, should be requested from the facility licensee.
2
Attachment 2 NRC Response to ACE letter of January 12, 2009 Question: Is Limerick Nuclear Power Plant in Complete Compliance with All Fire Safety Rules?
Response
The Nuclear Regulatory Commission (NRC) has determined that Limerick is in compliance with all fire safety rules because of the combined licensing, inspection, and enforcement activities we perform. The NRC has established a solid regulatory framework to regulate fire safety, which includes periodic inspections in order to identify significant issues of non-compliance and ensure timely corrective action to restore compliance when needed.
For your information, the NRC conducts the following routine Fire Protection inspections at the Limerick Generating Station. The results of these inspections are available for viewing in ADAMS as mentioned in the cover letter.
Triennial Fire Protection Team Inspection Every three years, a team composed of a fire protection inspector, a reactor operations inspector, and an electrical inspector conduct a review of the defense-in-depth used by the facility to mitigate the consequences of a fire. This inspection is conducted in accordance with inspection procedure (IP) 71111.05T (ML061140176) and includes approximately 200 person-hours of direct on-site inspection. This inspection targets specific risk-significant areas of the facility for a detailed review. This review includes the design of the post-fire safe shutdown equipment for the target areas (including control and power cables), protection of the post-fire safe shutdown equipment (including control and power cables) from the effects of fires, and operating procedures for achieving stable safe shutdown conditions in the event of a significant fire in the target areas which damages equipment and requires a plant shutdown. The inspection also includes a walkthrough of one of the procedures (or portions thereof) for verifying post-fire shutdown capabilities.
The most recent triennial fire protection inspection was conducted at Limerick in July and August of 2007. The inspection report was issued August 27, 2007, and is available in ADAMS under ML072400443.
Annual Resident Fire Protection Review Every year, a resident inspector evaluates performance of the on-site fire brigade by observing one or more fire brigade drills. The inspection is conducted in accordance with IP 71111.05AQ (ML080350272) and evaluates fire brigade performance, fire brigade equipment, command and control functions, availability and condition of manual fire-fighting equipment, and the licensees assessment of performance through the drill critique.
The most recent fire brigade drill observation was conducted at Limerick in December 2008. It is documented in Section 1RO5 of inspection report 2008-005, in ADAMS under ML090330638.
1
Quarterly Resident Fire Protection Review Every quarter, a resident inspector tours four to six risk-important areas of the plant to assess defense-in-depth aspects of the fire protection program. This review is also conducted in accordance with IP 71111.05AQ. The defense-in-depth aspects of the program include passive fire barriers (such as walls and penetration seals), active fire barrier components (such as doors and dampers),
material condition of fire-fighting equipment and systems, and control of combustible materials.
The four quarterly reviews for 2008 are documented in Section 1RO5 of inspection reports 2008-002 (ML081270551), 2008-003 (ML082261341), 2008-004 (ML083181209), and 2008-005 (ML090330638).
Notwithstanding your specific Limerick questions, on a national level, the NRC staff continues to evaluate fire protection issues with potential generic applicability. These issues include unapproved manual operator actions, multiple spurious operations due to fire-induced failures, and fire barrier adequacy; none of which currently affect Limerick compliance with all fire safety regulations.
2