ML17303A348
| ML17303A348 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/23/1987 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17303A349 | List: |
| References | |
| 161-00100-EEVB, 161-100-EEVB, TAC-64971, NUDOCS 8703310594 | |
| Download: ML17303A348 (12) | |
Text
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ACCESSION NBR: 8703310594 DOC. DATE: 87/03/23 NOTARIZED: NO DOCNET e FACIL: STN-50-528 Palo Verde Nuclear Stations Unit fi Arizona Publi 05000528 AUTH. NAME AUTHOR AFFILIATION VAN BRUNT'. E. Arizona Nuclear Pouer Prospect f formerly Ari zona Public Serv RECIP. NANE RECIPIENT AFFILIATION Document Control Branch (Document Control Desk )
SUBJECT:
Application f'r amend to License NPF-41 i changing Tech Specs Section 3/4. 11. 1 re secondary sys liquid utaste discharges to onsite evaporation ponds on one-+ime-only basis. Fee paid.
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Arizona Nuclear Power Project P.o. BOX 52034 ~ PHOENIX, ARIZONA85072-2034 March 23, 1987 161-00100-EEVB/JRP U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 1 Docket No. STN 50-528 (License NPF-41)
Request for One Time Only Technical Specification Change File: 87-F-005-419.05 87-056-026
Dear Sir:
Per conversation with E. A. Licitra and other NRC staff on March 23, 1987, submitted herewith is a one-time only request for an Emergency Technical Specification Change to the Unit 1 Technical Specifications Section 3/4.11.1, secondary system liquid waste discharges to onsite 'evaporation ponds. The requested period of this one-time only Emergency Technical Specification Change, is to begin at 8:00 am MST on March 24, 1987, and is to expire at 11:59 pm PST on May 23, 1987.
This change is required expeditously in that failure to act in a timely way would result in derating and shutdown of the unit.
The proposed change will allow the concentration of radioactive materials discharged from the secondary liquid waste to the onsite evaporation ponds, to exceed 5xlO 7 uCi/ml (gamma emitters with half lives less than 75 days).
This discharge will be within the guidelines of 10 CFR Part 20, Appendix B, Table II, Col. 2, concentratio'ns for a period not to exceed 60 days.
The continued operation of Unit 1 will not result in an unsafe condition as the proposed change is withe.n the limits of 10 CFR Part 20, Appendix B.
Enclosed within this change request are:
A. Description of Proposed Change Reque'st B. Purpose of the Technical Specification C. Justification for- the Emergency Classification D. Basis for No Significant Hazards Consideration E. Safety Analysis of the Proposed Change Request F. Environmental Impact Consideration Determination G. Markedup Technical Specifications F
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P UPS. Nuclear Regulatory Commission Attention: Document Control Desk
Subject:
Request for One Time Only Technical Specification Change 161-00100 page 2 Please be advised that a Technical Specification amendment request will be forth coming for Units 1, 2 and 3 to permanently change this section and also incorporate Region V comments.
Pursuant to 10 CFR 50.91(b)(1), and by copy of this letter, we have notified the Arizona Radiation Regulatory Agency of our request for a Emergency Technical Specification change. In accordance with 10 CFR 170.12(c), the license amendment application fee of $ 150 has been forwarded to the USNRC License Fee Management Coordinator.
If you have any questions or concerns, please call Joseph R. Provasoli at (602) 371-4160.
Very truly yours, CUA E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/JRP/rw Attachment CC: 0. M. De Michele~'aynes J. G.
G. M. Knighton (w/a)
J. B. Martin (w/a)
E. A. Licitra (w/a)
R. P. Zimmerman (w/a)
R. M. Diggs (with WFD $ 150.00)
C. F. Tedford (w/a)
A. C. Gehr 'w/a)
ATTACHMENT DESCRIPTION OF PROPOSED CHANGE RE UEST The proposed change request would modify Technical Specification 3.11.1.1 by changing the specification to allow (effective March 24, 1987) the con-centration of radioactive materials discharged from the secondary liquid waste to the onsite evaporation ponds, to exceed 5x10 uCi/ml (gamma emitters with half lives less than 75 days), but limited to 10 CFR 20, Appendix B. Table II, Col. 2 concentration for a period not to exceed 60 days+
PURPOSE OF THE TECHNICAL SPECFICATION This specification is provided to ensure that at any time during the life of the nuclear station, the annual total body dose due to ground contami-nation of an UNRESTRICTED AREA, arising from transportation and deposition by wind of the accumulated activity discharged to the pond from the secon-dary system of the plant (if the pond gets dried up) on the UNRESTRICTED AREA, is within the guidelines of 10 CFR Part 20 for the above-mentioned postulated event. I Restricting the concentratio'ns of the secondary'iquid wastes discharged to the onsite evaporation ponds will restrict the quantity of radioactive material that can get accumulated in the ponds. This, in turn, provides assurance that in the event of an uncontrolled'release of the pond's con-tents to an UNRESTRICTED AREA, the resulting total body annual exposure from ground contamination to a MEMBER OF THE PUBLIC at the nearest exclu-sion area boundary will be within 0.5 rem.
This specification applies to the secondary system liquid waste discharges of radioactive materials from all reactor units to the onsite evaporation ponds. Since the chemical neutralizer tank concentrations will bound con-centrations in other secondary waste discharges, surveillance requirements stipulate that sampling and analysis of other secondary waste discharges need be performed only if the sampling and analysis of the contents of the chemical neutralizer tank shows that the neutralizer tank concentration exceeds the specified LLD.
JUSTIFICATION FOR THE EMERGENCY CLASSIFICATION The requested one time only Emergency Technical Specification change will allow Unit 1 to continue to operate to allow for cleanup activities of radioactive liquids resulting from a primary to secondary leak. The Emer-gency Technical Specification change request is necessary to avoid derating and shutdown of the unit. In order to achieve the above, a suspension of pre-noticing requirements of 10 CFR Part', 50.91 is required and expedi-tious granting of the proposed one time only change be effected. Me have used every effort to try and avoid an emergency request, however, our latest calculations show that the decontamination activities will be at it's limits by the morning of March 24, 1987.
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ATTACHMENT (Continued)
BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION The commission has provided standards for determining whether a sig-nificant hazards consideration exists as stated in 10 CFR 50.92.
A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment would not: (1) Involve a significant increase in the probability or consequences of an acci-dent 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.
A discussion of these standards as they relate to the amendment re-quest follows:
Standard 1 Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated be-cause the proposed change does not alter the current design of the facility. The Technical Specifications are being changed to allow continued operation of the unit while the concentration of radio-active material discharged from secondary system liquid waste to the onsite evaporation ponds is above the lower limit of detectabil-ity but within the limits of 10 CFR Part 20, Appendix B, Table II.
This allows for cleanup (decontamination) activities of radioactive liquids resulting from a primary to secondary leak, while maintaining the unit in an operating condition. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Standard 2 Create the possibility of a new or .,different kind of accident from any accident previously evaluated.
The proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed amendment does not vary, effect or provide any physical changes to the facility. This proposed change allows for discharge of radioactive liquids which have been generated during normal processing/regeneration of condensate polisher resins. The small amounts ((2x10-6 uCi/ml) of total activity -present in regenera-tion wastes which will be discharged into the onsite evaporation ponds are within the limits of 10 CFR Part 20, Appendix B, Table II. For these reasons, it has been determined that the proposed amendment does not create the possibility of a new or different, kind of accident from any accident previously evaluated.
I ATTACHMENT (Continued)
Standard 3 Involve a significant reduction in a margin of safety.
The requested amendment does not involve a significant reduction in a margin of safety because the proposed change does not affect the design basis of the plant. The existing limits for concentra-tions of radioactive material discharged from secondary sys)em liquid waste to the onsite evaporation ponds will remain at 5xlO u Ci/ml for principal gamma emitters. However, releases of principal gamma emitters with half lives less than 75 days may be allowed to exceed 5x10 u Ci/ml but will be limited to 10 CFR 20, Appendix B, Table II concentrations for a period not to exceed 60 days. This will allow PVNGS to maintain a dose to the public of less than 500 mrem per year from accumulated particulates in the evaporation pond after the three units have been operating for 40 years. This is consistent with the design basis of the facility. For these reasons, it has been determined that the change does not involve a significant reduc-tion in the margin of safety.
- 2. The proposed change matches one of the examples given in 51 FR 7751 of amendments that do not involve a significant hazards considera-tion. Specifically, the proposed amendment is a change which in someway may reduce the safety margin, but where the results of the change are clearly within all exceptable criteria with respect to the system, (Example VI).
E. SAFETY ANALYSIS OF THE PROPOSED CHANGE RE UEST The proposed Technical Specification change will not increase the probabil-ity or occurance of the consequences of an accident or malfunction of equip-ment important to safety previously evaluated in the FSAR. This change will not effect the operation of the facility, it will increase the allow-able limits of concentration for discharge into the evaporation ponds from secondary system liquid waste.
The proposed Technical Specification change will not create the possibility for an accident or malfunction of equipment of a different type than any evaluated previously in the FSAR. No physical changes are being made to the facility and this change is within the previously evaluated design and operation of the facility. The proposed Technical Specification change will not reduce the margin of safety as defined in the basis for any Techni-cal Specification. The basis for specification 3.11.1.1 uses the guidelines of 10 CFR 20 which, as noted by the footnote to the specification, will be the limiting factor for principal gamma emitters with half lives less than 75 days. This provides assurance that the resulting total body annual
'exposure from gro'und'ontamination to a member of the public at the nearest exclusion area boundary will be within the'imits.
Il" j ATTACHMENT (Continued)
ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION The proposed change request does not involve an unreviewed environmental question because operation of PVNGS Unit 1 in accordance with this change would not:
Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the staff's testimony to the Atomic Safety and Licensing Board, Supplements to the FES, Environmental Impact Appraisals, or in any decisions of the Atomic Safety Licensing Board; or
- 2. Result in a significant change in effluents or power levels; or
- 3. Result in matters not previously reviewed in the licensing basis for PVNGS which may have a significant environmental impact.
MARKED-UP TECHNICAL SPECIFICATION PAGE (see page 3/4 11-1)