ML20028B364
| ML20028B364 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/29/1982 |
| From: | Bauer E, Bradley E, Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20028B362 | List: |
| References | |
| NUDOCS 8211300322 | |
| Download: ML20028B364 (19) | |
Text
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v BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 AMENDMENT TO MARCH 1, 1979 APPLICATION FOR AMENDMENT OF 4
FACILITI OPERATING LICENSES DPR-44 & DPR-56 Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company C2113OO322 821129 PDR ADOCK 05000277 P
a BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 AMENDMENT TO MARCH 1, 1979 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 By letter dated July 11, 1978, the Division of Operating Reactors requested Philadelphia Electric Company (Licensee),
inter alia, to submit a license amendment application to incorporate the applicable specifications of the Appendix I Model Technical Specifications (Radiological Effluent Technical Specification or RETS) enclosed with the letter into the Appendix "A" Technical Specifications for Peach Bottom Units 2 and 3.
Accordingly, by cpplication dcted March 1, 1979, LicEnsco requested an amendment to the Peach Bottom Atomic Power Station Unit 2 and Unit ? Operating Licenses i~n response to the NRC request regarding the Appendix I Technical Specifications.
The NRC staff at a meeting with the Licensee on June 29, 1982, requested revisions in the Licensee's Amendment Application and/or explanation of proposed exceptions to the Appendix I Technical Specifications.
Therefore, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power Station Unit No. 2 and Unit No. 3 respectively, hereby amends its application of March 1, 1979 in its entirety, by requesting that the Technical Specifications incorporated in Appendix "A" of the Operating Licenses be amanded by revising sections 3.2, 4.2, 3.0, 4.8, 6.0 and associated bases; by revising pages 11 111, iva, vi, via (Unit 2), iv, iva, vi, via (Unit 3), 1, 2, 3, 4, 5, 6, 7, 8, 58, 59, 75, 84, 92, 93, 203-l 216, 248, 252, 254, 256, 257-259, 261.
The extent of these revisions has necessitated the inclusion of additional pages due to the organization of the Technical Specifications to meet the RETS requirements.
Therefore, the Specificatio'ns are further modified by adding pages 216a-1 through a-5, 216b-1, b-2, 216c-1, c-2, 216d-1 through d-6, 216e, 216f-l through f-7, 248a, 252a, i
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256n, 259c, b, 261c, end 265-267.
All chengss are indicated by a vertical bar in the margin of the attached revised pages.
Furthermore, since the changes proposed by this amendment incorporate in Appendix "A" the Technical Specifications applicable to the environmental radiological monitoring program presently incorporated in Appendix "B", Licensee hereby requests that the Technical Specifications incorporated in Appendix "B" of the Operating Licenses be amended by deleting sections 4.3, 5.3, 6.4, 7.5.2 and associated bases by changing pages i, ii, 13, 41, 42, 48, and 52 as indicated by a vertical bar in the margin of the attached revised pages.
The proposed changes conform to the intent of the model Technical Specifications.
However, certain of the model Technical Specifications are not applicable to Peach Bottom Atomic Power Station.
Additionally, the Licensee proposes several exceptions and alternatives to the administrative requirements regarding the implementation of the Model Technical Specifications.
These deviations are outlined as follows:
1.
Solid Radioactive Waste: The as-built Solid Radioactive Waste System is designed to process wet (spent demineralizer resins and spent filter material) and dry solid wastes.
Wet solid wastes are dewatered to
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precluda free water and pnckaged in High Intcgrity Containers (HIC).
HICs are designed to contain concentrated radwaste materials generated during the removal of corrosion and activation products from process systems.
The specific activity of these materials ranges from trace amounts to no greater than l
350 uCi/cc.
The predominant radionuclides are Co-60, Cs-137 and Zn-65.
The HICs are molded polyethylene.
This material has outstanding dielectric properties, chemical resistance to solvents, acids, and alkalles, toughness, good barrier properties, high environmental stress cracking resistance, good cold impact strength, ultraviolet light stability and radiation resistance.
Testing confirms the HICs ability to withstand f
vibration, drop, compression, puncture and pressu,ye tests.
Each container receives a variety of quality control checks to confirm its integrity.
HICs are designed to maintain their physical integrity for 10 half-lives of the longest lived significant isotope.
Based on the 30 year half-life of Cs-137, the design HIC lifetime is 300 years.
The HICs currently in i
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usa at Patch Bdttom stction cro utilized for the shipment of solid radwaste to the burial site in Barnwell, South Carolina.
These HICs have been accepted for burial of radwaste by the State of South Carolina Department of Health and Environmental Control.
Approved procedures are provided and updated at the station for operation of this system in accordance with design.
However, the as-built system does not have the capability for solidification as defined in the model Technical Specifications.
Therefore, the licensee concludes that a Process Control Program (PCP) as defined in the original Radiological Effluent Technical Specifications proposed by the NRC staff is not applicable to the Peach Bottom facility.
The latest guidance from the NRC staff redefines the PCP as a document that describes the methods and controls for the processing and packaging of solid radioactive waste.
These activities at Peach Bottom are currently controlled by plant procedures to ensure compliance with applicable regulations.
A PCP is inappropriate since it would elevate these plant procedures to a technical l
specification level.
Section 6.8.1 of the current Peach l
Bottom Technical Specification endorses NRC Regulatory l
J Guida 1.33 whibh in turn rcquiroa colid red'wcato I
procedures.
Section 6.5.1.6 requires the on-site review committee to review these procedures and modifications to the solid radwaste systems.
Modifications are reviewed and reported to the NRC in accordance with 10 CFR 50.59.
Reference to a PCP document and associated administrative controls would therefore be redundant to
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I the existing provisions in the Technical Specifications.
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For these reasons, the Licensee proposes to describe the 1
PCP in the Peach Bottom FSAR, and revise in accordar.ce i
s with the annual FSAR update regulation rather than incorporate reference to a PCP into the Specifications.
This would permit more expeditious handling of changes to solid radioactive waste procedures and systems of a minor nature, and their review under 10 CFR 50.59.
L 2.
Regulatory Guide 1.21: The section of the RETS requiring written procedures covering the Quality Assurance Program for effluent monitoring using the guidance'in Regulatory Guide 1.21 was not included in the license application since it is not specific regarding the s'
requirements for a quality assurance program or wr'itten procedures.
This lack of definition would result in a wide variance as to interpretation, and pre'sents a criteria against which it would be difficult to audit.
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In cny ccco, eqcticn 6.8.1 Cf tha Patch Cottom T;chnic21 Specificctions rcquirco writton proc;durc2 thct ccot AN31 N18.7, section 5.1 and 5.3, and Regulatory Guide 1.33.
These documents clearly identify the Quality As'surance procedures for effluent monitoring.
. Additionally, the Peach Bottom Quality Assurance Plan identifies the controls for the effluent monitoring j
program.
Consequently, Licensee has concluded that the provisions of the current Peach Bottom licensing document provides a more comprehensive and definitive set of requirements than the proposed reference to Regulatory Guide 1.21.
3.
Liquid Holdup Tanks: The model Technical Specifications establishes operability and surveillance requirements for level instrumentation on outdoor radioactive liquid lf' storage tanks that are not surrounded by dikes.
All outdoor tanks at the station which have the potential for containing radioactive liquids are surrounded by dikes capable of holding the tank contents and have overflows and drains connected to the liquid radwaste treatment system.
4.
Continuous Liquid Releases: The model Technical Specifications identifies the radioactive liquid waste 7-i r
ocapling cnd c'nnlyaic progrcm for both cont'inusuo end batch releases.
All routine radioactive liquid releases from the station are batch releases.
5.
Land Use Census:
a.
Dose assessment analysis to determine compliance with Appendix I has shown that a real residence does exist at the site boundary of maximum dose potential.
There is no reason to conduct an annual l
residence survey because it is not possible for a different residence to appear at a location with greater dose potential.
b.
The dose assessment analysis has also shown that the maximum dose to man occurs via the grass-cow-milk pathway.
The calculated dose at the maximum dose real dairy farm is greeter than the calculated dose at any hypothetical vegetable garden which could exist off-site.
Since this pathway could never be the limiting pathway, there is no benefit to be gained by performing an annual garden census.
6.
Gaseous Radwaste Trip Function: The radiation monitors on the gaseous radwaste system are provided with alarm -
indications, howay r, no trip functions aro'includ d in these monitors.
The holdup pipes in the offgas radwaste treatment system provide a nominal three day delay time in the passage of offgas radwaste to the main plant stack.
This extended holdup period provides sufficient time for manual isolation of the offgas system should the radiation levels in the offgas system increase, to insure that the doses due to gaseous effluents do not exceed the Technical Specifications.
7.
Special Reports: Licensee proposes that Special Reports required as a result of the Radiological Effluent Technical Specifications be furnished to the Commission within 21 working days of the date of the event.
This requirement satisfies the intent of the model Technical Specification of 30 days from the date of the event.
This is consistent with the licensee's current Technical Specifications requiring written followup to reportable occurrences which require prompt notification by defining the reporting period as a period of 10 working days.
8.
Annual Radiological Environmental Operating Report: The Licensee proposes to submit the Annual Radiological Environmental Operating Report to the Commission l
csvaring tha previous calendar yasr prior to May 31 of each year.
Submission of the report by this date provides the necessary time required for preparation, consultant input and detailed review to ensure completeness and accuracy of the submission to the Commission.
9.
Annual Radiation Dose Assessment Report: The Licensee proposes to submit the Annual Radiation Dose Assessment Report within 120 days after January 1 of each year.
This period allows sufficient time for the calculation of radiation doses following publication of the
--dioactive releases in the Radioactive Effluent Release Report.
The turnaround time between the determination of all plant radioactive effluents and publication of the Radioactive Effluent Release Report is very short.
This turnaround time does not allow time for calculation of radiation doses in time for publication of the Radiation Dose Assessment Report within 60 days after January 1 of each year.
10.
Steam Jet Air Ejector Radiation Monitors: The steam jet air ejector radiation monitors are permanently wired in i
place and are not normally accessible.
Currently, these monitors are calibrated by analysis of an offgas grab )
ccmplo.
Th2 draign cnd instc11stion of tha eterm jot air ejector radiation monitors makes it inadvisable to perform a source check as defined in the model Technical Specifications.
Additionally, performance of routine source checks would not be consistent with ALARA.
11.
Ground Water: The Branch Technical Position (March 1978) on radiological environmental monitoring states that ground water must be monitored only if likely to be affected.
There are no ground water sources that are likely to be affected by Peach Bottom because the ground water flow at the site is toward Conowingo Pond and no wells exist between the plant and the pond.
12.
Drinking Water, I-131: The Branch Technical Position recommends analysis for I-131 in drinking water only if the calculated dose is greater than 1 mrem /yr.
The maximum calculated dose to an individual from I-131 in drinking water is only 0.28 mrem /yr.
13.
Milk, Gamma Spectrometry: Experience obtained during seven years of operation of Peach Bottom indicates that nuclides other than I-131 from Peach Bottom releases have not been detected in milk.
The dose assessment analysis for Appendix I indicates that cesium-137 and t l
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134 uight hcva o minor d:so imp;ct co o recult of long-term buildup in soil with subsequent transfer to grass and milk.
Quarterly gamma spectrometry or cesium isotopic analyses on milk are adequate to detect and evaluate the occurrence of any such effects.
14.
Food Products, Gamma Spectrometry: No crops grown in the vicinity of Peach Bottom are irrigated with water in which liquid plant wastes have been discharged.
15.
Green Leafy Vegetation, I-131: The milk pathway, which results in a greater maximum dose to man than the vegetation pathway, is mon'tored at locations near the site and is a better indicator than vegetation samples.
The Branch Technical Position requires this analysis only if milk sampling is not performed.
16.
Determination of Instrument Setpoints:
The Licensee proposes that the methodology and equations for determination of the liquid and gaseous radwaste effluent monitor alarm and trip setpoints should not be incorporated into the Offsite Dose Cal'culation Manual.
The calculation of alarm and trip setpoints on the liquid radwaste effluent monitor is administratively I
controlled by approved Health Physics and Chemistry i
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proc durco subjcct to intsrnal revicw cnd cudit.
Thsro are an insufficient number of alarm setpoints available on the Peach Bottom gaseous radwaste effluent monitors to accommodate both Emergency Action Levels of the Emergency Plan and the ALARA limits of Appendix I.
Incorporating setpoint determination into the ODCM would subject all setpoint adjustments to prior Commission approval through the routine licensing process.
Licensee proposes that the licensing document be limited to the radioactive release limits, with alarm and trip setpoints determined by the Licensee's administrative controls.
This would expedite the necessary adjustments to reflect changing plant conditions and needs.
The operability requirements of the liquid and gaseous radwaste effluent monitors contained in the limiting conditions of ooeration of these Technical Specifications and the methodology contained in the Offsite Dose Calculation Manual for computation of doses to a member of the public at or beyond the site l
boundary, ensure that the specified doses are monitored and controlled.
17.
Instrument and Channel Calibration: The definition of instrument and channel calibration (page 3 of the propo cd T chnical Specifications) hoc bacn revierd to specify that "the known value of the parameter shall be injected into the channel or instrument as close to the primary sensor as practicable".
The proposed revision acknowledges the diverse calibration requirements of primary sensors associated with different parameters.
For example: the injection of a known signal into primary sensors measuring flow or vibration is not practicable.
18.
PORC Review of ODCM: Licensee proposes that the Offsite not be 'ubject to PORC Dose Calculation Manual (ODCM) s review and approval.
The expertise for developing and reviewing the ODCM resides with the offsite engineering group, not with the members of PORC.
Adding this responsibility to the PORC will distract their attention from plant operating activities for which they have primary responsibility, and is therefore not in the interest of plant safety.
Additionally, Licensee proposes that technical specification 3.8.C.8c be deleted.
Licensee is unaware of any technical basis that the Standby Gas Treatment System be available when purging the primary containment via the Reactor Building Ventilation Exhaust System.
As permitted by technical specification 3.8.C.8b, tha primary co'n'tcinmant may be purg d via th's Rocctor Building Ventilation Exhaust System (RBVES) whenever primary containment integrity is not required.
Appropriate isolation features are available to terminate primary containment purging via RBVES in the event this release path becomes unavailable.
Upon approval of the Technical Specifications contained herein, licensee requests a period of 6 months from the date of approval for implementation of Technical Specifications proposed in this amendment.
This period is requested for the preparation and PORC approval process of additional Health Physics and Chemistry procedures necessary for the administrative control of the Radiological Effluent Technical Specifications and the Offsite Dose Calculation Manual.
Additionally, existing procedures must be carefully reviewed and modified as necessary to ensure that the performance of plant activities currently performed are consistent with the Radiological Effluent Technical Specifications.
The methodology to be used in the calculation of off-site doses due to radioactive gaseous and liquid effluents, and details of the environmental radiological monitoring program are set forth in a document titled "Offsite Dose Calculation Manual, Peach Bottom Atomic Power Station, Units 2 and 3, Philadelphia Electric Company", Revision 0, which is filed herewith and l
incorporated herein by reference.
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I Tha Plant Operation Rsview Committeo Cnd tha Operation and Safety Review Committee have reviewed this Amendment and the changes to the Technical Specifications proposed herein and have concluded that they do not involve an unreviewed safety question or a significant hazard consideration, and will not endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY By A ISh-/.
Vi'elPresid4nt c __
COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA S. L. Daltroff, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Amendment to March 1, 1979, Application for Amendment of Facility Operating Licenses and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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/4 Subscribed and sworn to before me this M " day of tbcrects F19:L
< < d < 'l l. L/ Y&y,Lfg gl/
Notary' Public Nc tary Pubhc, Ptitaje!;;his. PhJafd;h:a Ce.
k'y Commisson [npres kfy 23. l!F 3.
c.
CERTIFICATE OF SERVICE I certify that service of the foregoing Amendment was made upon the Board of Supervisors, Peach Bottom Township, York County, Pennsylvania, by mailing a copy thereof, via first-class mail, to Albert R. Steele, Chairman of the Board of Supervisors, R.D. No.
1, Delta, Pennsylvania 17314; upon the Board of Supervisors, Fulton Township, Lancaster County, Pennsylvania, by mailing a copy thereof, via first-class mail, to George K.
Brinton, Chairman of the Board of Supervisors, Peach Bottom, Pennsylvania 17563; and upon the Board of Supervisors, Drumore Township, Lancaster County, Pennsylvania, by mailing a copy thereof, via first-class mail, to Wilmer P. Bolton, Chairman of the Board of Supervisors, R.D. No. 1, Holtwood, Pennsylvania l
17532; all this 29th day of
- November, 1982.
l fEuqEne J. Bradley {
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Attorney for l
Philadelphia Electric Company l
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