ML20056E133
| ML20056E133 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/13/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-221, NUDOCS 9308200080 | |
| Download: ML20056E133 (82) | |
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POLICY ISSUE August 13, 1993 (NEGATIVE CONSENT)
SECY-93-221 FOR:
The Commissioners FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
APPROVAL 0F DECOMMISSIONING PLAN AND AMENDMENT OF LICENSE FOR DRESDEN NUCLEAR POWER STATION, UNIT 1, COMMONWEALTH EDISON COMPANY PURPOSE:
To inform the Commission of the staff intent to issue an order approving the Decommissioning Plan for the Dresden Nuclear Power Station (Dresden 1) and a corresponding amendment to License No. DPR-2.
BACKGROUND:
Dresden 1 is a 700 MW thermal boiling water reactor (BWR) that was operated from July 1960 to October 31, 1978; the operating license was issued on September 28, 1959 and would expire on.May 4, 1996. On October 31, 1978, the Commonwealth Edison Company (the licensee or CECO) shut down Dresden 1 to backfit it with equipment to meet new Federal regulations and to perform chemical decontamination of major piping systems.
CECO transferred all spent fuel to the spent fuel pool.
While Dresden 1 was out of service, the NRC imposed new requirements after the March 1979 accident at the Three Mile Island Nuclear Station, Unit 2.
In October 1984, after completing the chemical cleaning, Ceco concluded that the age and small capacity of Dresden I did not warrant the investment required to bring it into compliance with the new requirements and therefore elected to seek decommissioning.
NOTE:
TO BE MADE PUBLICLY AVAILABLE WHEN THE FINAL SRM IS MADE AVAILABLE CONTACTS:
P. Erickson, ONDD/NRR 504-1101 S. Weiss, ONDD/NRR h
504-2170-m 9 3d8ADOOfd 9
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The Commissioners,
1 Dresden 1 shares the Dresden site with two operating BWRs (Dresden 2 and 3)~
that are also owned and operated by CECO. On January 7, 1986, Ceco submitted a request to amend the Dresden 1 operating license to a possession only license (POL) and proposed significant changes in the technical specifications (TS).
On July 23, 1986, the Commission issued the Dresden 1 POL, and stated that the NRC could not approve the proposed TS changes until CECO submitted a safety analysis or a decommissioning plan to support the proposed changes.
On December 22, 1987, CECO submitted the first version of a decommissioning plan in which Dresden 1 would remain in long-term safe storage (SAFSTOR) until after Dresden 2 and 3 were permanently shut down.
Ceco later submitted an environmental report and additional information in response to NRC requests.
The Dresden 2 and 3 licenses expire on January 10, 2006, and January 12, 2011, respectively.
The licensee requested to renew the license for Dresden 1 to April 10, 2029, and submitted a safety analysis to support the use of SAFSTOR until that date.
Without renewal, the Dresden 3 license would expire on May 4,1996, long before Units 2 and 3 will be decommissioned. The effort to decommission Dresden 2 and 3 could continue significantly beyond the' length of j
the Dresden 3 license which will expire in January 2011.
CECO may also j
request license extensions for either or both of these plants.
Therefore, the 2029 renewal date requested by the licensee is reasonable and is permitted by NRC regulations.
DISCUSSION:
The staff has enclosed (1) an order approving the proposed decommissioning plan, (2) a license amendment to establish the decor tissioning TS, (3) the supporting staff safety evaluation, (4) the environmental assessment, and (5) a Notice of Issuance of Environmental Assessment and Finding of No Significant Impact.
The order approves the Dresden 1 Decommissioning Plan and adds a condition to apply the criteria of 10 CFR 50.59 to allow future changes in the decommissioning plan by CECO. The amendment replaces the existing TS with the SAFSTOR TS, renews License No. DPR-2 until April 10, 2029, and deletes the license conditions that no longer apply.
The enclosed safety evaluation addresses (1) the renewal of License No. DPR-2 until 2029, (2) the SAFSTOR TS, (3) the decommissioning plan, (4) the deletion of obsolete license conditions, and (5) financial considerations.
In the safety evaluation, the staff evaluated the control of radioactive effluents, spent fuel storage, fire protection and administrative controls.
The staff concluded that there is reasonable assurance that the health and safety of the public will be adequately protected.
j In 6he environmental assessment, the staff evaluated exposure to workers, the control of radioactive waste, and other environmental issues in 10 CFR Part 51.
The staff concluded that decommissioning Dresden 1 as proposed will not significantly affect the quality of the human environment and that an
1 4
The Commissioners
- environmental impact statement is not required.
The staff proposes to publish the enclosed Notice of Issuance of Environmental Assessment and Finding of No Significant Impact in the Federal Reaister.
C0 ORDINATION:
The Office of the General Counsel has no legal objection to the paper, i
RECOMMENDATION:
Unless the Commission otherwise directs within 10 days from the date of this paper, the staff will issue the order approving the Dresden 1 Decommissioning Plan and the associated amendment that renews the license, revises the TS and deletes license conditions that no longer apply.
\\M. 4 s$r Tay)
E cutive Director for Operations
Enclosures:
1.
Order approving Dresden 1 Decommissioning Plan 2.
Amendment 37 3.
Safety Evaluation 4.
Environmental Assessment 5.
Notice of Issuance of Environmental Assessment and Finding of No Significant Impact SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Monday, August 30, 1993, that the Commission, by negative consent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners OGC OCAA OIG OPA OCA OPP REGION III EDO SECY
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Docket No.50-010 Mr. Thomas J. Kovach Nuclear Licensing Manager Commonwealth Edison Company 1400 OPUS Place - Suite 300 Downers Grove, Illinois 60515
Dear Mr. Kovach:
SUBJECT:
ORDER TO AUTHORIZE DECOMMISSIONING OF DRESDEN NUCLEAR POWER STATION, UNIT 1, AND AMENDMENT NO. 37 TO LICENSE NO. DPR-2 (TAC NO. M66949)
T".e Commission has issued the enclosed order to authorize decommissioning' of the Dresden Nuclear Power Station, Unit 1.
Also enclosed is Amendment No. 37 to License No. DPR-2 which revises the technical specifications and renews the license to April 10, 2029. The order and amendment respond to your application of January 7,1986 as revised December 22, 1987; April 29, September 2, and November 21, 1988; March 27, April 10, May 16, and November 1,1989; June 7,1991; February 7, and October 30, 1992; and June 8, and July 2, 1993.
On June 27, 1989, the Commission published a Notice of Consideration of Issuance of Amendment to License and Opportunity for Hearing on the requested action in the Federal Reaister (54 FR 27081). Neither a request for hearing nor comments were received.
l; I have enclosed a copy of the related Safety Evaluation and Environmental Assessment supporting the order and amendment.
I have also enclosed a copy of the Notice of Issuance of Environmental Assessment and Finding of No Significant Impact, which was published in the Federal Reaister on l
Sincerely, Peter B. Erickson, Senior Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation
Enclosures:
As stated cc w/ enclosures:
See next page
Mr. Thomas J. Kovach.
Docket No. 50-10 Commonwealth Edison Company Dresden. Nuclear Power Station, Unit I cc:
Michael I. Miller, Esq.
Sidley and Austin One First National Plaza Chicago, Illinois 60603 Mr. J. Eenigenburg Plant Superintendent Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 U.S. Nuclear Regulatory Commission Resident Inspectors Office Dresden Station Rural Route #1 Morris, Illinois 60450 Chairman Board of Supervisors of Grundy County Grundy County Courthouse Morris, Illinois 60450 Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road, Bldg. #4 Glen Ellyn, Illinois 60137 Illinois Department of Nuclear Safety l
Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Mr. David J. Chrzanowski i
Nuclear Licensing Administrator Commonwealth Edisun Company i
OPUS West III l
1400 OPUS Place Downers Grove, Illinois 60515 l
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NUCLEAR REGULATORY COMMISSION In the Matter of
)
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COMMONWEALTH EDISON COMPANY
)
Docket No.50-010
)
Facility License No. DPR-2 (Dresden Nuclear Power Station
)
Unit No. 1)
)
ORDER AUTHORIZING DECOMMISSIONING OF FACillTY In an application of January 7,1986, as revised December 22, 1987; April 29, September 2, and November 21, 1988; March 27, April 10, May 16, and November 1, 1989; June 7, 1991; February 7, and October 30, 1992; and June 8, and July 2,1993, Commonwealth Edison Company (Ceco or the licensee) requested the U.S. Nuclear Regulatory Commission (the Commission, NRC) to approve its proposed Decommissioning Plan (Plan) for the Dresden Nuclear Power Station, Unit 1 (Dresden 1) and an amendment to License DPR-2.
The amendment would renew the license to 2029, revise the technical specifications, and delete obsolete license conditions. The Decommissioning Plan involves long-term safe storage (SAFSTOR) of Dresden 1 until after the adjacent nuclear units (Dresden 2 and 3) are permanently shut down.
On June 27, 1989, the NRC published a Notice of Consideration of Issuance of Amendment to License and Opportunity for Hearing in the Federal Reaister (54 FR 27081).
No request for hearing or petition for leave to intervene was filed after the notice of proposed action.
I
The Commission has reviewed the application to determine if it meets Commission rules and regulations and has found that decommissioning as stated in the Plan will be consistent with the regulations in 10 CFR Chapter I, and will not be inimical to the common defense and security or to the health and safety of the public. The bases for these findings are in the Safety Evaluation issued concurrently by the NRC Office of Nuclear Reactor Regulation.
The Decommissioning Plan replaces the Dresden I safety analysis report.
Accordingly, the NRC added a license condition allowing the licensee to make changes to the Decommissioning Plan after performing a review based on criteria similar to the criteria of Section 50.59 of Title 10 of the Code of Federal Reaulations (10 CFR 50.59).
The Commission prepared an Environmental Assessment and Finding of No Significant Impact for the proposed action.
The Commission has determined that the proposed action will not result in any significant environmental impact and that an environmental impact statement need not be piapared.
The Notice of Issuance of Environmental Assessment was published in the Federal i
Reaister on Accordingly, pursuant to Sections 103, 161b, 1611, and 1610 of the Atomic Energy Act of 1954, as amended, and 10 CFR 50.82, the Commission approves the Proposed Decommissioning Plan of January 7, 1986, as revised, and authorizes the licensee to decommission the Dresden I facility in accordance with the Decommissioning Plan and the rules and regulations of the Commission, subject I
to the following conditions:
i (a)(1) The approved Decommissioning Plan replaces the safety analysis report in its entirety, and the licensee may (1) make changes in l
l
the facility or procedures as described in the Decommissioning Plan, and (ii) conduct tests or experiments not described in the Decommissioning Plan, without prior Commission approval, unless the proposed changes, tests, or experiments involve a change in the technical specifications (TS) incorporated in the license or an unreviewed safety question.
l (2) A proposed change, test or experiment shall be deemed to involve an unreviewed safety question (i) if the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Decommissioning Plan may be increased, or (ii) if a possibility for an accident or malfunction of a different type than evaluated previously in the Decommissioning Plan may be created, or (iii) if the margin of safety as defined in the basis for any l
, TS is reduced.
(b)(1) The licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facility or procedures as described in the Decommissioning Plan.
The licensee shall also maintain records of tests and experiments performed pursuant to paragraph (a) of this section.
These records must include a written safety evaluation containing the basis for the determination that the changes, tests or experiments do not involve an unreviewed safety question.
(2) The licensee shall annually submit, as specified in 10 CFR 50.4, a report containing a brief description of any changes, tests and experiments, including a summary of the safety evaluation of each.
(3) The licensee shall maintain the records of changes in the facility until the date of termination of the license and shall maintain the records of changes in procedures and records of tests and experiments for three years.
(c)
If the licensee desires (1) to make a change in the TS or (2) to make a change in the facility or procedures described in the Decommissioning Plan or to conduct tests or experiments not described in the Decommissioning Plan, which involve an unreviewed safety question or a change in the TS, it shall submit an application for amendment of its license pursuant to 10 CFR 50.90 or request approval of a revision to the Decommissioning Plan.
i i
a For further details with respect to this action, see:
(1) the application for authorization to decommission Dresden 1, dated January 7, 1986, as revised; (2) Amendment No. 37 to License No. DPR-2; (3) the Commission Safety Evaluation; and (4) the Commission Environmental Assessment.
These' documents are available for public inspection at the Commission Public Document Room, the Gelman Building, 2120 L Street, N.W., Washington, D.C. 20555, and at the Morris Public Library, 604 Liberty Street, Morris, Illinois 60450.
I Dated at Rockville, Maryland this FOR THE NUCLEAR REGULATORY COMMISSION Thomas E. Murley, Director Office of Nuclear Reactor Regulation l
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COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR POWER STATION. UNIT 1 DOCKET NO.50-010 AMENDMENT TO POSSESSION ONLY LICENSE i
Amendment No. 37 i
License No. DPR-2 i
1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to' License No. DPR-2 filed by Commonwealth Edison Company (the licensee) e-January 7, 1986, and 23
{
revised December 22, 1987; April 29, September 2, and November 21, 1988; March 27, April 10, May 16, and November 1, 1989; June 7, 1991; February 7, and October 30, 1992; and June 8, and July 2, 1993, i
complies with the standards and requirements of the Atomic Energy Act i
of 1954, as amended (the Act), and Commission rules and regulations in l
10 CFR Chapter I, B.
The. facility will be maintained in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance that (i) the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) such activities will be conducted in compliance with Commission regulations; D.
The issuance of this amendment will not be inimical to the. common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission regulations and all applicable requirements have been satisfied.
i
- ~ ~.... - - -. -. - -
i 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2); and by deleting paragraphs 2.C.(3)', (4), (5), and (6) which no longer apply; and revising paragraph 2.F, " Fire Protection;"
and paragraph 3. as follows:
(2) Technical Specifications The Technical Specifications in Appendix A as revised through Amendment No. 37, are hereby incorporated in the license.
The licensee shall maintain the facility in accordance with the Technical l
Specifications.
F.
Fire Protection The Dresden Administrative Procedures specify the fire protection program. The Dresden Administrative Technical Requirements specify the limiting conditions for operation and surveillance requirements.
These provisions are subject to the following:
l The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not decrease the effectiveness of the fire protection capability.
[
l 3.
This amended license is effective as of its date of issuance and shall expire at midnight, April 10, 2029.
l FOR THE NUCLEAR REGULATORY COMMISSION l
Seymour H. Weiss, Director l
Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation 1
Attachment-Appendix A Technical Specification Changes Date of Issuance:
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4 ATTACHMENT TO LICENSE AMENDMENT NO. 37 POSSESSION ONLY LICENSE NO. DPR-2 DOCKET NO.50-010 Replace all of the pages of the Appendix A Technical Specifications with the enclosed pages.
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Drsedsn I DPR-2 Amtndm:nt No.
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l Appendix A to Amended Facility License DPR-2 Technical Specifications and Bases For 1
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Dresden Nuclear Power Station Unit 1 Crundy County, Illin'is o
1 Commonwealth Edison Corupany Docket No. 50-10 Date:
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l TABLE OF CONTENTS
.PAGE 1.0 Definitions..........................
1-1 1
1.1 Safety Limits - Deleted 1
1.2 Safety Limits - Deleted 2.1 LSSS - Deleted i
2.2 LSSS - Deleted j
i 3.0 LIMITING CQHDITION FOR REOUIRED EQUIPMENT I
i i
Sections 3.1 through 3.7 - deleted l
l 3.8 Radioactive Materials....................
3/4.8-1 i
3.8 A. Airborne Effluents....................
3/4.8-1 l
e 3.8 B.
Liquid Effluents.....................
3/4.8-2 3.8 C.
Deleted i
3.8 D.
Radioactive Haste Storage................
3/4.8-3 3.8 E.
Radioactive Effluent Monitoring Availability.......
3/4.8-3 3.8 F.
Deleted 3.8 G.
Miscellaneous Radioactive Haste Sources.........
3/4.8-4 3.8 H. General.........................
3/4.8-3 3.9 Aux 111ary Electric Systems - Deleted 3.10 Fuel Handling and Storage................
3/4.10-1 3.10.A. and 3.10.B - Deleted e
1 3.10 C.
Fuel Storage Pool Water Level............ 3/4.10-1 3.10 D.
Deleted 3.10 E. Nuclear Fuel.....................
3/4.10-1 3.11 High Energy Piping Integrity - Deleted 3.12 Fire Protection Systems.................
3/4.12-1 Sections 3.12.A through 3.12.H - Deleted per Generic Letters 86-10 J
and 88-12 (Amendment 101) i't 0353T:16 8911200231 891101 l
PDR ADOCK 05000010 p
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j SURVEILLANCE REOUIREMENT TABLE OF CONTENTS (Cont'd)
PAGE Sections 4.1 through 4.7 - Deleted i
4.8 Radioactive Materials...................
3/4.8 '
4.8 A.
Airborne Effluents...................
3/4.8-1 l
l i
4.8 B.
Liquid Effluents....................
3/4.8-2 t
4.9 C.
Deleted I
4.8 D.
Radioactive Waste Storage................
3/4.8-3
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4.8 E.
Radioactive Effluent Monitoring Availability......
3/4.8-3 i
4.8 F.
Deleted
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4.8 G.
Miscellaneous Radioactive Materials Sources......
3/4.8-4 i
L 4.8 H.
Ge ne ral........................
3 / 4. 8-3 4.9 Aux 111aryElectricalSystems-Deieted t
4.10 Fuel Handling and Storage.................
3/4.10-1 4.10 A. through 4.10.B. Deleted i
4.10 C.
Fuel Storage Pool Water Level.............
3/4.10-1 l
i 4.10 D.
Deleted 4.10 E.
Nu c l e ar Fue l......................
3 /4.10- 1 1
4.11 High Energy Piping Integrity - Deleted 4.12 Fire Protection Systems - Deleted l
l 5.0 Design Features........................
5-1 I
i 5.1 Site.............................
5-1 Sections 5.2 - 5.4 Deleted 5.5 Fuel Storage.........................
5-1 5.6 Seismic Design - Deleted til
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ADMINISTRATIVE CONTROLS TABLE OF CONTENTS (Cont'd)
PAGE 6.0 Administrative Controls....................
6-1 6.1 Organization, Review, Investigation and Audit.....
6-1 6.2 Plant Operating Procedures...................
6-11 6.3 Action To Be Taken in the Event of a Reportable Event in Plant Operation..............
6-13 6.5 Plant Operating Records....................
6-13 6.6 Reporting Requirements.....................
6-14 l
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LIST OF TABL3 Page l
l Table 6.6.1 Minimum Shift Manning Chart 6-4 1
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Table 6.6.1 Special Reports......
6-22 LIST OF FIGURES l
None 1
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Dresden I DPR-2 Amendment No.
1.0 Defini tiann The succeeding frequently used terms are explicitly defined so that a uniform interpretation of the specifications may be achieved.
j A.
T= mediate - Immediate means that the required action will be initiated as soon as practicable considering the safe operatio='of the unit and the importance of the required action.
B.
Instrument Calibration - An instrument calibration means the adjustment of an instrument signal output so that it correspeads, within acceptable range, and accuracy, to a known value(s) of the l
parameter which the instrument monitors. Calibration shall encompass the entire instrument including actuation, alarm, or trip.
C.
Instrument Functfenm1 Test - An instrument functional test means the injection of a simulated signal into the instrument primary sensor i
to verify the proper instrument response, alarm, and/or initiating l
action. The primary sensors of radiation monitors are excepted from this definition. For these monitors.the functional test will i
consist of injecting a simulated electrical signal into the 1
measurement channel.
t D.
Instrument Check - An instrument check is qualitative determination of acceptable operability by observation of instrument behavior during operation. This determination shall include, where possible, comparison of the instrument with other independent instruments measuring the same variable.
l E.
Doerable - A system, subsystem, train, component, or device shall be operable when it is capable of performing its specified i
function (s).
Implicit in this definition shall be the assumption that all necessary attendent instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its j
function (s) are also capable of performing their related support function (s).
F.
Doeratine - Operating means that a system, subsystem, train, component or device is performing its intended functions in its required manner.
G.
Surveillance Interval - Each surveillpace requirement shall be performed within the specified surveillance interval with:.
A maximum allowable extension not to exceed 25% of the a.
surveillsace interval.
b.
A total maximum combined interval time for any 3 consecutive intervals not to exceed 3.25 times the specified surveillance interval.
i 1.0-1 WP+4144
I Dra: den I DPR-2 Amendment Ns.
E.
off aite Dome calentation Manual (ODcM) - Contains the methodology j
and parameters used in the calculations of offsite doses due to radioactive gaseous and liquid effluents, and in the calculation of I
gaseous and liquid effluent monitor alarm / trip setpoints.
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I.
Process Control Program (PCP) - Contains the sampling, analysis, and formulation determination by which solidification,of radioactive wastes from liquid systems is assured.
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Dresden I DPR-2 Amendment No.
1.1 Safety Limits-Fuel Cladding Integrity 2.1 Limitir,g Safety System Settings -
Fuel Cisdding Integrity Deleted Deleted Deleted 1.2 Safety Limits-Reactor Coolant System 2.2 Limiting Safety System Settings -
Reactor Coolant System Deleted Deleted i
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Dracden I DPR<-2 l
Amendment Ne 3.0 LIMITING CONDITION FOR REQUIRED 4.0 SUT.VEILLANCE REQUIREMENTS EQUIPMENT 3.1 Reactor Protection System 4.1 Reactor Protection System __
Deleted Deleted 3.2 Protective Instrumentation 4.2 Protective Instrumentation Deleted Deleted 3.3 Reactivity Control 4.3 Reactivity Centrol Deleted Deleted 3.4 Standby Liquid Control System 4.4 Standby Liquid Control System I
Deleted Deleted 3.5 Core and Containment Cooling Systema 4.5 Core and Containment Cooling Systems Deleted Deleted 3.6 Primary System Boundary 4.6 Primary System Boundary Deleted Deleted 3.7 Containment Systems 4.7 Containment Systems Deleted Deleted l
3/4.1-1 WP+4144
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i Dreases 1 DPR-2 Amendment No.
3.8 Limitine Conditien For Recuired Ecuiement 4.8 Surveillance Recuirement 3.8 Radioactive Materials 4.8 Radioactive Materials Apolicability:
Aeolicability:
Applies to the radioactive effluents Applies to the periodic rnnitoring and l
from the plant.
recording of radioactive effluents.
t Obiective:
Obiective:
To assure that radioactive effluents are To ascertain that radioactive releases kept as low as practicable, and, in any are kept as low as practicab'le and are event, are not released to the within allowable values.
environment in an uncontrolled manner l
and to assure that any mate. rial released Specification:
l is within the limits of 10 CFR 20.
A.
Airborne Effluents Soecification:
1.
The main chimney monitoring A.
Airborne Effluents system shall have a daily instrument check, monthly 1.
Radioactive gases released source check, quarterly from the Dresden Unit 1 function test and once per 18 chimney shall be continuously month calibration.
monitored. To accomplish l
this, the chimney monitoring 2.
Main Chimney activity analysis system shall be operable at shall be performed at the l
all times except as noted in specified frequencies.
Specification 3.8.E.
Main chimney noble 1/ month a.
2.
Airborne effluents from Unit 1 gas (tritium and shall be added to those from principal gamma Units 2 and 3 and be included emitters).
in the site dose rate as calculated from prescribed b.
Main chimney parti-1/ month
- samples and following methods culate (principal prescribed in the approved genna emitters).
Dresden ODCM.
c.
Main chimney 1/ month *
- iodine, d.
Main chimney parti-1/qtr.
j culate composite 1
(Sr-89, Sr-90, i
gross alpha).
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Note
- Analysis frequency shall be l
l increased to 1/ week if release rates exceed 1% of any applicable limit referenced in Section O
3.8.A.2.
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3/4.8-1 WT+4144
Drecden I DPR-2 Amendment Ns.
3.8 Limitine condition For Recuired 4.8 Surveillance Recuirement (Cont'd)
Eeufement (Cont'd)
B.
Liquid Effluents B.
Liquid Effluents 1.
a.
The service water radiation 1.
Radioactive effluents shril monitor shall have an inst-not be released from Unit I rument check performed
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storage tanks directly to the daily, a functional check environment (release can be performed quarterly, and a made through D2/3 Radwaste source check and i
System). Radioactive calibration performed once effluents may be released from every 18 months.,
j Units 2 and 3 by way of the Unit 1 discharge canal only b.
The operability of the when discharges are controlled discharge canal sampler on a radionuclide basis in shall be verified prior to accordance with Appendix B, performing and once a day Table II, Column 2 of 10 CFR during planned discharge.
20 and all applicable limits listed in DPR-19 and DPR-25.
c.
Station records of batch Additionally, the discharge releases from Units 2 and 3 canal sampler shall be shall be maintained in j
operable at any time a radio-accordance with the active discharge is occurring specifications of DPR-19 via this pathway or the and DPR-25.
radioactive discharge shall be i
idmediately suspendeds 2.
a.
Activity analysis of conti-I nuous service water s
2.
The service water discharge discharge shall be shall be continuously performed monthly for monitored and the I-131, principal gamma concentration (above emitters dissolved and en-background) in the condenser trained gases, H-3, and cooling water discharge canal gross alpha activity.
shall not exceed the limits Additional analysis for stated below unless the Sr-89, Sr-90 and Fe-55 discharge is controlled on a shall be performed radionuclide basis in quarterly.
sccordance with Appendix B.
Table II, Column 2 of 10 CTR b.
In the event of failure of 20 and Note 1 thereto:
the service water monitor, effluents may continue to Maximum concentrat a be released via this pathway if a service water 1 x 10-7 pCi/mi grab sample is taken once C.
Deleted every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and analyzed.
C.
Deleted
,~
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i Drosden I DPR-2 l
l e
Amendment No.
l 3.8 TAmitine condition For Reouired Eculoment 4.8 Surveillance Requirement (Cont'd) l l
(Cont'd)
D.
Radioactive Waste Storage D.
Radioactive Waste Storage The maximum amount of radioactivity A sample from each of the l
in liquid storage in all Dresden above-grade liquid waste tanks Stations above grade tanks shall shall be taken, analyzed, and not exceed 90 curies.
If these recorded every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
If no conditions cannot be met the stored additions to a tank have been made liquid shall be recycled within 24' since the last sample, the. tank hours to below grade tanks.. All need not be sampled until the next tanks located within the seismic addition.
portion of the Chemical Cleaning Building are not considered above grade storage.
E.
Radioactive Effluent Monitoring E.
Radioactive Effluent Monitoring Availability Availability J
t 1.
The entire main chimney 1.
a.
The main chimn'ey noble gas monitoring system, including monitor may be out-of-the particulate filters and service for calibration and-I charcoal cartridges, may be maintenance provided that a out of service for calibration noble gas grab. sample is or maintenance provided that taken daily and analyzed.
the requirements listed in 4.8.E.,are satisfied.
b.
The main chimney f
particulate.and iodine sampling eystem may be out-of-service for maintenance provided that i
particulate and iodine i
samples shall be collected
)
using alternate filter holders and pumps connected l
to the main chimney. sample stream.
(
F.
Deleted F.
Deleted i
i 3/4.8-3
' af,,
WP+4144
- de
- -edilm e eeepeo s e enemy, e e -eas.e w
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Dronden I DPR-2
\\
Amendment N3.
i 3.8 Limitine Condition For Recuired 4.8 Surveillance Recuirement (Cont'd) i Eculpment (Cont'd)
G.
Miscellaneous Radioactive Materials G.
Miscellaneous Radioactive Materials Sources Sources Source Leakare Test Each sealed' source shall be tested for leakage and/or contamination by Snecification the licensee or by other persons specifically authorized by the Each sealed source containing Commission or an Agreement State.
radioactiv'e material in excess of The test method shall have a 100 microcuries of beta and/or detection sensitivity of at least gamma emitting material or 5 0.005 microcuries per test sample.
microcuries of alpha emitting material shall be free of 1 0.005 Each category of sealed sources microcuries of removable shall be tested at the frequency contamination.
described below.
Each sealed source with removable 1.
Sources in use (excludine contamination in excess of the startuo sources oreviousiv above limit shall be immediately subiected to core flux) - At withdrawn from use and either least once per six months for decontaminated and repaired or all sealed sourr.es containing disposed of in accordance with radioactive material:
Commission regulations.
a.
With a half-life greater l
A complete inventory of radioactive than 30 drys (excluding l
materials in the licensee's Bydrogen 3), and possession shall be maintained I,
current at all times.
b.
In any form other than gas.
2.
Stored sources not in use -
Each sealed source shall be tested prior to use or transfer to another licensee unless tested within the previous six months. Scaled sources transferred without a certificate indicating the last
~
test date shall be tested prior to being placed into use.
A Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.6.C.3 if source leakage tests reveal the
(
presence of 2 0.005 microcuries of removable contamination.
' /
i
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3/4.8-4 i
WP44144 i
Drc: den I DPR-2 Amendment N3.
3.8,Limilipe Condition For Recuired 4.8 Surveillance Recuirement (Cont'd)
Eouierent (Cont'd)
H.
General H.
General It is expected that releases of 1.
Operating procedures shall be radioactive material in effluents developed and used, and will be kept at small fractions of equipment which has-been the limits specified in Section installed to maintain control 20.106 of 10 CFR Part 20.
The over radioactive materials in licensee will exert his best gaseous and liquid effluents efforts to keep levels of produced during normal activity radioactive material in effluents shall be maintained and used, as low as is reasonably achievable.
to keep levels of radioactive
' material in effluents released to unrestricted areas as low as is reasonably achievable. The environmental monitoring program'given in the ODCM shall be conducted.
I l
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3/4.8-5 i
WF+4144 l
brecden I DPR-2 Amendment No.
BASES A.
Airborne Effluents - The basis for airborne effluents from the site are contad.ned in the Off-Site Dose Calculation Manual.
l i
i B.
Licuid Effluents - Liquid effluent release rate will be controlled in terms of the concentration in the discharge canal. In the case of unidentified mixtures, such concentration limit is based on assumption that the entire content is made up of the most restrictive isotope in accordance with 10 CFR 20.
Such a limit assures that even if a person obtained all of his daily water intake from such a l
source, the resultant dose would not exceed that specified in 10 CFR 20.
Since no such use of the discharge canal is made and considerable natural dilution occurs prior to any location where such doses could occur, this assures that off-site doses from this source will be far less than the limits specified in 10 CFR 20.
C.
Deleted D.
Radioactive Liouid Waste Storare - The maximum gross radioactivity in i
liquid storage in the specified~ tanks has been limited on the basis of an accidental spill from all stated tanks due to a seismic event j
great enough to damage them. The Chemical' Cleaning Building is seismically designed and designed to contain a simultaneous spill from all the contaminated liquid stogage tanks housed within.
Assuming a low river flow'of 3100 f t /sec, a day period over which the radioactive liquid wastes are diluted in the river, and consumption of the water by individuals at standard man consumption rate (3000 ml/ day), the single intake by an individual would not exceed one-third the yearly intake 9 owable by 10 CFR 20 for 11 unidentified radioisotopes (1 x 10- pCi/ml).
The factor of 3 was applied to 10 CFR 20 limits as recommended for situations in which population groups could be exposed.
The sampling frequency has been established so that if the maximum amount of gross radioactivity is exceeded, action can be taken to reduce the radioactivity to a level below the specified limit.
E.
Radioactive Effluent Monitor 4ne Availability F.
Deleted C.
Mineellaneous Radlemetive Materlata Sources The objective of this specification is to assure that leakage from byproduct, source and special nuclear material sources does not exceed allowable limits.. The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(c) limits for plutonium.
H.
Environmental Radiolorical Monitorine Prorram - The bases for the environmental monitoring program are contained in the ODCM.
f g...
3.3/4.8-6 WP+4144
_ =..... -.....
Dr;; den I DPR-2 Amendment N3.
3.9 Limitine Condition For Reenired Eouinm g 4.9 Surveillance Recuirement
.9 Auxiliary Electrient Systemn 4.9 Atatiliarv Electrieml Systeme j
Deleted Deleted 1
J 1
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i Drccden I DPR-2 Amendment N3.
EASES Deleted a
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B.3/4.9-2 WP+41h4 1
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+y, 6
Drooden I DPR-2 Amendment No.
3.10 Limitine condition For Reauired Eeulement 4.10 Surveillance Requirement Fuel Bandline and Storare Fuel Handline and Storare Aeolienbility Aeolicability Applies to fuel handling and fuel Applies to the recording of the fuel storage.
pool water level and water quality parameters.
Obiective Obiective To prohibit fuel from being loaded into To verify the fuel pool wate'r level is the reactor core and ensure adequate maintained as specified in 3.10.C and fuel pool wat.er level and quality.
water quality parameters as specified in 3.10.F.
i Specification Snecification A. and B.
- Deleted A. and B. - Deleted C.
Fuel Storage Pool Water Level C.
Fuel Storage Pool Water Level Whenever irradiated fuel is stored Whenever irradiated fuel is stored in the fuel storage pool, the pool in the fuel storage pool, the pool water level shall be maintained at water level shall be recorded daily.
f a level of at least 18 feet.
l D.
DE!JtTED E.
Nuclear Fuel shall sat be loaded D. DE LETED into the reactor core.
F.
Fuel Storage Pool Water Quality F.
Fuel Storage Pool Water Once initial fuel pool cleanup is 1.
Sample and analyze monthly.
completed:
l 1.
CEId.5 ppm 2.
Conductivity 1 10.0 paho/cm 025'c 3.
pH 5.3 to 8.6 If any of the above limits are exceeded, prepare and submit to the commission within 30 days, a Special Report which identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to ensure that future water quality is in compliance with specification 3.10.F.
This is in lieu of a Licensee Event Report.
3/4.10-1 WP+4144
.. ~....
j Dro: den I DPR-2 4
Amendment No.
i RASES
?
i C.
Fuel Storare Pool Water Level -
l To assure that there is adequate water to shield and cool the irradiated fuel assemblies stored in the pool, a minimum pool water level is established. The minimum water level of 18 feet is established because it would be a significant change from the normal level, well above a level to assure adequate cooling (just above active fuel) and above the level at which the GSEP action is initiated (5' uncontrolled loss of level with level decreasing).
t j
E.
Reactor Core To assure that a critical assembly of nuclear fuel is no longer i
possible in'the reactor core, the placement of nuclear fuel into the j
reactor core is specifically prohibited.
F.
Fuel Storare Pool Water Duality ll i
In December 1983, the Unit i fuel pool water cooling and cleanup system was taken out of service because of operational problems.
i i
This did not adversely affect the fuel shielding or cooling since the latest discharged fuel had been in the pool over seven years; however, two years of stagnation led to the growth of micro-organisms and the concern for microbial influenced corrosion (MIC) of pool i
structures. The pool water was treated with hydrogen peroxide in i
December 1987 to kill the organisms. Following the treatment, the pool bottom was vacuumed to remove the debris. Periodic visual j
examinations of fuel assemblies have revealed no corrosion effects from either MIC or the long term peroxide treatment. A continuous purification filtration system was installed in March 1989 to control i
the water purity.
i l
i i
I
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4 e
3.3/4.10-2 Y
e l
Decaden I DPR-2 Amendsment No.
l 3.11 Limitina conditions for coeration 4.11 Surveillance Recuirements t
Eich Enerry Pipine Interrity Hirh Enerry Pfeine Interrity Deleted Deleted b
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)
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WP+4144
=
f Drecden I DPR-2 Amendment Ns.
5.0 Desien Features 5.1 Site Dresden Unit 1 is located at the Dresden Nuclear Power Station which-consists of a tract of land of approximately 953 acres located in the Northwest quarter of the Morris 15-einute quadrangle (as designated by the U.S. Geological Survey), Goose Lake Township, Grundy County, Illinois. The tract is situated in portions of Sections 25, 26, 27, 34, 35, and 36 of Township 34 North, Range 8 East of the Third Principal Meridian.
3 2 ~ 5.4 - DEt1TED 5.5 ruel storare The K,gg of the spent fuel storage pool shall be less than or equal to 0.90 S6 sessxie DESIGM - DELET.E.D
~
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I WP+4144
.7..........
---..a _.-.
DRESDFN I DPR-2 Amendment No.
6.0 ADMINISTRATTVE CONTROLS 6.1 Orranization. Review. Investiration and Audit A.
Onsite and offsite organizations shall be established for the unit operation and corporate management, respectively The onsite and offsite organizations shall include the positions for activities affecting the safety of the nuclear power plant.
1.
Lines of authority, responsibility, and communication shall be established and defined for the highest management levels through the intermediate levels to and including all oper.ating organization positions.
These relationships shall be documented and updated, as appropriate, in the form of organization charts, functional descriptions of department responsibilities and relationships, and job descriptions for key personnel positions, or in the equivalent forms of documentation. The requirements shall be documented in the Quality Assurance Manual or the Management Plan for Nuclear Operations, Section 3 Organizational Authority Activity; Section 6 Interdepartmental Relationships.
2.
The Station Manager shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of plant.
3.
The Senior Vice President-Nuclear Operations shall have the corporate responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
4.
The individuals who train the operating staff and those who l
carry out health physics and quality assurance functions may report to the appropriate onsite manager; however. thav ah=11 have sufficient organizational freedom to ensure their independence from operati.onal pressures.
B.
DELETED l
C.
The shif t manning for the station shall be as shown in Table 6.1.1.
i The Operating Assistant Superintendent, Operating Engineers, Shif t Engineers, and Shift Foremen shall have a Senior Operating License.
The Fuel Handling Foreman shall have a limited Senior Operating License.
The Vice President BWR Operations on the corporate level has responsibility for the Fire Protection Program.
An Operating Engineer at the station will be responsible for implementation of the Fire Protection Program.
l 6-1 l
..__.._..._,...___......._m DRESDEN I DPR-2 Amendment N2.
6.0 ADMINISTRATTVE CONTROLS (Cont'd. )
i D.
Qualifications of the station management and operating staff shall meet minimum acceptable levels as described in ANSI N18.1,
" Selection and Training of Nuclear Power Plant Personnel," dated March 8, 1971, with the exception of the Health Physics Services
~
Supervisor who shall meet or exceed the qualifications of Radiation Protection Manager of Regulatory Guide 1.8, September 1975, and the Shif t Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant for transients and accidents. The individual filling the position of Technical Superintendent shall meet the minimum acceptable level for
" Technical Manager" as described in 4.2.4 of ANSI N18.1 - 1971.
E.
Retraining and replacement training of Station personnel shall be in accordance with ANSI N18.1, " Selection and Training of Nuclear Power Plant Personnel," dated March 8, 1971.
A training program for the fire brigade shall be maintained under the direction of the Operating Engineer and shall meet or exceed the requirements of Section 27 of the NFPA Code - 1975, except for fire brigade training sessions which shall be held at least quarterly.
]
F.
Retraining shall be conducted at intervals not exceeding two years.
G.
The. Review and Investigative Function and the Audit Function of activities affecting quality during facility operations shall be constituted and have the responsibilities and authorities outlined below:
1.
The Superintendent of the Off-site Review and Investigative Function shall be appointed by the Manager of Quality Assurance / Nuclear Safety (QA/NS). The Corporate Audit Function shall be the responsibility of the Manager of QA/NS and shall be independent of operations. The Manager of QA/NS reports directly to the Chief Executive Officer and has the responsibility to set Corporate Policy for both the areas of Quality Assurance and Nuclear Safety. Policy is promulgated through a central policy committee directed by the Manager of QA/NS. The Manager of QA/NS has the responsibility for the performance of periodic audits of each nuclear station and corporate department to determine that QA/NS policy is being carried out.
s.
Off-site Review and Investirative Function The Superintendent of the Off-site Review and Investigative Function shall: (i) provide directions for the review
{"N.
6-2
--- _.~
DRESDEN I DPR-2 Amendment Na.
6.0 AININISTRATIVE CONTROLS (Cont'd.)
and investigative function and appoint a senior participant to provide appropriate direction, (ii) select each participant for this function, (iii) select a complement of more than one participant who collectively possess background and qualifications in the subject matter under review to provide comprehensive interdisciplinary review coverage under this f unction, (iv) independently review and approve the findings and recommendations developed by personnel performing the review and investigative function.
(v) approve and report in a timely manner all findings of noncompliance with NRC requirements and provide recommendations to the Station Manager, Vice Preside'nt BWR Operations, Manager of QA/NS, Assistant Vice President (AVP) Quality Programs and Assessment, and the Senior Vice President Nuclear Operations. During periods when the Superintendent of the Off-site Review and Investigative Function is unavailable, he shall designate this respon-sibility to an established alternate who satisfies the formal training and experience requirements for the Super-intendent of the Off-site Review and Investigative Function.
The responsibilities of the personnel performing this function are stated below. The Off-site Review and Investigative Function shall review:
(1) The safety evaluations for 1) changes to procedures, equipment or systems as described in the safety analysis report and (2) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute unreviewed safety questions. Proposed changes to the Quality Assurance Program description shall be reviewed and approved by the Manager of QA/NS.
(2) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59.
(3) Proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59.
(4) Proposed changes in Technical Specifications or NRC
~
operating licenses.
6-3
DRESDEN I ppR-2 Amendment No.
TABLE 6.1.1 MININJM SHIFT MANNING CHART (1)
I CONDITION OF NUMBER OF MEN IN EACH p0$fTf 0N UNITS STA or NON.
RAD 4
III RQ(3) g g ggg; WITH FUEL FIRST UNIT SECOND UNIT THIRD INIT 22 Cold shutdown Cold Shutdown Cold Shutdown 1
1 0
5 1
ONE Above Celd Shutdown Cold Shutdown Cold Shutdown 2
2 1
5 1
Cold Shutdewn Cold Shutdown Cold Shutdown 1
2 0
5 1
TWO Above Cold shutdown Cold shutdown Cold shutdown 2
3 1
5 1
Above Above Cold Shutdown Cold Shutdown Cold Shutdown 2
3 1
5 1
1 i
- Senior Reactor Operator. At least one SR0 must remain in the Control Room at all times when one or more units is above cold shutdown. This person may, however, leave the Control Room for periods not to exceed 10 minutes, provided another SRO acts as relief operator. The $CRE or shif t supervisor can fulfill this requirement.
- Reactor Operator (For each reactor containing fuel., one R0 will be in the Control Room at all times.)
- Station Control Room Engineer (STA with Senior Reactor Operator's License).
N04-LIC.
- Equipment Operators and Equipment Attendants.
RAD EN
- Radiation protection Men.
NOTES: (1) - $hif t crew composition may be less than the minimum requirements for s period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected abrence of on-duty shif t crew members provided immediate action is taken to restore the shif t crew composition to within the minimum requirements.
(2) - Does not include the licensed Senior Reacter Operator or Senior Reactor Operator limited to fuel handling, supervising CDRE OPERATIONS.
(3) - Shall not operate units on which they are not licensed.
AD0!TIONAL REQUIREMENTS A.
SRO can be R0 at controls.
B.
$RO in Control Room cannot provide relief to $R0/R0 at controls.
C.
$RO in Control Room must be in sight of or audible range of operator at all times or be in audible range of annunciators.
G 0
DRESDEN I DPR-2 Amendment No.
6.0 ADMINISTRATIVE CONTROLS (Cont'd. )
- (5) Noncompliance with NRC requirements, or of internal procedures or instructions having nuclear safety significance.
(6) Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety as referred to it by the On-site Review and Investigative Function.
Reporta'le events' under 10 CFR 50.73.
(7) b (8) All recognized indications of an unanticipated' deficiency in some aspect of design or operation of safety related structures, systems or components.
(9) Review and report findings and recommendations regarding all changes to the Generating Stations Emergency Plan prior to implementation of such changes.
(10) Review and report findings and recommendations regarding all items referred by the Technical Staff Supervisor, Station Manager, Vice President BWR
. Operations and AVP Quality Programs and Assessment.
(11) Review changes to the Fire Protection-Program and implementing procedures.
b.
~ Station Audit Function The Station Audit Function shall be the responsibility of the AVP Quality Programs and Assessment independent of BWR Operations. Such responsibility is delegated to the Nuclear Quality Programs Manager.
Either of the above, or designated Corporate Staff or Supervisor approved by AVP Quality Programs and Assessment shall approve the audit agenda and checklists, the findings and the report of each audit. Audits shall be performed in accordance with the Company Quality Assurance Program and Procedures. Audits shall be performed. to assure that safety-related functions are covered within the period designated below:
(1) Audit of the Conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per year.
(..
6-5
DRESDEN I DPR-2 Amendment NJ.
6.0 ADMINISTRATIVE CONTROLS (Cont'd.)
~ (2) Audit of the adherence to procedures, training and qualification of the station staff at least once per year.
(3) Audit of the results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or methods of operation that affect nuclear safety at least once per six months.
(4) Audit of the performance of activities required by the Quality Assurance Program to meet the Criteria of Appendix "B", 10 CFR 50 at least once per 4 months.
(5) Audit of the Facility Emergency Plan and Laplementing procedures at least once per 12 months.
(6) Audit of the Facility Security Plan and " implementing procedures at least once per 12 months.
(7) Audit on-site and off-site reviews at least once per 24 months.
I (8) Audit of Facility Fire Protection Program and l
implementing procedures at least once per 24 months..
(9) The radiological environmental monitoring program and the results thereof at least once per 12 months.
i (10) The ODCM and implementing procedures at least once per 24 months.
(11) The PCP and implementing procedures for solidifi-cation of radioactive waste at least once per 24 months.
(12) Report all findings of nencompliance with NRC requirements and recommendations and results of each audit to the Station Manager, the Manager of QA/NS, the Vice President BWR Operations, AVP Quality Programs and Assessment, the Senior Vice President-l Nuclear Operations and the Chief Operating Officer.
(13) Changes to the Decommissioning Plan.
l l
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6-6
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=_____..__..-.....n..
DRESDEN I DPR-2 Amendment Ns.
6.0 AININISTRATIVE CONTROI.S (Cont'd.)
c.
" Authority
)
1 1
The Manager of QA/NS reports to the Chief Executive
]
Officer. The Manager of QA/NS has the authority to order unit shutdown or request any other action which he deems necessary to avoid unsafe plant conditions.
The AVP Quality Programs and Assessment reports to the Senior Vice President-Nuclear Operations. The AVP Quality Programs and Assessment has the authority to recommend unit shutdown or request any other action which he d.eems necessary to avoid unsafe plant conditions. All such disagreements shall be reported immediately to the Manager of QA/NS and the Chief Operating Officer.
d.
Records I
(1) Reviews, audits and recommendations shall be doeur'nted and distributed as covered in 6.1.G.l.a and 6.
' 1.b.
(2) Copies of documentation, reports, and correspondence shall be kept on file at the station.
I e.
Procedures i
Written administrative procedures shall be prepared and i
maintained for the Off-site Reviews and Investigative i
Functions described in Specifications 6.1.G.1.a.
These
)
Procedures shall cover the following:
i (1) Content and method of submission of presentations to the Superintendent of the Off-site Review and Investigative Function.
j (2) Use of committees and consultants.
(3) Review and approval.
(4) Detailed listing of itans to be reviewed.
(5) Method of (a) appointing personnel, (b) performing j
reviews, investigations, (c) reporting findings and i
recommendations of reviews and investigations (d) j approving reports, and (e) distributing reports.
j F
1 6-7 l
i 1
l l
DRESDEN I DPR-2 Amendment No.
i 6.0 ADMINISTRATIVE CONTROLE (Cont'd.)
(6) Determining satisfactory completion of action required based on improved findings and recommendations reported by personnel performing the review and investigative function.
f.
Persennel (1) The persons, including consultants, performing the review and investigative function, in addition to the Superintendent of the Off-site Review and Investigative Function, shall have expertise in one or more of the following disciplines as appropriate for the subject or subjects being reviewed and investigated.
(a) nuclear power plant technology i
(b) reactor operat' ions (c) utility operations (d) power plant design 1
(e) reactor engineering l
(f) radiological safety (g) reactor safety analysis (h) instrumentation and control (i) metallurgy (j) any other appropriate disciplines required by I
unique characteristics of the facility.
(2) Individuals performing the Review and Investigative Function shall possess a minimum formal training and experience as listed below for each discipline.
(a) Nuclear Power Plant Technology i
?
Engineering graduate or equivalent with 5 years experience in the nuclear power field design and/or operation.
. (b) Reactor Operations Engineering graduate or equivalent with 5 years experience in the nuclear power plant operations.
(c) Utility Operations l
l l
Engineering graduate or equivalent with at least j
5 years of experience in utility operation l
and/or engineering.
j l
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6-8 1
W9 a
. m s.
. a a - ~..
t DRESDEN I DPR-2 Amendment No.
6.0 AININISTRATIVE CONTROLS (Cont 'd.)
~
(d) Power Plant Design i
Engineering graduate or equivalent with at least 5 years of experience in power plant design and/or operation.
I (e) Reactor Engineering.
I Engineering graduate or' equivalent.
In
{
addition, at least 5 years of experience in nuclear plant engineering, operation, and/,or graduate work in nuclear engineering or equivalent in reactor physics is required.
(f) Radiological Safety Engineering graduate or equivalent with at least t
5 years of experience in radiation control and safety.
(g) Safety Analysis e
Engineering graduate or equivalent with at least 5 years of experience in nuclear engineering.
(h) Instrumentation and Control Engineering graduate or equivalent with at least f
5 years of experience in instrumentation and control design and/or operation.
i (1) Metallurgy Engineering graduate or equivalent.with at least 5 years of experience in the metallurgical field.
(3) The Superintendent of the Off-site Review and l
Investigative Function shall have experience and training which satisfy ANSI N18.1 - 1971 requirements for plant managers.
2.
The On-site Review and Investigative Function shall be supervised by the Station Manager. The Station Manager can i
designate this responsibility to an alternate who satisfies the*
i ANSI N18.1 (March 8,1971) experience requirements for Plant Manager i
i I
i 6-9 I
..___.. _ _ _ _ _... _ - ~
- -.... ~ -
~
i t
DRESDEN I DPR-2 Amendment Ns.
[
6.0 ADMINISTRATIVE CONTROIS (Cont'd.)
l a.
' On-site Review and Investf rative Function The Station Manager (or designee) shall: (i) provide direction for the Review and Investigative Function and appoint the Technical Staff Supervisor. or other comparably qualified individual as a senior participant to provide appropriate direction; (ii) approve participants for this function; (iii) assure that a complement of more than one participant who collectively possess background and qualifications in the subject matter under review are selected to provide comprehensive inter-disciplinary review coverage under. this function; (iv) independen'tly review and approve the findings and recommendations developed by personnel performing the Review and l
Investigative Function; (v) report all findings of noncompliance with NRC requirements, and provide recommendations and (vi) submit to the Offsite Review and Investigative Function for concurrence in a timely manner, those items described in Specification 6.1.G.I.a which have been approved by the On-site Review and Investigative Function.
The responsibilities of the personnel performing this function are stated below:
i (1) Review of: 1) procedures required by Specification l
6.2 and changes thereto, 2) any other proposed procedures or changes thereto as determined by the l
Station Manager (or designee) to affect nuclear l
safety.
~
t (2) Review of all proposed tests and experiments that affect nuclear safety.
(3) Review of all proposed changes to the Technical Specifications.
(4) Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
(5) Investigation of all noncompliance with NRC requirements and shall prepare and forward a report covering evaluation and recoaunendations to prevent recurrence.
(6) Review of facility operations to detect potential safety hazards.
l
<~:.,
~!
6-10
/
i DRESDEN I DPR-2 Amendment No.
I 6.0 ADMINISTRATIVE CONN 0IS (Cont'd.)
" (7) Performance of special reviews and investigations and reports thereon as requested by the Superintendent of the Off-site Review and Investigative Function.
(8) Review of the Station Security Plan and shall submit recommended changes to the Director of Corporate Security and the AVP Quality Programs and Assessment in lieu of distribution in accordance with 6.1.G.2.c.(1).
(9) Review of the Emergency Plan and station implementing procedures and identification of recommended changes.
(10) Review of reportable events and actions taken to prevent recurrence.
(11) Review of any unplanned on-site release of radioactive material to the environs including the preparation and forwarding of reports covering evaluation recommendations and disposition of the l
corrective action to prevent recurrence to the Vice l
President BWR Operations and to the Superintendent of i
l the Off-site Review and Investigative Function.
l (12) Review of changes to the PCP and UDCM and major
. changes to the radwaste treatment systems.
1 l
(13) Review changes to the Fire Protection Program and implementing procedures.
b.
Authority The Technical Staff Supervisor is responsible to the Station Manager (or designee) and shall make recommenda-tions in a timely manner in all areas of review, investigation, and quality control phases of plant maintenance, operation and administrative procedures relating to facility operations. The Technical Staff Supervisor shall have the authority to request the action necessary to ensure compliance with rules, regulations, and procedures when in his opinion such action is necessary. The Station Manager (or designee) shall follow such recommendations or select a course of action that is more conservative regarding safe operation of the,
facility. All such disagreements shall be reported immediately to the Vice President BWR Operations anel the Superintendent of the Off-site Review and Investigative Function.
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i DRESDEN I DPR-2 Amendment No.
l 6.0 AININISTRATIVE CONTROLS (Cont'd. )
- c. " Reeerds (1) Reports, reviews, investigations, and recommendations prepared and performed for Specification 6.1.G.2.a shall be documented with copies to the Vice President BWR Operations, the Superintendent of the Off-site Review and Investigative Function, and the AVP Quality Programs and Assessment.
l l
(2) Copies of all records and documentation shall be kept on file at the station.
d.
Procedures l
Written administrative procedures shall be prepared and maintained for conduct of the On-site Review and Investigative Function. These procedures shall include the following:
(1) Content and method of submission and presentation to the Station Manager (or designee) Vice president EWR Operations and the Superintendent of the Off-site Review and Investigative Function.
(2) Use of committees.
(3) Review and approval, (4) Detailed listing of items to be reviewed.
(5) Procedures for administration of the quality control activities.
(6) Assignment of responsibilities.
e.
Persennel (1) The personnel performing the On-site Review and Investigative Function, in addition to the Station Manager (or designee) shall consist of persons having expertise in:
(a) nuclear power plant technology (b) reactor operations (c) reactor engineering (d) radiological safety (e) chemistry (f) instrumentation and control (g) mechanical and electric systems.
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DRESDEN I DPR-2' Amendment No.
6.0 ADMINIS*HLATIVE. CONTROLS (Cont'd.)
(2) Personnel performing the On-site Review and Investigative Function shall meet minimum acceptable levels as described in ANSI N18.1,1971, Sections 4.2 and 4.4.
H.
Fire Protection.
L 1.
An independent fire protection and loss prevention program inspection and audit shall be performed at least once per 12 months utilizing either qualified off-site licensee personnel or an outside fire protection firm.
2.
An inspection and audit of the fire protection and loss prevention program shall be performed by a qualified outside fire consultant at least once per 36 months.
6.2 Plant Oeeratine Procedures i
A.
Detailed written procedures including applicable checkoff lists covering items listed below shall be prepared, approved, and adhered to:
1.
Systems and components involving nuclear safety of the facility.
i j
2.
Deleted.
3.
Actions to be taken to correct specific and foreseen potential _
i malfunctions of systems or components including responses to alarms.
4.
Emergency conditions involving potential or actual release of radioactivity
" Generating Stations Emergency Plan" and station emergency and abnormal procedures.
5.
Instrumentation operation which could have an effect on the safety of the facility.
6.
Preventive and corrective maintenance operations which could have an effect on the safety of the facility.
l 7.
Surveillance and testing requirements.
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DRESDEN I DPR-2 Amendment No.
I l
6.0 AININISTPATIVE CONTROLS (Cont'd. )
i 8.
Tests and experiments.
9.
Deleted.
10.
Station Security Plan and implementing procedures.
11.
Fire Protection Program implementation.
12.
ODCM implementation.
13.
PCP implementation.
14.
Working hours of 'the Shift Engineer, Station Control Room Engineer, Shift Foreman, and Nuclear Station Operator job classifications such that the heavy use of overtime is not routinely required.
B.
Radiation control procedures shall be maintained, made available to all station personnel and adhered to.
These procedures shall show permissible radiation exposure and shall be consistent with the requirements of 10 CFR 20.
This radiation protection program shall be organized to meet the requirements of 10 CFR 20.
l C.
1.
Procedures for items identified in Specification 6.2.A and any changes to such procedures shall be reviewed and approved by the Operating Engineer and the Technical Staff Supervisor in the areas of operation, fuel handling, or instrument maintenance, and by the Maintenance Assistant Superintendent and Technical Staff Supervisor in the areas of plant maintenance and plant inspection. Procedures for items identified in Specification 6.2.B and any changes to such procedures shall be reviewed and approved by the Health Physics Services Supervisor. At least one person approving each of the above procedures shall hold a valid senior reactor operator's license. In addition, these procedures and changes thereto must have authorization by the Station Manager (or designee) before being implemented.
2.
Work and instruction type procedures which implement approved maintenance or modification procedures shall be approved and authorized by the Maintenance Assistant Superintendent where the written authority has been provided by the Production Superintendent. The " Maintenance / Modification Procedure" utilized for safety related work shall be so approved only if procedures referenced in the " Maintenance / Modification Procedure" have been approved as n
6-14
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-DRESDEN I DPR-2 Amendment No.
6.0 ADMINISTRATIVE CONTROLS (Cont'd.)
req 6 ired by 6.2.A.
Procedures which do not fall within the requirements of 6.2.A or 6.2.B may be approved by the Department Heads.
i D.
Temporary changes to procedures 6.2.A and 6.2.3 above may be made 3
provided:
1.
The intent of the original procedure is not altered.
1 2.
The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License for Units 2 and 3.
3.
The change is documented, reviewed by the On-site Review and Investigative Function and approved by the Station Manager (or I
designee) within 14 days of implementation.
t E.
Drills of the emergency procedures described in Specification 6.2.A.4 shall be conducted at the frequency specified in the Generating Station Emergency Plan.
These drills will be planned so that during the course of the year, communication links are tested and outside agencies are contacted.
6.3 Action to be Taken in the Event of a Reportable Event in Plant Operation Any reporta'ble event shall be promptly' reported to the Vice President BWR f
Operations or his designated alternate. The incident shall be promptly reviewed pursuant to Specification 6.1.G.2.a(5) and a separate report for each reportable event shall be prepared in accordance with the l
requirements of Specification 6.6.B.
r f
6.4 Deleted.
6.5 Plant Operating Records A.
Records and/or logs relative in the following items shall be kept in i
a manner convenient for review and shall be retained for at least-five years.
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DRESDEN I DPR-2 Amendment No.
6.0 AIMINISTRATIVE CONTROLS (Cont'd.)
1.
Deleted.
2.
Records of standby operations and principal maintenance -~
activities, including inspection and repair, regarding principal items of equipment pertaining to nuclear safety.
3.
Records and reports of reportable and safety limit events.
4.
Records and periodic checks, inspection and/or calibrations performed to verify the Surveillance Requirements (See Section 4 of these Specifications) are being met. All equipment failing to meet surveillance requirements and the corrective action *e en shall be recorded.
v 5.
Records of changes made to the equipment or reviews of tests and experiments to comply with 10 CFR 50.59.
6.
Records of radioactive shipments.
7.
Records of tests pertaining to nuclear safety.
8.
Records of changes to operating procedures.
l 9.
Shift Engineers Logs.
10.
By-product material inventory records and source leak test results.
B.
Records and/or logs relative to the following items shall be recorded in a manner convenient for review and shall be retained for the life of the plant.
1.
Substitution or replacement of principal items of equipment pertaining to nuclear safety.
2.
Changes maJe to the plant as it is described in the Safety Analysis Report.
1 i
3.
Records of spent fuel inventory and assembly histories.
i j
4.
(Deleted) i S.
Updated, corrected, and as-built drawings of the plant.
l 6.
Records of plant radiation and contamination surveya.
j 7.
Records of off-site environmental monitoring surveys.
l 6-16 l
DRESDEN I DPR-2 Amendment N3.
6.0 AININISTRATIVE OONTROLS (Cont'd.)
8.
Records of radiation exposure for e.11 plant personnel, including all contractors and vit,itors to the plant in accordance with 10 CFR 20.
9.
Records of radioactivity in liquid and gaseous wastes released to the environment.
- 10. Deleted.
11.
Records of individual staff members indicating qualifications, experience, training and retraining.
12.
Deleted.
- 13. Minutes of meetings and results of reviews performed by the Off-site and On-site Review Functions.
14.
Deleted.
6.6 REPORTING REOUIREMENTS In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following identified reports shall be submitted to the Regional Administrator of the appropriate Regional Office of the NRC unless otherwise noted.
A.
Routine Recorts 1.
Deleted.
2.
A tabulation shall be submitted on an annual basis of the number of station, utility and other pers nnel (including contractors) receiving exposures greater than 100 mrem /yr and their associated man rem exposure according to work and job functions, (See Note); e.g.,
reactor operations and surveillance, inservice inspection, routine maintenance, special maintenance (describe maintenance), waste processing, and refueling. The dose assignment to various duty functions may be esthnates based on pocket dosimeter. TLD, or film badge measurements. Small exposures totalling less than 20% of the individual total dose need not be accounted for.
In the aggregate, at least 80% of the total whole body dose received from external sources shall be assigned to specific major work functions.
3.
Deleted.
Note:
This tabulation supplements the requirements of 20.407 of 10 CFR Part 20.
~6-17 e
DRESDEN I DPR-2 Amendoent No.
6.0 ADMINISTRATIVE CONTROLS (Cont'd.)
B.
Reoortable Events Reportable events will be submitted as required by 10 CFR 50.73.
C.
Unione Reoortine Recuirements 1.
Radioactive Effluent Release Reoort i Anrual)
A report shall be submitted to the Commission within 60 days after January 1 of each year specifying the quantity of each of the principal radionuclides released to unrest ~ricted areas in liquid and gaseous effluents du.ing the previous 12 l
months. The format and content of the ritport shall be in accordance with Regulatory Guide 1.21 (Revision 1) dated June 1974. Any changes to the PCP shall be included in this report.
2.
Environmental Radioactivity Data (Annual Report) i Standard Radiological Monitoring Program a.
(1) Non-Routine Report (a) If a confirmed measured radionuclide concentration in an environmental sampling medium averaged over any; calendar quarter sampling period exceeds the reporting level given in Table 4.8-1 and if the radioactivity is I
attributable to plant operation, a written report shall be submitted to the Regional Administrator of the NRC Regional Office with a copy to the Director Office of Nuclear Reactor l
Regulation, within 30 days from the end of the quarter. When more than one of the radiosuclides in Table 4.8-1 are detected in the medium, the reporting level shall have been exceeded if I(Cg/(RL)g) is equal to or greater than 1 where C is the concentration of the ith radionuclide in the medium and RL is the reporting level of radionuclide i.
(b) If radionuclides other than those in Table 4.8-1 are detected and are due to plant effluents, a reporting level is exceeded if the potential annual dose to an individual is equal to or greater than the design objective doses of 10 CPR 50, Appendix I.
(
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DRESDEN I DPR-2 i
Amendment No.
l 6.0 ADMINISTRATIVE CONTROLS (Cont'd.)
(c) This report shall include an evaluation of any l
release conditions, environmental factors, or other aspects necessary to explain the anomalous effect.
(2) Annual Operating Report An annual report containing the data taken in the standard radiological monitoring program (Table l
4.8-1) shall be submit:2d by March 31 of the next year. The content of the report shall include:
l l
(a) Results of environmental sampling sunnarized on a quarterly basis following the format o" Regulatory Guide 4.8 Table 1 (December 1975);
(individual sample results will be retained at the station);
In the event that some results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons i
for the missing results. Sunnaries, interpretatit 's, and analysis. of trends of the results are to be provided.
(b) An assessment of the monitbring results and
' radiation dose via the principal pathways of arposure resulting from plant emissions of l
radioactivity including the maximum noble gas gamma and beta air doses in the unrestricted
[
area. The assessment of radiation doses shall be perfermed in accordance with the ODOM.
(c) Results of the census to determine the locations of animals producing milk for human consumption, and th~e pasture season feeding practices at dairies in the monitoring program.
(d) The reason for the omi Sion if the nearest dairy to the station is not in the monitoring program.
(Table 4.8-5)
(e) An annual susmary of meteorological conditions concurrent with the releases of gaseous
{
effluents in the form of joint frequency i
distributions of wind speed, wind direction, and i
atmospheric stability.
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DRESDEN I DPR-2 Amendment No.
6.0 AININISTRATIV CONTROLS (Cont'd.)
~
(f) The results of che interlaboratory comparison program described in Section 3.8.E.7.
(g) The results of the 40 CFR 190 uranium fuel cycle dose analysis for each calendar year (h) A summary of the monitoring program, including l
maps showing sampling locations and tables giving distance and direction of sampling locations from the station.
3.
Special Reports Special reports shall be submitted as indicated in Table 6.6.1.
6.7 Deleted.
i 6.8 Offsite Dose Calculation Manual (ODCM)
A.
The ODCM shall describe the methodology and parameters to be used in the calculation of offsite doses due to radioactive gaseous and liquid effluents and in the calculation of gaseous and liquid effluent monitoring instrumentation alarm / trip setpoints consistent with the applicable 1.CO's contained in th'se Technical e
Specifications. Methodologies and calculational l
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Amendment No.
l TABLE 6.6.1 SPECIAL REPORTS SPECIFICATION
/Jia REFTRENCE SUBMITTAL DATE 1
a.
Radioactive Source Leak Testing (1) 3.8.F Annual Report l
t i
NOTES:
1.
The report is required only if the tests reveal the presence of 0.005 i
microcuries or more of removable contamination.
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- DPR-2 Amendment Ns.-
l 6.0 ADMINISTRATIVE CONTROLS (Cont'd.)
procedurts acceptable to the Commission are contained in NUREG-0133.
~
The ODCM shall be submitted to the Comission 'at the time of proposed Radiological Effluent Technical ~ Specifications and shall be l
subject to review and approval by the Comission prior to implementation.
l B.
Licensee initiated changes to the ODCM may be made provided the change i
1.
Shall be submitted to the Commission by inclusion in the l
Monthly Operating Report pursuant to Specification 6.6.A.'3.
I within 90 days of the date the change (s) was made effective and i
shall contain:
r a.
Sufficiently detailed information to support the~ change.
Information submitted should consist of a package of those pages of the ODCM to be changed together with appropriate i
analyses or evaluations justifying the change (s);
j b.
A determination that the change will not reduce the' accuracy or reliability of dose calculations or setpoint determinations; and
, Documentation of'the fact'that the change has been c.
reviewed and foun'd acceptable by the On-site Review Function..
2.
Shall become effective upon review and acceptance by the.-
On-Site Review Function.
6.9 Process Control Program (PCP) f A.
be PCP shall contain the sampling, analysis, and formulation seterminstion by Wich solidification of radioactive wastes from liquid systems is assured.
i B.
The PCP shall be approved by the Commission prior to implementation.
C.
Licensee initiated changes may be made to the PCP provided the change:
1.
Shall be submitted to the Commission in the Radioactive
' Effluent Release Report for the period in which'the change was made and st.all contain:
l 1
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DRESDEN I DPR-2 Amendment No.
6.0 AININISTRATIVE CONTROLS (Cont 'd. )
Sufficiently detailed information to support the change; a.
b.
A determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes; and Documentation that the change has been reviewed and found c.
acceptable by the On-site Review Function.
2.
Shall become effective upon review and acceptance by the On-site Review Function.
i 6.10 Major Changes to Radioactive Waste Treatment Systems (Liquid, Gaseous, i
Solid) (See note below) l A.
Licensee initiated major changes to the radioactive waste systems may be made provided 1,.
The change is reported in the Monthly Operating Report for the period in which the evaluation was reviewed by the On-site Review Function. The discussion of each change shall contain:
A summary of the evaluation that led to the determination a.
i that the change could be made in accordance with 10 CFR 50.59; b.
Sufficient detailed information to support the reason for the change; A detailed description of the equipment, components, and c.
process involved'and the interfaces with other plant systems; d.
An evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments; A comparison of the predicted releases of radioactive e.
materials in liquid and gaseous effluents and in solid 4
1 waste to the actual releases for the period in which the changes were made; f.
An estimate of the exposure to plant operating personnel as a result of the change; and Note:
Licensee may choose to submit this infonaation as part of the annual FSAR update.
+
6-13 1
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DRESDEN I DPR-2 Amendment No.
6.0 ADMINISTRATIVE CONTROLS (Cont'd.)
f g.
Documentation of the fact that the change was reviewed and l
found acceptable by the On-site Review Function.
i 2.
The change shall become effective upon review and acceptance by.
l the On-site Review Function, j
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UNITED STATES
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g NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 t
a
%v*.... f SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDER AUTHORIZING DECOMMISSIONING AND AMENDMENT NO. 37 TO POSSESSION ONLY LICENSE NO. DPR-2 COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR POWER STATION. UNIT 1 DOCKET NO.50-010 1.
INTRODUCTION AND BACKGROUND Dresden Nuclear Power Station, Unit 1 (Dresden 1) is a 700 MW-thermal boiling water reactor (BWR) that operated from July 1960 to October 31, 1978.
On October 31, 1978, Commonwealth Edison Company (Ceco or the licensee) shut down Dresden 1 to backfit it with equipment to meet new Federal regulations and to perform chemical decontamination of major piping systems.
While Dresden 1 was out of service, the U.S. Nuclear Regulatory Commission (NRC) imposed new requirements after the March 1979 accident at Three Mile Island, Unit 2.
Ceco later concluded that the age and small capacity of Dresden I did not warrant the investment needed to bring it into compliance with the new requirements and therefore elected decommissioning.
Dresden 1 shares the Dresden site with two operating BWRs (Dresden 2 and 3) th:1 are also owned and operated by Ceco. The Dresden site is near the confluence of the Kankakee and Des Plaines Rivers in Grundy County near Morris, Illinois.
The site is about 50 miles southwest of Chicago, Illinois.
After permanently shutting down Dresden 1 on October 31, 1978, the licensee transferred the spent fuel to the spent fuel storage pool.
In an application of January 7, 1986, as revised December 22, 1987; April 29, September 2, and November 21, 1988; March 27, April 10, May 1-6, and November 1, 1989; June 7, 1991; February 7, and October 30, 1992; and June 8, and July 2,1993, the licensee requested NRC approval of its proposed SAFSTOR Decommissioning Plan (Plan) for Dresden I and an amendment of License No. DPR-2. The proposed amendment provides for the NRC to replace the current technical specifications (TS) with the "SAFSTOR" TS, renew License No. DPR-2 until April 10, 2029, delete several obsolete license conditions, and revise the license condition on fire protection. SAFSTOR is defined as the decommissioning alternative in which the facility is placed and maintained in i
a condition that allows it to be safely stored until it is later decontaminated to levels that permit the release of the property for unrestricted use.
j I
On July 23, 1986, the NRC amended the Operating License No. DPR-2, to a possession only license (POL). On June 27, 1989, the NRC published a Notice i
of Consideration of Issuance of Amendment to License and Opportunity for Hearing for the proposed decommissioning in the Federal Reaister (54 FR 27081).
After issuing the Notice, the NRC received neither a request for hearing nor comments.
2.
EVALVATION The NRC staff evaluated safety issues for the SAFSTOR Decommissioning Plan, the renewal of License No. DPR-2 to April 10, 2029, the amendment to the technical specification (TS), the deletion of certain license conditions, and CECO financial assurance plan.
The storage of spent fuel is the major safety issue for Dresden 1, since the spent fuel contains the largest inventory of residual radionuclides.
l 2.1 Evaluation of License Renewal The licensee intends to decommission all three units simultaneously.
The Dresden 2 and 3 licenses expire on January 10, 2006, and January 12, 2011, l
respectively. Without renewal, the Dresden 1 license would expire on May 4, 1996, long before the decommissioning of Units 2 and 3.
The effort to decommission Units 2 and 3 could continue significantly beyond January 2011, the Dresden 3 license expiration date.
Ceco may also request license renewals for either or both of these units.
In a letter of May 16, 1989, the licensee requested the NRC to renew the license for Dresden 1 to April 10, 2029, and enclosed a no significant hazards consideration analysis to support that i
request. The NRC Federal Reaister Notice of June 27, 1989, included the proposed renewal date of April 10, 2029.
Based on our evaluation of the proposed license renewal, the proposed decommissioning plan and the proposed TS, the staff concludes that renewal of the Dresden I license from May 4, 1996 to April 10, 2029 is permitted by NRC regulations and is reasonable and acceptable.
2.2 SAFSTOR Technical Specifications (TS)
Dresden 1 is defueled with all the spent fuel stored in the Fuel Storage Building (FSB). The fuel will remain in the FSB until after a Federal repository is established, probably after the year 2010.
The proposed TS prohibit moving any fuel into the reactor and impose the requirements and controls for retaining Dresden 1 in a SAFSTOR status.
l At the Dresden Station, all three units are contiguous, and some facilities and certain safety-related systems are common to all three. units.
The shared auxiliary facilities include the station analytical laboratory, the laundry, and maintenance shops, which are all located in or adjacent to Dresden 1.
The l
station fire suppression system uses the Dresden I diesel fire pump and screen wash pumps, and the station water supply is a part of Dresden 1.
The t
l 1,
Dresden 1 instrument air and station air compressors are connected to the ~~
Dresden 2 and 3 systems. All three units share the security plan, emergency plan, fire protection plan, radiation protection plan, and environmental monitoring plan which protect all three units.
The staff reviewed the proposed Dresden 1 TS and verified that the required systems and program plans are adequate to ensure safety of the proposed SAFSTOR alternative for Dresden 1.
The staff has determined that the Dresden 1 TS are consistent with the TS of.the other two units, and that the change in the TS for Unit I will not adversely affect the safe operation of Units 2 and 3.
The staff finds the Administrative Controls Section of the TS which includes the station organizational functions, personnel qualifications, training, safety committee functions, procedures, records, and reporting systems to be acceptable since they are consistent with the defueled non-operating condition of Dresden 1.
Some of the proposed Dresden 1 TS require compliance with NRC-approved Dresden Unit 2 and Unit 3 programs including the Station Environmental Monitoring Plan and the reporting requirements of the Offsite Dose Calculation Manual (0DCM).
The fire suppression water system documented in the Dresden Administrative Technical Requirements (DATR) is common to all units.
The licensee proposed to delete from the TS the safety limits, the limiting safety system settings, and the limiting conditions for operation (LCO) for Dresden 1 reactor operations.
Limiting conditions required for shared safety-related equipment were retained.
The staff evaluated and verified each change, deletion and retention in the proposed SAFSTOR TS. The following sections of this evaluation are numbered according to the proposed TS, and the TS numbers are horizontally centered on the page.
LO/2.0. " Definitions and Desian Features" The licensee proposed to change the Definitions section by deleting all definitions pertaining to the operational modes and retaining only those that apply to the SAFSTOR mode. The licensee deleted the primary system definitions including those for the reactor vessel, containment, and seismic design features. The licensee added two definitions, one for the ODCM and another for the Process Control Program. The staff concludes that the proposed changes to definitions are appropriate for the defueled non-operating condition of Dresden 1 and are acceptable.
3.0. "Limitina Conditions for Recuired Ecuipment" The licensee proposed modifying Limiting Conditions for Required Equipment (LCRE), formerly LCOs in the operational TS, to adapt them to the SAFSTOR mode. The licensee deleted all operational mode LCOs, including those for the reactor protection system, protective instrumentation, reactivity control, standby liquid control, core and containment cooling, primary system boundary, containment system, high energy piping, and fuel cladding integrity.
I 4-The reactor is permanently defueled; therefore, no protective instrumentation or safety systems are needed. The spent fuel has decayed so that active spent l
fuel pool cooling is no longer required.
The licensee removed the primary and l
secondary systems from service and chemically removed most of the loose activation products.
As a consequence, operational mode LCOs and containment integrity are no longer required. These deletions and modifications to Section 3.0 of the TS are consistent with the non-operating status of Unit I and thus are acceptable.
3.8. " Radioactive Materials" A.
Airborne Effluents In 1984, the Y
issued Dresden 2 and 3 TS Amendments No. 83 and No. 77, to establish requirements consistent with the guidelines of Appendix I to 10 CFR Part 50.
Sections 3.8 and 4.8, " Radioactive Materials," of the Dresden 2 and 3 TS are identical and specify dose rate limits for unrestricted areas at or beyond the Dresden site boundary from all gaseous effluent sources within the site.
The proposed Dresden 1 airborne effluent TS states that gaseous effluents shall be added to the total site effluents and be included in the site dose rate as calculated from specified samples and following the methods prescribed in the approved Dresden ODCM.
The gaseous effluents discharged from Dresden I chimney include the exhausts from the turbine building, the reactor building, the off-gas filter building, the blow down flash tank, the fuel storage building, and the controlled areas of the access building, such as the laboratory, the l
laundry, and the machine shop. These effluents will continue to be filtered through pre-roughing and HEPA filters before being discharged.
A representative 60-liter-per-minute sample of the chimney exhaust is continuously monitored with control and alarm terminals located in the control room for Dresden 2 and 3.
The proposed Dresden 1 TS require continuous monitoring of the plant chimney even though no iodine will be released from Dresden 1; however, small amounts could be released from Dresden 2 and 3 through the adjacent Dresden 1 turbine building. The minimum frequency of analysis for iodine is decreased from weekly to monthly. All other analysis frequencies remain unchanged. The licensee proposed to modify the TS surveillance requirements for the Dresden I chimney continuous monitor to be consistent with those in the Dresden 2 and 3 TS.
The ventilation exhaust from the chemical cleaning facility is filtered through roughing and HEPA filters before discharge.
The filtered exhaust is continuously sampled through a particulate filter and iodine cartridge which are analyzed weekly.
l l
l
- l The exhaust from the radioactive waste storage building is filtered
~'
through roughing and HEPA filters before discharge.
It is not sampled or monitored. The only wastes now processed through this facility are miscellaneous seepage and drainage waters.
j The licensee expects insignificant gaseous effluent radioactivity from Dresden 1 during the SAFSTOR period; however, all but the gaseous effluents from the waste storage building and above ground waste storage tanks are continuously monitored and, if applicable, would be added to and reported with the Dresden site effluents.
B.
Liquid Effluents The licensee uses the waste system for Dresden 2 and 3 to process for disposal all radioactive liquid wastes from Dresden 1, which may include liquids from the radioactive waste collector tank, the waste neutralizer tank, the secondary steam generator collection tanks, the turbine building floor drains, laundry waste, laboratory waste, and the waste storage and hold-up tanks.
The only other sources of liquid effluents are the circulating water system, which is no longer in.use, and the service water from both Dresden 1 and the Chemical Cleaning Facility.
This service water, which is now used only for air conditioning and for cooling the turbine building closed cooling water system, is continuously monitored with an alarm in the control room.
Each month, the licensee obtains and analyzes a composite sample. The service water system in the Chemical Cleaning Facility is no longer in use but is equipped with a continuous monitor if needed.
C.
Radioactive Waste Storage The waste storage limits are unchanged. The liceme removed from the station all Dresden 1 chemical cleaning waste that was stored in the Chemical Cleaning Facility. The licensee solidified and shipped these l
wastes as controlled under the Dresden Process Control Program (PCP) which l
is appropriately referenced in the proposed Dresden 1 TS.
D.
General l
This sectior remains unchanged except for the addition of a commitment to I
follow the etfironmental monitoring program in the ODCM. The portions of the TS that specified effluent concentration limits have been deleted since these limits are now controlled by the ODCM.
Since the reactor was shut down in 1978, the irradiated fuel and contained I
activation products have decayed significantly.
In 1982, the licensee chemically cleaned the primary system removing approximately 755 curies of radionuclides.
As a consequence, the radioactive effluents from Dresden 1 are insignificant.
The licensee has implemented approved radiation protection and environmental monitoring programs at the Dresden station, conducting radiation surveys on a quarterly schedule and maintaining and testing the area radiation monitors.
l
i For the above stated reasons, the proposed radioactive materials TS are
~"
I acceptable.
3.9. " Auxiliary Electrical Systems" The licensee proposed to delete the TS for the Dresden 1 auxiliary electrical l
systems, which include two 138-kV transmission lines, a diesel generator with l
starting batteries, a 34.5-kV substation, two 480-V buses, and the 125-Vdc l
station batteries. The stored irradiated fuel, the most significant hazard, l
has decayed sufficiently so that the heat load no longer requires mechanical l
cooling or the related electrical systems. The fuel storage pool cooling system has been out of service for many years and only occasional water additions, to replace evaporation losses, are required to maintain the water shielding level.
Therefore, no significant radiological releases would result from failure of the auxiliary electrical systems at Dresden 1 during the SAFSTOR period.
Since shutting down Dresden 1 in 1978, the licensee has continued its l
maintenance and surveillance program.
It will continue this program to l
maintain and test, as needed, all Dresden 1 electrical systems except for the l
main generator, transformers 1 and 11, and the emergency diesel generator system.
Therefore, the auxiliary electrical system TS may be deleted and electrical j
service to safely maintain Dresden 1 in the SAFSTOR mode will be achieved with l
the remaining equipment and the existing preventive maintenance and surveillance programs.
Accordingly, the TS proposed by the licensee are acceptable.
3.10. " Fuel Handijna and Storaae" This new section replaces the LCO, " Refueling." The licensee proposed to delete all TS requirements formerly pertaining to refueling, such as interlocks, nuclear instrumentation, control rod (CR) and CR drive maintenance and to add the restriction that nuclear fuel cannot be loaded into the reactor.
The proposed TS require daily checks of the minimum water level in the fuel storage pool.
If the water level dropped, a pool level float would actuate alarms in the Radioactive Waste Building and in the Dresden I control room.
The area radiation monitor in the Fuel Storage Building (FSB) would also actuate an alarm in the control room if the pool level decreased; thus giving more redundancy in monitoring this parameter.
A very conservative radiological accident at Dresden I would be to assume the simultaneous rupture of all 683 fuel assemblies stored in the FSB.
This non-mechanistic event is of an extremely low probability. However, the licensee submitted an evaluation of such an accident to determine the worst case radiological exposure to personnel in the FSB and to the public at the nearest unrestricted area boundary or exclusion area boundary (EAB). The assumptions used in this worst case onsite accident conservatively included that
l 30 percent of the 141,400 curies of Kr-85 in the fuel would be released, that no Kr-85 would be absorbed in the pool water during the accident, and that the release would occur in a 2-hour period.
These conditions would result in a Kr-85 concentration in the FSB of 5.2 curies per cubic meter.
This would result in a total skin dose rate of 1085 rem per hour after 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; however, the FSB would be ventilated during any operations, and workers would evacuate in minutes before receiving any significant exposure to the Kr-85.
This i
analysis did not account for any halogen radionuclides because the biologically significant ones have decayed to a stable form since the 1978 shutdown.
The licensee estimated the maximum offsite whole body dose at the nearest EAB (475 meters) to be 0.016 rem and the worst skin dose to be 1.7 rem for the offsite release using the same assumptions, but taking no credit for retention in the FSB or for the ventilation system (thus assuming a ground level release over a 2-hour period).
In Section 15.7.5, " Spent Fuel Cask Drop Accidents," of the NRC " Standard Review Plan," (NUREG 0800), the NRC stated that plant siting and dose-mitigating engineered safety feature systems are acceptable if the whole body dose at the EAB is well within the exposure guideline values of 10 CFR Part 100. The NRC defined "well within" as 25 percent of the 10 CFR Part 100 values or 6 rem for whole body doses.
The estimated whole body dose at the nearest Dresden EAB in this worst case accident is less than 1 percent of the acceptable dose.
The U.S. Environmental Protection Agency Protective Action Guidelines are 1 rem whole body and 50 rem to skin; the 0.016 rem and 1.7 rem above are well within the guidelines.
Recognizing that this improbable worst case accident scenario would result in relatively small exposures, the licensee did not include TS limitations on heavy loads over the fuel or FSB ventilation controls.
However, the licensee included procedural control of FSB doors so that the doors will be kept closed during fuel handling. These controls ars discussed below.
The licensee is also writing procedural controls to use for heavy loads whenever fuel casks are handled.
By letter dated July 2, 1993, the licensee submitted a Dresden I certified fuel handler (CFH) training program for NRC review and approval.
The NRC will ensure that the training program provides for adequate and timely l
training for Unit 2 and 3 licensed operators or others that would be responsible for any movement of Dresden I spent fuel.
In December 1983, the licensee took the Dresden 1 fuel pool water cooling and cleanup system out of service for 2 years because of operational problems.
This did not adversely affect the fuel shielding or cooling because the newest discharged fuel had been in the pool for over 7 years and was generating very I
little decay heat.
However, the pool water remained stagnant for this 2-year period, which allowed micro-organisms to grow in the pool and prompted the concern for microbial influenced corrosion (MIC) of metallic pool structures.
I l
In December 1987, the licensee successfully treated the pool water with hydrogen peroxide to eradicate any such organisms. After the treatment, the licensee vacuumed the pool bottom to remove the resulting waste.
Periodic i
visual examinations of fuel assemblies and pool structures and monitorit.g of fuel pool corrosion coupons revealed no corrosive effects from either MIC or the long term peroxide treatment. A continuous purification filtration system maintains water purity. During late 1992, the licensee completely cleaned the fuel pool again using a mobile filtering system.
The proposed SAFSTOR TS specify quality limits for the fuel pool water with monthly sampling and analysis for specific conductivity, chlorides, and acidity (pH). Procedure DAP 1-3, " Administrative Control Program for Dresden 1," March 1989, implements fuel pool water quality limits that are more restrictive than the TS.
Procedure DCP 1020-1, " Chemistry Surveillance Schedule," requires a weekly sampling and analysis of the pool water.
Procedure DAP l-3 also requires the outside doors of the FSB to be closed during any fuel movement to ensure that normal building ventilation exhausts through the Dresden 1 chimney during times when fuel could become damaged.
l This provides for a high level, above ground, release that is filtered and l
monitored, thus minimizing any exposures.
l The staff concludes that the licensee meets the requirements of NRC General l
Design Criterion 61, " Fuel Storage and Handling and Radioactivity Control,"
I and has proposed suitable procedural controls to further mitigate any l
postulated accident. Therefore, the proposed fuel handling and storage TS are acceptable.
3.12. " Fire Protection Systems" In a letter of March 20, 1989, CECO requested that the Dresden 2 and 3 TS be amended in accordance with NRC Generic Letters 86-10, " Implementation of Fire Protection Requirements," and 88-12 " Removal of Fire Protection Requirements from Technical Specifications."
In these generic letters, the NRC advised that the NRC-approved fire protection plan could be moved from the TS to the FSAR or an equivalent enforceable document. On June 30, 1989, the staff issued License Amendments 106 and 101 for Dresden 2 and 3, allowing Ceco to move certain of the fire protection program TS into the Dresden Administrative Technical Requirements (DATR).
The proposed Dresden 1 TS and license condition 2.F, " Fire Protection," move provisions of the fire protection program to the DATR.
The Proposed TS and a license condition allow changes in the program without prior approval of the NRC only if the changes would not decrease the effectiveness of the program.
However, upon being implemented, such changes would still be subject to an NRC inspection to verify compliance with the change process.
1
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l The Dresden I fire protection program proposed for inclusion in the DATR is from the existing TS.
The DATR have no fire detection instrumentation requirements for Unit 1 because the detectors were to be located only in the following three areas:
core spray pump area, generator area, and the primary feed pump area.
These detectors are not now needed because this equipment is no longer safety-related at Dresden 1.
However, the other fire protection systems for the reactor building remain operational.
l The proposed Dresden 2 and 3 DATR program also includes the Dresden 1 diesel fire pump surveillance requirements because the Dresden 1 fire suppression water system is an integral part of the Dresden Station fire suppression system. The DATR also specifies wet pipe sprinklers for the Dresden 1 diesel fire pump area.
Table 3.1-2 of the DATR surveillance program includes the sprinkler system. The proposed surveillance requirements for the Dresden 1 fire pump diesel engine, including starting batteries and charger, remain i
unchanged.
l The licensee proposed to delete the requirement for the Dresden I carbon-l dioxide suppression system from the proposed DATR Fire Protection Program l
because the protected equipment, the Dresden 1 emergency diesel generator day tank area and the feedwater pump area, are no longer needed.
The proposed surveillance requirements for the Dresden 1 fire hose stations will be the same as for Dresden 2 and 3; however, seven hose stations in the l
Dresden 1 Turbine Building that are no longer in safety-related areas are not l
included in the proposed DATR program.
The DATR includes two safety-related i
stations which remain in the Turbine Building and one in the Crib House.
Although seven stations were removed from the DATR program, the equipment remains operational and the stations are included in the Dresden station fire hose surveillance program.
The proposed Dresden 1 TS do not include a requirement for penetration fire barriers because the protected safety-related equipment for reactor operation and shutdown is no longar needed.
Ceco completed modifications to consolidate necessary Dresden I controls and instrumentation into the control room for Dresden 2 and 3.
The modifications include a new fire and security wall between the control room for Dresden 2 l
and 3 and a new adjacent office area that was the former Dresden I control All penetrations in the control room for Dresden 2 and 3 are included room.
in the Units 2 and 3 fire barrier program. All existing Dresden 1 j
penetrations into the new office area are permanently sealed.
CECO continues i
to maintain the remaining Dresden I penetration fire barriers.
l As summarized above, the staff has reviewed the proposed SAFSTOR Fire Protection Program for Dresden I and concludes that the above revisions to the TS and the amendment to license condition 2.F. are acceptable.
5.0."Desion Features" l
This section of the TS retains the site description and the fuel storage design features. The licensee proposed to delete the descriptions of the i
reactor vessel, containment, and seismic design features.
Due to the defueled, nonoperating status of Dresden 1, these changes to Section S.0 of the TS are acceptable.
6.0." Administrative Controls" The licensee proposed changing the organization, review, investigation, and audit sections of the Dresden 1 TS to bring them into agreement with the same sections that have been previously approved in License Amendments 97 and 92 for Dresden 2 and 3.
The licensee also submitted proposed Dresden 2 and 3 TS amendments to move the Corporate and Dresden Station organization charts from the TS to the Ceco Quality Assurance Manual in accordance with the Commission recommendations in GL 88-06. The staff issued this change in License Amendments No. 105 and 100 for Dresden 2 and 3.
The proposed changes to the Unit 1 Administrative Controls TS would make them consistent with the TS for Dresden 2 and 3.
Table 6.1.1 specifies the minimum shift manning at the Dresden site in which R0 and SR0 refers to reactor operators and senior reactor operators that are licensed for operation of Units 2 and 3.
Since Unit 1 is in SAFSTOR and its reactor is always without fuel, no Unit I licensed operators are required for operation, surveillance or maintenance. The licensee proposed removing the organizational charts for all three units because the CECO organization is now described in the Ceco Quality Assurance Manual. The licensee also now uses uniform plant staff position titles and responsibilities.
The licensee proposed making the following changes to the Dresden I administrative controls to reflect the SAFSTOR mode of the facility:
a.
Include the ODCM and the Dresden PCP by reference in the Dresden 1 TS.
Most radioactive wastes will be processed through the Dresden 2 and 3 radioactive waste processing systems.
b.
Eliminate procedures for the following areas that no longer apply to Dresden 1:
1.
Refueling I
2.
Primary system leaks 3.
Abnormal reactor changes 4.
Safe shutdown Remove the TS action requirements on exceeding safety limits because i
c.
l the safety limits have been deleted.
d.
Eliminate the requirements for the following records because they no longer apply:
1.
Radioactive waste shipment records because all waste is processed through Dresden 2 and 3 2.
New fuel records 3.
Transient or operational cycling of certain equipment 4.
Inservice inspections 5.
Environmental qualification of equipment
Eliminate the reporting requirements for the startup report, monthly e.
operating report, and all special reports except for radioactive source leak testing.
The licensee proposed changing the Dresden 1 TS format to be compatible with the Dresden 2 and 3 formats.
The staff has reviewed the proposed Dresden 1 Administrative Control TS and concludes that they are acceptable and compatible with the existing Dresden 2 and 3 TS.
Due to the defueled, nonoperating condition of Dresden 1, those sections that were deleted from the operational TS are no longer required to maintain it in a SAFSTOR condition.
2.3 Conclusion on Proposed TS Chances The requested technical specifications changes in the licensee November 1, 1989, letter are acceptable.
2.4 Evaluation of Decommissionino Plan The Decommissioning Plan (Plan) would place Dresden 1 in the SAFSTOR mode for up to 36 years, or until Dresden 2 and 3 are decommissioned and dismantled.
At the end of the SAFSTOR period, Dresden I will be decommissioned by l
i decontaminating and dismantling. The major objectives of the Plan are to l
(1) maintain Dresden I systems and structures needed to support the operation i
of Dresden 2 and 3, (2) secure all nonessential Dresden I systems and structures to mitigate deterioration and ensure that the physical integrity of l
the contained system will not be lost, (3) dispose of radioactive and hazardous wastes remaining on site in preparation for the SAFSTOR dormancy period, and (4) store spent fuel on site until a Federal repository is available for permanent disposal. Other~ elements of the Plan would contribute to personnel safety and ease of access to Dresden 1 areas.
In its October 30, 1992 letter, the licensee stated that it does not plan to make major structural or equipment changes that would require the submittal of a dismantlement plan. While maintaining the plant in SAFSTOR, before the plant is dismantled, the licensee may make changes in the Decommissioning Plan and perform those disassembly operations as permitted by current Commission guidance and the 10 CFR 50.59 type requirements stated in the enclosed order.
The licensee shall, pursuant to 10 CFR 50.82(d), submit a detailed dismantlement plan in the future for NRC approval before beginning final dismantling activities.
The NRC will consider a request to terminate License No. DPR-2 after Ceco reduces residual radioactivity to levels acceptable for unrestricted access and conducts detailed surveys that are confirmed by the i
NRC through independent surveys.
As described above, the staff reviewed the Dresden 1 Decommissioning Plan and associated TS and found them acceptable.
4 l.
2.5 Deletion of License Conditions That are No Loncer Aoplicable 3
License DPR-2 contains the following license conditions and sections that no longer apply with Dresden I permanently shut down and defueled:
Section 2.C.(3).
This condition requires certain modifications to be completed before any Dresden I restart. Since Dresden I will not restart and other license conditions prohibit restart, this condition is not needed and may be deleted.
Section 2.C.(4).
This condition provides a temporary exemption from certain requirements for the emergency core cooling system.
The exemption expired on December 31, 1978, and may be deleted.
Section 2.C.(5).
This condition prohibited Dresden I from being operated unless certain modifications were completed and operating conditions met.
Since Dresden I will not restart, it may be deleted.
Section 2.C.(6).
This requirement for backup diesel generator surveillance as a condition for reactor power operations does not apply to Dresden 1 in its permanently shut down status.
Section 2.G.
This condition relates to the chemical decontamination of the Dresden 1 primary coolant system. The licensee completed this decontamination, solidified the resulting waste, and shipped it to a low-level waste burial site. Thus this condition may be deleted-3.
FINANCIAL CONSIDERATIONS In its February 7, 1992, submittal, as revised October 30, 1992, Ceco listed the factors used in estimating the cost of decommissioning.
The list includes labor, materials, equipment, specialty contractors, and license fees.
Ceco estimated the total cost of decommissioning to be $160 million for Dresden 1 and 5177 million each for Dresden 2 and 3 in 1991 dollars.
CECO expects to have accumulated the 5160 million in the external trust fund by 2007.
Ceco is funding the cost of decommissioning Dresden I through annual contributions of
$11 million per year to the trust fund and as of September 30, 1992, had
$37.2 million in this fund. A recent revision to 10 CFR 50.82(a)
(57 FR 30383, July 9, 1992) states:
"For a facility which permanently ceased operation before the expiration of its operating license, the collection period for any shortfall of funds will be determined, upon application by the licensee, on a case-by-case basis taking into account the specific financial situation of each licensee."
This revised rule had several criteria upon which the staff could base its i
l evaluation of the ability of a licensee to provide funding assurance into the 1
SAFSTOR period. These criteria include:
(1) licensee bond ratings; (2) licensee financial history, including its past funding of reactor safety 1
i
expenditures; (3) State public utility commission (PUC) decisions and commitments; (4) the number of other generating plants that a licensee owns; and (5) other factors that the licensee demonstrates as being' relevant.
b The most recent Ceco bond rating from Moody Investors Services, one of the major bond rating services, is Baa2.
(See Moody Public Utility News Reports, March 30, 1993.) This rating is an investment-grade rating, although not as strong as an "A" rating necessary for the NRC to automatically approve funding into SAFSTOR. Nevertheless, it provides investors some degree of confidence that their bond investments will be repaid at bond maturity and is thus a good indicator of investment community projections of future solvency of a company.
The Ceco financial history has been positive, although Ceco has suffered some financial distress resulting from PVC disallowances.of nuclear plant capital expenses.
In 1992, Ceco had over $6.026 billion in operating revenues and realized $552.3 million in net income.
Value Line (April 16, 1993) projects net income to grow to $590 million in 1993 and 5630 million in 1994.
The Ceco annual decommissioning payments of 511 million for Dresden 1 are less than 2 percent of recent and projected net income. CECO should thus have little difficulty in continuing to make its decommissioning payments for Dresden 1.
The Illinois Commerce Commission allows Ceco to collect decommissioning funds from ratepayers. The NRC has no information indicating that this policy will change.
Ceco owns all or part of 15 nuclear units, including Dresden 1.
These nuclear units comprise about 83 percent of its generating capacity. Thus, Ceco is a large utility with an extensive asset base. Although Ceco could be adversely affected if a serious problem were to arise at all nuclear power plants, such a situation would be highly unlikely.
Because Ceco has an extensive asset base, serious problems leading to shutdown of any one of its nuclear plants would be unlikely to affect finances to the extent of jeopardizing the funding of Dresden 1 decommissioning.
Based on the above considerations, the staff has concluded that the CECO funding plan provides reasonable assurance of adequate funds for ducommissioning Dresden 1.
This conclusion is also based on CECO commitments to follow its funding plan as described above and to adjust its contributions j
to its external trust fund as decommissioning cost estimates change.
4.
STATE CONSULTATION In accordance with the Commission regulations, the staff notified the Illinois State official of the proposed issuance of the amendment. The State official had no comments.
5.
ENVIRONMENTAL CONSIDERATION This action involves issuing an order and a license amendment that authorizes Ceco to maintain Dresden 1 in safe storage (SAFSTOR) until after Dresden 2 and 3 are permanently shut down, at which time all three units would be
4 I
I
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dismantled. The amendment renews the license, deletes obsolete license conditions, and changes the TS requirements to reflect the SAFSTOR status of' Dresden 1.
The NRC staff completed an Environmental Assessment and published
(
a Notice of Issuance of Environmental Assessment and Finding of No Significant Impact in the Federal Reaister. Upon completing the_ Environmental Assessment, the Commission concluded that the proposed order and amendment will not significantly affect the quality of the human enviror, ment.
6.
CONCLUSION
[
The Commission concluded that (1) there is reasonable assurance that the-health and safety of the public will not be endangered by decommissioning Dresden I in the proposed manner, (2) such activities will be conducted in compliance with the Commission regulations, and (3)' the issuance of the order i
I and amendment will not be inimical to the common defense and security or -to the health and safety of the public.
Principle contributors:
K. R. Ridgway t
P. B. Erickson l
M. B. Fairtile J. L..Minns l
R. S. Wood
?
Date:
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5 5
a,z..,.
4,
/
UNITED STATES
!" 3g [g NUCLEAR REGULATORY COMMISSION 3
r.. g WASHINGTON, D C. 20555 he
....+
ENVIRONMENTAL ASSESSMENT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING ORDER AUTHORIZING FACILITY DECOMMISSIONING AND AMENDMENT OF tICENSE NO. DPR-2 COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR POWER STATION. UNIT 1 DOCKET NO.50-010 1.
SUMMARf 0F PROPOSED ACTION The U.S. Nuclear Regulatory Commission (the Commission, NRC) is considering issuing an order and an amendment to Commonwealth Edison Company (Ceco or the licensee), that would authorize decommissioning of the Dresden Nuclear Power Station, Unit 1 (Dresden 1). On October 31, 1978, Commonwealth Edison Company (CECO or the licensee) shut down Dresden I to backfit it with equipment to meet new Federal regulations and to perform chemical decontamination of major piping systems. While Dresden I was out of service, the NRC imposed new requirements after the March 1979 accident at the Three Mile Island Nuclear Station, Unit 2.
Ceco later concluded that the age and small capacity of Dresden 1 did not warrant the investment needed to bring it into compliance and therefore elected to seek decommissioning.
On January 7,1986, CECO submitted its proposed Decommissioning Plan (the Plan) and license amendment as revised December 22, 1987; April 29, September 2, and November 21, 1988; March 27, April 10, May 16, and November 1, 1989; June 7, 1991; February 7, and October 30, 1992; and June 8, and July 2, 1993. The Plan and associated amendment provide for long term storage (SAFSTOR) of Dresden 1 followed by its dismantlement.
When the NRC issues the order approving the Plan, it would also issue an amendment to License No. DPR-2, that would revise the technical specifications (TS) and renew the license to April 10, 2029, consistent with the Plan.
On June 27, 1989, the NRC published a Notice of Consideration of Issuance of Amendment to License and Opportunity for Hearing on the proposed license amendment in the Feder,al Reaister (54 FR 27081). The NRC did not receive public comments or a request for hearing regarding this notice.
Dresden 1, a 700 MW thermal, boiling water reactor (BWR) is located near the confluence of the Kankakee and Des Plaines Rivers in Grundy County, near Morris, Illinois. The site is about 50 miles southwest of Chicago, Illinois, and is shared with Dresden Units 2 and 3, both of which are operating nuclear plants.
CECO removed all spent fuel assemblies from the reactor and placed them in the Dresden I spent fuel storage pool. The spent fuel will remain on site until a Federal repository is available to receive it.
l l,
1 The NRC clarified environmental review requirements for decommissioning
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licensed nuclear facilities when it amended the regulations on June 27, 1988, (53 FR 24018), " General Requirements for Decommissioning Nuclear Facilities."
In so doing, the NRC eliminated the mandatory requirement for an Environmental Impact Statement (EIS) after considering the effects of decommissioning in its Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (FGEIS), NUREG-0586. The FGEIS addresses the decommissioning of commercial pressurized water reactors (PWRs), and boiling water reactors (BWRs), and various other nuclear facilities and applies to Dresden 1, a BWR.
t In Section 51.95(b) of Title 10 of the Code of Federal Reculations (10 CFR 51.95) the NRC requires environmental assessments (EAs) for power reactor decommissioning.
In the statement of considerations for the amendment to the decommissioning regulations (53 FR 24039), the Commission stated that:
l If the impacts for a particular plant are significantly different from those studied generically because of site-specific considerations, the environmental assessment would discover those and lay the foundation for the preparation of an EIS.
If the effects for a particular plant are not significantly different, a Finding of No Significant Impact would be prepared.
Therefore, before approving a request to decommission Dresden 1, the NRC must conduct a site-specific EA to determine whether or not the effects differ significantly from those discussed in the FGEIS and whether or not any such differences have significant impact.
2.
PURPOSE OF AND NEED FOR PROPOSED ACTION l
The purpose of decommissioning as proposed by the licensee is to (1) retain Dresden 1 in a SAFSTOR status until after Dresden 2 and 3 are permanently shut down and (2) continue maintaining the Dresden I spent fuel pool until after spent fuel is shipped to a Federal repository.
Since Dresden 1 is permanently shut down, Ceco is required by 10 CFR 50.82 to submit a proposed Decommissioning Plan for the NRC to review for app oval.
In l
granting the action proposed by Ceco, the NRC would allow Ceco to place the i
Dresden 1 facility in a SAFSTOR status and would renew the license until I
April 10, 2029.
By that time a significant amount of radioactive decay will l
have occurred which will reduce low-level radioactive waste volume and l
possible radiation exposure to both workers and the public.
3.
ALTERNATIVES INCLUDING PROPOSED ACTION In the FGEIS, the NRC specified three decommissioning alternatives for reactor facilities: DECON, ENTOMB, and SAFSTOR.
Ceco chose the SAFSTOR alternative i
for Dresden 1.
These alternatives, and the "no action" alternative are compared in Table 1 and discussed below.
i l
l 1
.-=
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i
' I 3.1 DECON - Prompt Dismantlement t
The DECON option is to promptly remove equipment, structures, and other portions of the facility containing radioactive contaminants, or to decontaminate them to a level that permits the facility to be released for i
unrestricted access.
Ceco did not select the DECON option for Dresden 1 because the safe operation of Dresden 2 and'3 depends on the continued i
operation of numerous systems in buildings around the Dresden I containment building. Many of these buildings and systems would have to be removed to decontaminate and dismantle Dresden 1.
These buildings and systems cannot be removed without disabling support operations for other units.
If these buildings and systems were dismantled, similar systems would have to be reconstructed to provide the support required to operate Dresden 2 and 3.
Another disadvantage of DECON is its higher occupational radiation dose as compared to the other alternatives.
j 3.2 ENTOMB - Entombment i
l The ENTOMB option is to encase the radioactive contaminants in a structurally I
long-lived material, such as concrete. The entombed structure must be appropriately maintained, and continued surveillance is required until the' radioactivity is removed from the site or decays to a level that permits unrestricted use of the property.
Waiting for decay is impractical at-most power reactors because long-lived radionuclides such as nickel-59* nickel-63 and niobium-94 are present in reactor components near the core.
Ceco has not selected the ENTOMB option for Dresden 1.
Ceco determined that i
sufficient radioactivity from these long-lived radionuclides will be present in reactor structures to preclude the release of Dresden I for unrestricted use even after 100 years of decay.
Furthermore, the congestion from the t
entombment construction activities performed while Dresden. 2 and 3 were operating could adversely affect the safe operation of these units.
i An entombment structure would make removal of that residual radioactivity more difficult during final dismantlement and would not be compatible with the spent fuel remaining on site.
3.3 SAFSTOR - Deferred Dismantlement SAFSTOR is the alternative in which a facility is placed and maintained in a condition that allows it to be safely stored and subsequently decontaminated to levels that permit release of the property to unrestricted use.
i The facility may be left intact, except that all fuel must be removed from the reactor core, and radioactive fluids and wastes must be removed from the site.
Ceco selected the SAFSTOR alternative because the spent fuel must remain on site in the spent fuel pool until a Federal-repository is available to receive it.
Therefore, the spent. fuel pool and its associated systems could not be dismantled in the near future.
By delaying the dismantlement, the licensee would significantly reduce the radiation exposure to workers.
1
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O CECO stated that Dresden 1 can be safely and inexpensively maintained in dormancy on the shared site with Dresden Units 2 and 3 and that selecting SAFSTOR for decommissioning Dresden I will yield no significant environmental effects.
j 3.4 No Action The licensee must decommission a radioactive facility to restore it to a condition that offers reasonable assurance that the decommissioned facility does not adversely affect public health and safety. Some action is required to ensure that at the end of its life the risk from a facility is within acceptable bounds. Therefore, NRC regulations do not permit the licensee of any type of nuclear facility at any level of contamination to take no action; that is, to simply abandon or leave the facility after ceasing operation (FGEIS Section 2.4.1).
4.
AFFECTED ENVIRONMENT In a letter of January 10, 1983, about the full term operating license applications for Dresden 2 and 3, Ceco submitted 1980 population data for the Dresden site. The data, from the 1980 census, showed a population of 10,415 within a 5-mile radius of the Dresden site and a population of 77,956 in the nearest population center of Joliet, Illinois,15 miles northeast of the site.
The population near Dresden I has not changed significantly since 1980 and remains largely rural. SAFSTOR activities at Dresden 1 are very local and passive and will not significantly affect that population as discussed below.
5.
ENVIRONMENTAL IMPACT OF PROPOSED ACTION The staff evaluated the proposed Decommissioning Plan, the renewal of License No. DPR-2, and the amendment of the Dresden 1 TS to meet the environmental requirements in 10 CFR 51.45.
5.1 Soil Contamination In 1975, soil at Dresden I was contaminated with radioactivity from a leak at the Dresden I waste solidification building. Most of the contaminated soil was removed and sent to an authorized waste burial site. Today, about 30 millicuries of cesium-137 and 10 millicuries of cobalt-60 from the 1975 event remain in 300 cubic yards of soil that is located east of the Unit I rad-waste building.
On January 21, 1988, Ceco applied to the State of Illinois for authorization to dispose of other, less contaminated soil at the Dresden site since Illinois is an agreement state and this falls within its authority. This request to the state involves 2200 cubic yards of soil contaminated with 2.6 millicuries of cesium 137 and 4.6 mil 11 curies of cobalt 60. On February 14, 1989, CECO 1
provided additional information to the State of Illinois in response to its questions of July 8,1988. To date, the State of Illinois has taken no further action with respect to the CECO application.
In its letter of October 30, 1992, to the NRC, Ceco committed to remove all soil from the
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Dresden site that contain radionuclides at levels that exceed the NRC decommissioning release criteria and to transfer that soil to a licensed radioactive waste disposal facility during the final decommissioning of all three units by the license renewal date of April 10, 2029.
10 CFR 50.82(f)(2) requires that radiation surveys and documentation demonstrate that the facility and sit- 'e suitable for unrestricted access before the facility license is terminated. This requirement will be imposed in addition to any requirements that may be imposed by the State of Illinois with respect to the Ceco application to the state.
The licensee is monitoring groundwater in three wells located in the southeast portion of the Dresden site for any migration of radioactive material.
In the environmental report (ER) Ceco stated that it will continue conducting an environmental surveillance program during the SAFSTOR period to monitor any releases of radioactivity to the environment.
This program will be a part of the operational monitoring systems of Units 2 and 3 and will be capable of adequately identifying radioactive releases from Unit 1.
In turn, this would prompt the licensee to take remedial action for any such release. The staff finds the commitments and monitoring to be acceptable.
5.2 Status of Federal, State, and Local Environmental Permits The licensee obtained the appropriate Federal, State, and local environmental permits for the Dresden site. Most of these permits pertain to Dresden 2 and 3, which are operating plants.
Dresden I has no active construction or other work that could significantly affect the environment or require a separate environmental permit.
Ceco has, however, applied to the State of Illinois with respect to Dresden I soil contamination as discussed in Section 5.1 above.
5.3 Local Short-Term Uses Verses Long-Term Productivity Dresden I shares many systems and buildings that are needed for continued operation of Dresden 2 and 3.
CECO intends to use these systems, buildings, and the site for generating power until the other units are permanently shut down.
During the Dresden 1 SAFSTOR period, the licensee plans to use the Dresden site only to generate electrical power. No advantage would be gained by making only part of the site available earlier. Therefore, local short-term use would not conflict with the long-term productivity of the site.
5.4 Irreversible and Irretrievable Commitments of Resources The proposed SAFSTOR period of Dresden I followed by dismantling would not involve any change in commitment of resources other than the Dresden I land area, which is already committed to supporting power generation at the site regardless of the Dresden I status. The amount of land used for Dresden 1 will remain the same.
Ceco could ultimately return the land to unrestricted use after decontamination or dismantling all structures.
When compared to DECON (prompt dismantlement), a delay in dismantling the Dresden 1 facility would allow radioactive decay to reduce the volume of radioactive waste for
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disposal at the end of the SAFSTOR period. The smaller volume of radioactive waste would need less burial space at a low-level waste burial site and would require less resources for processing and shipping.
l 5.5 Potential Exposure to Workers Since shutting down Dresden 1 in October 1978, Ceco has maintained Dresden 1 using a Radiation Protection Program (RPP) (TS Section 6.2.B) that is consistent with 10 CFR Part 20, " Standards for Protection Against Radiation."
The proposed TS retain this RPP which has been previously approved by the NRC; therefore, by issuing the order and amendment, the NRC would enable CECO to maintain the RPP in effect.
I NRC staff calculations show that delaying the final decontamination cnd dismantlement of Dresden I will significantly lower the gamma radiation levels from the activated steel components (the gamma radiation is primarily from cobalt-60, which has a 5.2-year half-life). This reduction in radioactivity will lower exposure levels in the plant and reduce the volume of waste and the radiation doses to workers. Ceco will perform all work with radioactive components in accordance with radiation work permits issued for each activity.
5.6 Radioactive Waste The ER includes a discussion of the chemical decontamination of the primary l
system of Dresden 1.
Ceco solidified the resultant spent radioactive resins and sludge materials and shipped them offsite as solid radioactive waste.
This program enabled CECO to significantly reduce site radioactivity, reduce l
the risk to plant workers, and reduce the opportunity for offsite radionuclide migration.
5.7 Nonradiological Issues No activities are anticipated at Dresden 1 as a result of NRC approval of the Dresden 1 SAFSTOR Decommissioning Plan that would involve a significant change l
in air quality, asbestos removal, exhaust emissions, chemical or biocide discharge, sanitary discharge, or noise.
Also, since Dresden I will continue to be maintained and monitored with no significant change in activities at the site, the NRC approval will have no significant impact on endangered species or the socioeconomics of the area. Upon reviewing the Decommissioning Plan and ER, the staff concluded that the licensee has selected the decommissioning alternative that minimizes environmental hazards and does not introduce any adverse effects.
l 5.8 Accident Analysis The ER includes an evaluation of the effects of postulated accidents and natural phenomena on the Dresden I stored fuel during the SAFSTOR dormant period. The accidents and phenomena included the loss of pool water, seismic events, site flooding and fires. The design basis hazard used by Ceco was a l
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loss of pool water combined with a complete rupture of all fuel rods.
The staff evaluated this ;ccident in the enclosed Safety Evaluation and determined that the analysis provided by the licensee was conservative and that postulated exposures from radioactive releases at the exclusion area boundary would be less than the U.S. Environmental Protection Agency protective action guidelines.
CECO implemented procedures to lessen the effects of a fuel handling accident, i
an event of less crequence than the design basis hazard but of higher probability.
These procedures require that the Fuel Storage Building doors remain closed during fuel band!ing and that fuel movement or loads carried over the fuel be controlled.
By keeping the doors closed, any radioactive releases caused by a fuel handling accident would result in a filtered and monitored stack release rather than an uncontrolled ground level release.
We find that the licensee has provided acceptable accident analyses and proposed procedures.
5.9 Radiological Environmental Monitoring Ceco performs radiological monitoring for airborne and liquid effluents in accordance with the Dresden Offsite Dose Calculations Manual (ODCH), which applies to all three units at the site.
CECO submits to the NRC a semi-annual radioactive release report for all three units.
The staff reviewed the i
Dresden radiological env'ironmental monitoring program and documented its findings in the related Safety Evaluation (Pages 4-6).
The staff concludes that the Dresden I radiological environmental monitoring program is acceptable.
1 5.10 Unavoidable Impacts During the SAFSTOR period, Ceco will maintain a few acres for Dresden I as a restricted area. Since this area will remain part of an operating reactor site, no other use is reasonable for the Dresden I area until after the other two units are shut down and all three units are decommissioned.
6.
AGENCIES AND PERSONS CONSULTED The NRC staff reviewed the Ceco request and consulted with representatives from the State of Illinois.
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FINDING OF NO SIGNIFICANT IMPACT Upon completing the environmental assessment, the Commission concluded that the environmental impacts of decommissioning Dresden I as proposed are adequately bounded by the environmental impacts of decommissioning light-water reactors as analyzed in the FGEIS and that the proposed action will not have a significant impact on the quality of the human environment. Accordingly, the Commission will not prepare an environmental impact statement for this proposed action.
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Attachment:
Table I Date:
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TABLE 1 Comparison of Dresden 1 Environmental Assessment Alternatives Alternative Advantages Disadvantages SAFSTOR Lower waste volume & curies; Requires surveillance & access lower radiation exposure &
control; site not available for dose; least commitment of unrestricted access; residual land to radioactive waste radioactivity must be removed l
disposal; least impact on at end of SAFSTOR period.
Dresden 2 and 3 operations.
ENTOMB Lower waste volume & curies; Long-lived radionuclides (Ni-63 lower radiation exposure to
& Nb-94) must be removed in the workers; entombment structure future; site not available controls access to residual for unrestricted access; more radioactivity.
difficult to remove residual radioactivity at the end of ENTOMB period because of the entombed structure.
DECON Fastest release of land Higher waste curies, waste for unrestricted use; no volume, and radiation dose; requirement for continued not compatible with spent surveillance or access fuel remaining on site; control; prompt removal not viable because of of radioactivity; Unit I significant effects on workers more familiar Dresden 2 and 3; would with l'ait I construction; require new systems to Unit i equipment in newer be installed at Dresden to and better condition.
replace dismantled systems.
NO ACTION None Would not ensure that risk to the public from the facility will be within acceptable bounds.
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7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION-COMMONWEALTH EDISON COMPANY DRESDEN NUCLEAR POWER STATION. UNIT 1 DOCKET NO.50-010 NOTICE OF ISSUANCE OF ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT The U.S. Nuclear Regulatory Commission (the Commission) is considering issuing an order authorizing the decommissioning of the Dresden Nuclear Power Station, Unit 1 (Dresden 1) that is licensed to the Commonwealth Edison Company (Ceco).
The proposed Decommissioning Plan involves safe storage (SAFSTOR) of Dresden 1 until after Dresden 2 and 3 are permanently shut down, at which time all three units would be decontaminated and dismantled.
The licensee also requested that the Dresden 1 license (DPR-2) be renewed to April 10, 2029 to be consistent with the proposed SAFSTOR period.
Descriotion of Proposed Action Dresden I has been shut down since Octc er 31, 1978, and all spent fuel has been removed from the reactor and transferred to the Dresden I spent fuel storage pool. Approval of the Decommissioning Plan will allow Ceco to retain Dresden 1 in a SAFSTOR status in accordance with an approved Decommissioning Pl an.
Placing Dresden 1 in SAFSTOR will allow continued use of the site for electric power production by Dresden 2 and 3 until final shutdown and decommissioning (decontamination / dismantlement) of all three units.
Findino of No Sionificant impact The staff has reviewed the proposed decommissioning against the requirements in 10 CFR Part 51. Upon conducting an Environmental Assessment, the staff concluded that no signifil: ant environmental impacts are associated with the proposed SAFSTOR decommissioning and that the proposed decommissioning will not significantly affect the quality of the human environment. Therefore, the Commission has determined, pursuant to 10 CFR 51.31, not to prepare an environmental impact statement for the proposed decommissi6ning of Dresden 1.
The following documents contain further details on this action:
(1) the application from the licensee of January 7,1986, as revised December 22, 1987; April 29, September 2, and November 21, 1988; March 27, April 10, May 16, and November 1, 1989; June 7, 1991; February 7, and October 30, 1992; and June 8, and July 2, 1993; (2) the Commission's related Safety Evaluation; and (3) the Commission's Environmental Assessment and finding of No Significant Impact.
Dated at Rockville, Maryland, this
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FOR THE NUCLEAR REGULATORY COMMISSION Seymour H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Operating Reactor Support Office of Nuclear Reactor Regulation i
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