ML17325A431
| ML17325A431 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/02/1987 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Murley T NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML17325A433 | List: |
| References | |
| AEP:NRC:1034A, NUDOCS 8711090253 | |
| Download: ML17325A431 (10) | |
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/~"i ACCESSION NBR'ACIAL:
50-31 5 50=316 AUTH. NAME ALEXICHzM. P.
RECIP. NAME MURLEYiT. E.
REGULATOR NFORMATION DISTRIBUTION TEM (RIDS) 87110'70253 DQC. DATE: 87/11/02 NOTARIZED:
NO DOCKET 0 Donald C.
Cook Nuclear Power Planti Unit ii Indiana h
05000315 Donald C.
Cook Nuclear Power Planti Unit 2i Indiana 5
05000316 AUTHOR AFFILIATION Indiana Michigan Power Co.
RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Application for amends to Licenses DPR-58 Sc DPR-74'evising RETS to include radioactivitg releases generated from incineration of contaminated waste oil in plant auxiliary boiler sos. Supersedes 870828 request. Fee paid.
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Indiana Michigan Power Company One Summit Square P.O. Box 60 Fort Wayne, IN 46801 219 425 2111 R
IHWANSl SNCNIGQN PWElR AEP:NRC:1034A Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 TECHNICAL SPECIFICATION CHANGES - RADIOACTIVE EFFLUENTS U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 Attn:
T.
E. Murley November 2, 1987
Dear Dr. Murley:
This letter and its attachments transmit proposed changes to the "Radiological Effluents" section of the Technical Specifications (T/Ss) for Units 1 and 2 of the Cook Plant.
These changes are being proposed in order to include radioactivity releases generated from incineration of contaminated waste oil in the plant auxiliary boiler system as a T/S item.
Our letter of August 28, 1987 (AEP:NRC:1034) provided detailed information regarding this method of waste oil disposal; this submittal supersedes the approval request made in that letter.
Attachment 1 to this letter contains a discussion of the proposed changes to our T/Ss as well as the justification required under 10 CFR 50.92.
Attachment 2 contains the proposed T/Ss for Unit 1 and Unit 2.
For completeness, and to assist in your review, Attachment 3 contains a copy of the August 28, 1987 submittal referenced above.
We believe that the proposed changes will not result in (1) a significant change in the type of effluents or significant increase in the amounts of any effluents that may be released offsite or (2) a significant increase in individual cumulative occupational radiation exposure.
These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee (PNSRC) and will be reviewed by the Nuclear Safety and Design Review Committee (NSDRC) at their next regularly scheduled meeting.
87gg090253 8
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Dr. T.
E. Murley AEP:NRC:1034A In compliance with the requirements of 10 CFR 50.91(b)(l), copies of this letter and its attachments have been transmitted to Mr. R.
C. Callen of the Michigan Public Service Commission and Mr. G. Bruchmann of the Michigan Department of Public Health.
Pursuant to CFR 170.12(c) we have enclosed, an application fee of
$150.00 for the proposed amendments:.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
Sincerely, M. P. Al xich Vice President cm Attachments cc:
John E. Dolan W.
G. Smith, Jr.
- Bridgman R.
C. Callen G.
Bruchmann G. Charnoff NRC Resident Inspector
- Bridgman A. B. Davis
- Region III
Attachment 1 to AEP:NRC:1034A Donald C.
Cook Nuclear Plant Units 1 and 2
Discussion of Proposed Technical Specification Changes
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Attachment 1 to AEP:NRC:1034A Page 1
Discussion'f Pro osed Chan es Technical S ecification Chan es Attachment 2 contains proposed changes to Technical Specification (T/S)
Table 4.11-2 ("Radioactive Gaseous Waste Sampling and Analysis Program" )
and Section 3.11.2.3 ("Dose, Radioiodines, Radioactive Material in Particulate
- Form, and Radionuclides Other Than Noble Gases" ).
These changes add sampling and analysis requirements associated with incineration of contaminated waste oil in the auxiliary boiler system, and impose new requirements for the maximum allowable yearly off-site dose resulting from this pathway.
The contaminated waste oil to be addressed by the proposed T/S changes is generated principally from oil used for primary system pump motor bearing lubrication.
Some contaminated oil is also generated from various sources in the auxiliary building.
The contaminated waste oil is generated during normal maintenance-related activities performed on
- motors, pumps, and other mechanical devices.
The contaminated oil is initially collected in 55-gallon drums and is then transferred to a waste oil storage tank.
The contaminated oil has, in the past, been added to the (uncontaminated) fuel oil in the auxiliary boiler fuel oil tanks and subsequently burned when the auxiliary boiler was operating, Radioactivity releases from this pathway have been included in the releases reported in our semi-annual reports, and as such have also been included in our calculated doses to offsite population.
Our analyses have shown that radioactivity releases from burning contaminated waste oil in the manner described above were always below the 10 CFR 20, Appendix B limits for radioactivity releases to air in unrestricted areas.
Releases were also always in conformance with the requirements of 10 CFR 50, Appendix I for annual doses to individuals in unrestricted areas.
Further detail as to our method of contaminated waste oil disposal and the associated analyses we have performed can be found in our letter AEP:NRC:1034 dated August 28, 1987.
Our August 28 letter is included as Attachment 3 to this submittal.
In the August 28 submittal we had requested NRC approval for the method of contaminated waste oil disposal discussed above.
However, in subsequent discussions with NRC staff it was decided that an amendment to our T/Ss was a preferable approach to resolving this matter.
Those discussions form the basis for our present request for a T/S amendment.
Bases Chan es A review has been performed of the Bases secti.ons potentially affected by the requested T/S changes.
As a result of this review we believe the Bases as currently stated adequately accommodate the requested changes and that no revision of the Bases is required.
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Attachment, 1 to AEP:NRC:1034A Page 2
10 CFR 50.92 Evaluation Per 10 CFR 50.92, a proposed amendment will not involve a significant hazards consideration if the proposed amendment does not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously analyzed or evaluated, or (3) involve a significant reduction in a margin of safety.
Criterion 1 These changes add sampling and analysis requirements for contaminated waste oil to be incinerated in our auxiliary boiler system thereby enhancing the formal control of activities that have previously not been included in our T/Ss.
The proposed changes to our T/Ss do not involve a significant increase in the probability or consequences of any previously evaluated accident.
Criterion 2 The proposed changes have no effect on plant operations; they expand the requirements contained in our T/Ss.
Therefore, the changes do not create the possibility of a new or different kind of accident from any previously analyzed or evaluated.
Criterion 3
The proposed changes do not involve a significant reduction in the margin of safety since they only provide an enhancement in the formal control of activities not previously included in our T/S requirements.
The NRC has provided guidance concerning the determination of significant hazards by providing certain examples (48 FR 14870) of amendments considered not likely to involve significant hazards consideration.
The second of these examples refers to changes that impose additional limitations, restrictions or controls not presently included in the T/Ss.
Since the requirements for sampling and analysis of contaminated waste oil prior to incineration in the auxiliary boiler system constitute restrictions that are not currently included in our T/Ss, we believe this example is applicable and that the proposed changes involve no significant hazards consideration as defined in 10 CFR 50.92.