ML20009H173

Notifies That NRC Re Acceptance Review of Application for OLs Contained Incorrect Encl 4 & Omitted Encl 14.Corrected Encl 4 & Entire Encl 14 Encl,Re Environ Rept Encl

ML20009H173
Person / Time
Site:	Limerick
Issue date:	07/31/1981
From:	Schwencer A Office of Nuclear Reactor Regulation
To:	Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8108060369
Download: ML20009H173 (16)

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ASchwencer NSIC Docket Nos.: '50-352 MService NRC PDR l

and 50-353 DCalkins L PDR l

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DEisenhut/RPu'rple Mr. Edward G. Bauer, Jr.

Attorney, OELD' l

Vice President and General Counsel I&E(3)

Philadelphia Electric Company 2301 Market Street P.O. Box 8699 Philadelphia, Pennsylvania 19101 L

SUBJECT:

ERR,0RS IN NEC LETTER OF JULY 6 1981, ON ACCEPTANCE REVIEW 0F APPLICATION FOR.0PERATING LICENSES FOR LIMERICK GENERATING STATION, UNITS 1 AND 2. to the subject letter contained several errors. Please substitut:e the corrected Enclosure 4 which is attached.

. In addition.some copies of the subject letter did not have an Enclosure 14.

Please add the attached Enclosure 14 to the letter.

l Sincerely, A. Schwencer, Chief l

Licensing Branch No. 2 Division of Licensing I

Enclosure:

As stateo cc w/ enclosure:

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NRC FORM 318 (10-80) NRCM ONO OFFICIAL RECORD COPY use o ini-m.

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k rir. Edward G. Bauer, Jr.

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Vice President & General Counsel Philadelphia Electric Company Ja 2301 Market Street

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Philadelphia, Pennsylvania 1

19101 Y

[u Troy B. Conner, Jr., Esq.

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Mr Conner, Moore & Corber Sen. Vincent Boyer c

1 1747 Pennsylvania Avenue, N. W.

ior Vice President j

Nuclear Operations E4 Washington, O. C.

20006 Philadelphia Electric Company 4

Deputy Attorney General 2301 Market Street-4 Room 512, Main Capitol Building Philadelphia, Pennsylvania 19101 Harrisburg, Pennsylvania 17120 Karl Abraham Mr. Robert W. Adler Public Affairs Officer Assistant' Attorney General Region I, OIE U. S. Nuclear Regulatory Commission Bureau of Regulatory Counsel i

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631 Park Avenue 505 Executive House P. O. Box-2357 King of Prussia, PA 19806 Harrisburg, Pennsylvania 17120 Allan Kanner, Esq.

Honorable Lawrence Coughlin 1622 Locust Street House of Representatives

' Philadelphia, Pennsylvania 19103 Congress of the United States Washington, D. C.

20515' Ms. Phyllis Zitzer Limerick Ecology Action Roger 8. Reynolds, Jr., Esq.

P. 0. Box 761 324 Swede Street Pottstown, Pennsylvania 19464 Norristown, Pennsylvania 19401 Robert J. Sugarman Lawrence Sager, Esq.

Berle, Butzel, Kass & Case Sager & Sager Associates 4J Rockefeller Plaza 45 High Street New York, New York 10111 Pottstown, Pennsylvania 19464 Frank R. Romano Joseph A. Smyth 61 Forest Avenue Assistant County Solicitor Ambler, Pennsylvania 19002 County of Montgomery Marvin I. Lewis Courthouse 6504 Bradford Terrace Norristown, Pennsylvania 19404 Philadelphia, Pennsylvania 19149 Eugene J. Bradley John Shniper.

Philadelphia Electric Company Meeting House Law Building & Gallery Associate General Counsel Mennonite Churst Road 2301 Market Street Schulykill Road (RT 724)

Philadelphia, Pennsylvania 19101 Spring City, Pennsylvania 19475 Mr. Jacque Durr Resident Reactor Inspector D*V'" P. Hershey U. S. N le r Regulatory Comission Comun].ty Legal Services, Inc.

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Sanatoga, Pennsylvania 19464 Philadelphia, Pennsylvania 19107

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JAlan J.- Nogee

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3700 Chestnut Street

-Philadelphia, Pennsylvania-19104.

R. L. Anthony Box 186 Moylan, Pennsylvania-19065

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Dr. M. Bruce'Irvin, Pastor The Church of the' God Shepard -

35 West Philadelphia Avenue Boyertown, Pennsylvania 19512.

HarddO A. Lockwood, Jr.

. Lockwood, Rend & Bolger

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= 2126 Land Title Building-Philadelphia, Pennsylvania 19101 Davi.d Cohen, Councilman - at - Large City Council, Room 588 City Hall 4

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ENCLOSURE 4 REQUEST FOR ADDITIONAL INFORMATION FOR ER0L E240.1 Identify the anticipated date of operation of Maiden Creek-Dam.

(2.4.1)

E240.2 Identify the period of record used to develop tne flood frequency-(2.4.2) curve (Figure 2.4-3).

The period of record considered was apparently prior to the date indicated in Reference 2.4-5 (1968). Re-estimate the curve using the period of record through 1980 so that the effects of Tropical Storm Agnes (June 1972) and other events since may be i ncl u ded.

E240.3 Table 2.4-7 and Figure 2.4-5 apparently have been based on records (2.4.2) l through 1967. We understand other incidents of sow flow have occured wnich may alter estimates of the low flow frequency characteristics of streams in the site region. Accordingly, discuss the low flow characteristics of the Schuylkill River, Perkiomen Creek, and the Delaware River at Trenton through 1980.

E240.4 The rist paragraph of Section 2.4.2.2 does not indicate whether flow (2.4.2) augmentation will be achieved by any storage to be provided by l

Philadelphia Electric Company as a result of requirements imposed by the Delaware River Basin Commission.

Indicate whether such j

augmentation will occur, when it is likely to occur, and the amount i

and reliability of such augmentation.

If the Point Pleasant t

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. Diversion Plan is the source of that augmentation the appropriate background information should be referenced and summarized such as:

the DRBC FEIS of February 1973, the DRBC Final Environmental Assess-ment of August.1980, the ORBC Proceedings on-Docket.No. D-79-52CP' of February 18, 1981, the DRBC Proccedings-on Docket No. D-65-7CP(8) of February 18, 1981, and the Army actions on NAPOP-R-0534-3 and NAPOP-R-0813-13.

E240.5 Indicate wnether estimates of water levels are likely to change during (2.4.3) tne course of plant operation due to erosion and sedimentation, and discuss the basis for your evaluation.

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E240.6 The last paragraph of Section 2.4.3 indicates that flow-frequency (2.4.3) estimates have been based on pre-1968 da+a.

Revise the estimates to reflect the flow history through 1980.

E240.7 The bed slope for Possum Hollow Run appears to be incorrect and should (2.4.4) be checked.

E240.8 Tables 2.4-10 and 2.4-11 indicate downstream water users apparently (2.4.5) identified at the tine the ER for the CP was written. Provide any other anticipated users or changing user requirements that have been identified for the future.

E240.9 (a) The Delaware River Basin Commission pennit for water use was (2.4.6) the subject of considerable discussion during the course of-the Construction Permit reivew. The initial decision of ;he Atomic Safety and Licensing Board ~indicateds that'a' L t

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DRBC. Decision was to be made by January 1,1977, on w. 9'

.c or not compensation storage would be1 required.

Indict.e what the status of that process has' been. (See-Question E240.4 above).

(b) As part of tne same issue, considerable discussion occurred about the consequences of plant operation if Tocks Island Dam was not constructed and compensating storage was not provided. The data used to project the periods on non-full power operation did not include information for the middle and late 1970s.

Identify the likelihood and duration of plant shutdown assuming that the present flow augmentation planning process is carried out.

E240.10 Identify any effects on runoff that have occured due to plant construc-(4.5.1) tion.

Include an evaluation of the ercsion that has occurred on -drainage courses upstream of construction areas, and the impact of erosion and/or deposition on downstream areas.

E240.ll In Section 5.1 two additional effects should be identified. First, the (5.1) effects of plant water use on other users should be idenitfied (and possibly cross references to other sections of the ER). Secondly, erosion 4

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l and depositon effects of water intake and discharge should be considered.

E240.12 Identify-Department.of-Environmental ResourcesL and< Delaware-River:

.(5.1.1)

Basin Commission standards for receiving-waters that'may differ.

Indicat2 wnich standard you intend to comply witn.

E240.13 Identify tne range of initial blowdown dilution areas anticipated (5.1.2) for tne corresponding renage of Schuylkill River flows that are likely to occur curing plant operation.

E240.14 Describe tne deposition and erosion in front of the intake structure (5.1.2) anticipated during the life of the plant.

l E240.15 Average monthly blowdown temperatures alone do not indicate the range (5.1.2) of temperatures likely to occur during plant operation. Provide your estimates of the extreme temperatures likely to occur during operation and indicate whether such temperatures are likely to cause impacts such as being a constraint on plant operation.

E240.16 Indicate the likelihood of the intake structure on Perkiomen Creek (5.1.2) being inoperable due to flooding or erosion. Provide the basis for your analysis.

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-Indicate the period of record used to estimate the percentage of (5.1.2) diverted flow in Perkiomen Creek described in Seciton 5.1.3.2.2, and if necessary, update for data collected through 1980.

E240.18 Indicate wnether deposition in front of the intake structure en (5.l.2)

Perkiomen Creek'is likely to cause plant shutdown.

E240.19 Estimate the increased flood risk to property along the east branch

( 5.1.2 )

of Perkiomen Creek due to diversion from tne Delaware River; that is, provide an estimate of the increased likelihood of flooding due to l

high creek flows from diversions coincident with heavy precipitation.

(You may cross reference your responses to Questions 240.22 and 24.23).

E240.20 Were any streamflow and water level measurements made by Philadelphia (6.1.1)

Electric Company on either the Schuylkill River or Perkiamen Creek?

If so, describe their nature and data collected.

E240.21 Calcualte the raciological consequences of a liquid pathway release (7.1) from a postulated core melt accident. The analysis should assume, un-less otherwise justified, that there was a penetration of the reactor basemat by the molten core mass, and that a substantial portion of radioactively contaminated suppression pool water was released to the ground. Doses should be compared to those calculated in the Liquid Pathway Generic Study (NUREG-0440,1978). Provide a summary of your

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l analysis procedures and the values of parameters used (such as per-l' r

i meabilities, gradients, populations affected, water use).

It is sugges+ed tnat meetings with the staff of the Hydrologic Engineering Section be arrangeo so that we may share with you the body of'infor-mation necessary to. perform this analysis.

E240.22-Descr.iptions of floodplains, as requried by Executive Order 11988, (2.4.2)

Floodplain Management, have not been provided. The definition used in the Executive Order is:

Floodplain:

The lowland and relatively flat areas adjoining inland and coastal waters included in floodprone areas of offshore islands, including at a minimum that area subject to a one percent or ~ greater chaage of flooding in any given year.

(a) Provide descriptions of the floouplains adjoining the Schuylkill River, Perkiomen Creek, East Branch Perkiomen Creek, and the Delaware River adjacent to the site, plant faiclites and reaches used for carrying pumped diversion flow. On a suit >1e scale map (s)

I provice delineations of those areas that will be flooded during the one percent (100 year; flood both before and after plant con-struction or operation.

(b) Provide details of the methods used to determine the floodplains in response to a. above.

Include your assumptions of and basis 1

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flood flows and water evaluations. If studies approved by the Federal Insurance Administration (FIA) are available for the site and'other affected areas ~, the details ofi the' analysis ~

ased in the reports need not be supplied. You can instead pro-vide the reports from which you obtained the floodplain information.

(c)

I'.entify, locate on a map and describe all plant stuctures and topographic alterations in the floodplains.

Indicate the start and completion dates of all such items.

E240.23 (a) Discuss the hydrologic effects of all itmes identified in response (2.4) to questions 240.22c. Discuss the potential for altered flood f')ws and levels, offsite. Discuss the effects on offsite areas of debris generated from the site during flood events.

(b) Provide the details of your analysis used in reponse to a. above.

The level of detail is similar to that identified in item 240.22b.

E290.1 Endangered Species.

(3.9.2 and 5.5)

Are there any preposed or listed Threatened or Encangered Plant Species potentially occurring along the proposed Limerick transmission line coridors?

. E290.2 Provide a description of the. grounding systems which will be used (3.9.3 and 5.5) to reduce induced voltages and currents in conducting objects, such as metal fences, in the vicinity of the right-of-way.

E311.1 It is' indicated ~ on Page 2.1-2 of 'tne environmental report that.there (2.1.1.2) are sections of land within the exclusion area. that-are not-presently owned by Philadelphia Electric-Company but are controlled'by the Commonwelatn of Pennsylvania, and that they will be acquired or an agreement will be executed win

'"9 Commonwealtn so that Philadelpnia Electric Company can restrict access to these properties, if necessary.

Indicate the date by which either of' the proc 2dures listed above will provide Philadelphia Electric Company the aathority to determine all activities within the exclusion area as required by 10 CFR Part 100.

E450.1 In accordance witn NRC's Interim Policy (45 FR 40101) revise Section (7.1.1) 7.1.1 to include a probalistic evaluation of impacts of accidents in-cluding those formerly called Class 9 accidents.

E451.1 Table 2.3.2-86 presents offsite terrain evaluation.

In order to (2.3.2.2) determir.e the effect of terrain on an effluent, onsite elevations, by direction, using the same distance. intervals as in Table 2.3.2-86 are needed.

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-9 E451.2 As specified in Regulatory Guide 4.2, Revision 2, the following maps (2.3.2.2) are needed:

(a) a map snowing detailed topographic feautures (as modified by the station) on a large scale within a five-mile radius of the station and, (b) a smaller scale map showing topography within a 50-mile radius of the station.

E451.3 A separate report, referred to in the I as "Micrometeorological Data (2.3.2) and Analysis for the Limerick Generating Station Environmental Report-Operating License State and Final Safety Analysis Report Submittals,"

l has not been submitted to the NRC.

Since this report appears to have essential information which will be used in DEF preparation, we request the applicant to submit two copies of it.

E451.4 No data are presented da the ER to permit an independent assessment of (5.1.4.2).

the environmental impact of the cooling tower plume as specified in Regulatory Guide 4.2, Revision 2, Section 2.3.

E471.1 The agricultural survey should be extended from 5 miles to 50 miles (2.1.3.6 and (nat river miles).

Same comment'both page 2.1-11 and page 5.2-14.

5.2.4.1)

E471.2 Although PECO claims to be using 1.109 equations and assumptions, it (5.2) appears they have modified critical parameters such as dose conversion factors. While they are free to do so, NRC will perform an independent assessment.of population dose to determine compliance with 10 CFR Part 50, Appendix 1.

! l E471.3 Table 1.2-51 "X/Q depleted" should include both radioactive decay l

(5.2.2.1) and deposition cccurring during atmospheric transport.

L E471.4-Table 6.1-45:

1 year and 6 months prior to fuel load: While-six (6.1.5.2) radiciodine air samples per week is more' than adequate, the samples should include 3 offsite areas expected to exhibit the highest annual average D/Q during operation.

Direct Radiation Measurements:

There should be 2 rings of 16 each (32) plus 8 areas of special interest such as schools, nearby residences, and population centers, for a total of 40. Thirty-five stations may be enough, but the smaller number will require a Justification.

Surface Water Samples and Drinking Water Samples shculd be collected l

by continuous sampling, not compositea from grab samples.

It _is not clear from this table (or Table 6.1-47) whether PECO proooses to do that.

Ground Water Samples:

should be collected quarterly if the wells are likely to be affected.

" E471.5 Table 6.1-46: MDL I-131 in water is missing.

Is there a reason for this?

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I 4 REQUEST FOR ADDITIONAL INFORf1ATION Diablo Canyon Units 1 and 2 260.17 Section 17.l ~ 2.2 of' the standard forma t (Regulatory Guide 1.70) i requires the identification of safety-related. structures, systems, l

and components (Q-list) controlled by the QA program. You are requested to supplement and clarify the Diablo Canyon Q-list in L

Table 3.2-4 of the FSAR in accordance with the following:

l a.

The following items do not appear on the Q-list (FSAR Table 3.2-4).

Add the appropriate items to the' Q-list and provide a commitment that the remaining items are subject to the per-tinent requirements of the FSAR operational quality assurance program or justify not doing so.

l 1.

Safety-related masonry wall s (see IE Bulletin No. 80-11).

2.

Breakwaters.

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Leak detection system (see FSAR Section 3.5).

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Missile barriers which protect safety-related itens.

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5.

Onsite powr system (Class IE).

a) Electrical penetrations of containnent - Non-vital l

including primary and backup fault current protective l

devices.

b) Raceway fire stops and seal s.

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l c) Emergency light battery packs.

6.

Radiation monitoring (fixed and portable).

7.

Radioactivity monitoring (fixed and portable).

l 8.

Radioactivity sampling (air, surfaces, liquids).

9.

Radioactive contamination measurenent and analysis.

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Personnd monitoring internal (e.g., whole body counter) and l

external (e.a., TLD system).

11.

Instrument storage, calibration, and maintenance.

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12. Decontamination (facilities, personnel, and equipment).

13. Respiratory protection, including testing.

14.

Contamination control.

15. Radiation shielding.

16.. Meteorological data collection programs.

17. Expendable and consumable items necessary' for the func-tional performace of safety-related structures, systems, and components (i.e., weld rod, fuel oil, boric acid,,

snubber oil, etc.).

18. Measuring and test equipment used for safety-related structures, systems, and components.

19. Ground slope east of builoing complex.

20. Firewater storage reservoir ponds.

21. Hydrogen recombiner, including piping and valves.

22. Containment pressure indication system.

23. Containment water level indication systems.

24. Containment hydrogen indication system.

25. Valve operators for safety-related valves.

26. Motors for safey-related pumps.

b.

The following items form the Q-list (iSAR Table 3.2 a) need ex?ansion and/or clarification as noted. Revise the list as-indicated or justify not doing so.

f 1.

Portions of the turbine generator building (sheet 4) which enclose the emergency diesel-generator units and ancillary systems as well as other safety-related components should be under the controls of the operational QA program.

2.

New fuel storage racks (sheet 3) should be under the con-trols of tne operational QA program.

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3.

Intake structure and conduit (sheet 5) should be under the controls of the operational QA program.

4.

Containment structure sump, sump screen, and vortex sup-pression should be under the controls ~ of the operational QA program.

5. ' Reactor cavity sump pump (sheet 18) should be under thelcon-trols of the-operational QA program.

l 6.

Clarify that the primary system PORV, safety valves, and -

PORV block valves and their actuators are included under

" Reactor Coolant Systems Valves," (sheet 25).

7.

Clarify that the main steamline safety valves and steamline PORVs and their actuators are included under " Valves for the Above (Main Steam Piping-SG to MSIV) Portion of System" (sneet 23).

8.

Identify the safety-related instrumentation and control systems to the same scope and level of detail as providea in Chapter 7 of the FSAR.

9.

The 250V DC Motor Control Center OS 121 (sheet 36) should be under the controls of the operational QA program.

10. Circulating water conduits (sheet 5) should be under the controls of the operational QA program.

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