ML20078S023

Proposed Tech Specs Deleting Ets,Per Amend 66.Safety Evaluation Encl

ML20078S023
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Site:	Beaver Valley
Issue date:	11/03/1983
From:	DUQUESNE LIGHT CO.
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ATTACHMENT A Remove pages:

All pages of Appendix B Insert pages:

iio pages 8311150363 831103 PDR ADOCK 05000334 P-PDR

e ATTACHMENT B SAFETY EVALUATION Proposed Change Request No. 36, Revision 4 requests that Appendix B of the Beaver Valley Power Station, Unit No.1 Technical Specifications be deleted.

Description and Purpose of Change The Environmental Technical Specifications - Appendix B, is to be amended by deleting those radiological sections that have been incorporated into' Appendix A in accordance with Amendment No. 66, the Radiological Effluent Technical Specifications (RETS). This change is required to pennit full implementation of the RETS by January 1,1984.

The Nonradiological Surveillance sections of Appendix B can also be deleted, based on the data stated in our annual Environmental Reports, which conclude that operation of the cooling tower has not adversely affected the environment. The Definition and Administrative Controls sections can then be deleted, since all of the environmental surveillance programs of Appendix B have been either incorporated into the RETS or deleted.

Basis 1.

Is the probability of an occurrence or the consequence of an accident or malfunction of equipment important to safety as previously analyzed in the Updated Final Safety Analysis Report (UFSAR) increased? No.

Reason:

The RETS incorporate the applicable radiological sections of Appendix B into Appendix A and provides for surveillance of effluent monitoring instrumentation, releases, waste handling systems and offsite monitoring, therefore, a reduction in the total dose to the public from gaseous and liquid releases should result. This then will decrease the probability of an occurrence or consequences of an accident or malfunction of equipment as described in the UFSAR. The Radioactive Waste System is described in Section 11.2, Radiation Protection Shielding and Monitoring is described in Section 11.3, the Environmental Radiological Monitoring Program is described in Section 2.8, Measuring and Reporting of Effluents from Nuclear Power Plants is described in Section 1.3.3.21, Accidental Release of Waste Liquid is described in Section 14.2.2 and Accidental Release of Waste Cases is described in Section 14.2.3.

Tne 1980 Nonradiological Environmental Monitoring Program is described in Section 2.8.3.1 and states that no evidence of adverse environmental impact to the Ohio River or the surrounding vegetation was found. This is consistent with the conclusions stated in the Annual Environmental Reports submitted to the NRC each year since the plant began operation in 1976.

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Attachment B Safety Evaluation Page 2 2.

Is the possibility for an accident or malfunction of a different type than previously analyzed in the UFSAR created? No.

The increased surveillance provided by the incorporation Reason:

of the RETS into Appendix A serves to further control the quantity and activity of r&dioactive releases to the envir-onment. Based on the data that was collected and submitted in the Annual Environmental Reports and Section 2.8.3.1 of the UFSAR, the Terrestrial Ecological Survey and the Soil Chemistry Program ar no longer required, since the data consistently demonstrates no adverse environmental impact.

3.

Is the margin of safety, as defined in the basis for any Technical Specification reduced? No.

The RETS should limit releases below the limits previously Reason:

established by Appendix B.

The systems or components described in the RETS will not be physically changed or the function al tered.

4. -

Based on the above, is an unreviewed safety question involved? No.

In accordance with 10 CFR 50.59, an unreviewed safety question Reason:

is not involved since the RETS have been incorporated into Appendix A and provide for enhanced surveillance monitoring of releases to the environment.

Conclusion Two. surveillance requirements not required to be deleted by imple-mentation of the RETS are (1) Terrestrial Ecological Survey conducted every other year to assess-the impact of the cooling tower drift on the terrestrial vegetation and (2) Soil Chemistry Program conducted every five years to assess possible changes in soil pH and conductivity from the operation of the cooling tower. A review of the Terrestrial Ecological Surveys conducted during operational years 1976, 1978, 1980 and 1982 ~ shows no adverse impact on the environment. The data was collected and submitted to the NRC in Annual Environmental Reports and provides adequate justification for deleting the Terrestrial Ecological Survey requirement. The Soil Chemistry Program conducted during opera-tional years 1976 and 1978 shows no adverse impact on the environment.

In 1978, the sampling frequency requirement was changed from every other year to every five years (summer and winter), therefore, the next scheduled sampling requiremant is June and December 1983. However, based on the results of the data collected and submitted to the NRC in previous Annual Environmental Reports and on the results of the samples collected in June 1983, it is requested that the December sampling requirement be waived, based on the fact that sufficient data exists to justify deleting the Soil Chemistry Program requirement.

v Attachment B Safety Evaluation Page 3 The Definition and Administrative Controls sections will no longer be applicable since all of the applicable environmental surveillance programs of Appendix B will have either been moved to Appendix A via the RETS or deleted.

By replacing the radiological sections of Appendix B with the RETS and deleting the above sections Appendix B will be retired.

The proposed change, to delete Appendix B, will not remove or relax any existing requirement related to the probability or consequences of accidents previously considered and do not involve a significant i

hazards consideration..The proposed change will not remove or relax any existing requirenent needed to provide reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner. We have determined that this change will not authorize a significant change in the types or a significant increase in the amounts of effluents or in the authorized power level and will si Therefore, pursuant not result in any(4)gnificant environmental impact.no environmental impa to 10 CFR 50.5(d) tion or environnental impact appraisal is required.

The OSC and ORC have reviewed thi:: proposed change, and based on the above safety evaluation, it is concluded there is reasonable assur-ance that-the public health and safety will not be endangered by operation in the prcposed manner.

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ATTACHMENT C DUQUESNE LIGHT COMPANY Nuclear Safety and Licensing Department SOIL CHEMISTRY (ETS Reference 3.1.3.10)

Objective Conductivity and pH of soils are studied as part of a program to monitor the impact of cooling tower drift on the terrestrial ecosystem.

Methods 1.

pH Soil samples were collected June, 1983 and analyzed for pH and soluble concentration.

Statistical analyses of pd and soluble salt concentrations indicate that a minimum of ten (10) samples are required from each soil series to detect statistically significant changes at the 0.05 level of probability. Fifteen (15) samples are obtained per sampling point and the arithmetic mean and standard deviation are calculated and compared to prior sampling periods.

Ten (10) permanent sampling locations (See Figure 7-2) representing points of projected low and high salt deposition from cooling tower drift have been established. Using a compass and soil test auger, soil samples are collected in summer and winter at the ten (10) locations.

Three (3) equidistant radii (e.g., O*, 120*, 240* azimuth) are established about the pin marking each permanent sampling point Samples are collected to a depth of six inches at 2, 4, 6, 8, and 10 feet along each radius for a total of fifteen (15) samples per permanent sampling point.

Samples are prepared by transferring each soil sample to a plate, and distributing the sample uniformly over the plate. The sample is dried' overnight at 10-15'C above room temperature.

Using the hand grinder, the soil samples are crushed until a major portion will pass a 10-mesh (U.S. No.10) sieve.

The crushed soil samples are then placed in jars and mixed for five (5) minutes on a mixing wheel. About 20 grams per sample are prepared for chemical analysis. A pH meter and electrodes and thermometer are used to determine the pH.

_1_

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DUQUESNE LIGHT COMPANY a-Nuclear Safety and Licensing Department SOIL CHEMISTRY (ETS Reference 3.1.3.10) (continued)

Methods (continued) 2.

Specific Conductance (Soluble Salt Concentration)

Specific conductance is determined by using a conductivity bridge, a dip-type conductivity cell, and a thermometer.

When the conductivity value has been determined, the electrical conductivity is converted to approximate salt concentrations using the following formula:

Salt concentration (mg per liter) equals 640 x Electrical conductivity (millimhos per em)

The arithmetic mean and standard ~ deviation of pH and conductivity values are calculated for each of the ten-(10) permanent sampling points.

way analysis of variance is used to compare the values of A one this sampling period with values obtained for previous sampling period.

Results June 1983:

No investigative levels for soil pH and/or conductivity were reached in this survey. The mean pH of the soils from the ten (10) sampling points stipulated in this program did, however, vary (See Table VII-2).

The highest mean pH occurred at sampling point 1-1 (6.76) and the lowest occurred at - sampling point 3-2 (4.11).

Of the the 150 soil samples analyzed, the range of pH values was from 3.85 to 7.15.

The mean pH of all the samples was 4.83.

Specific Conductence values varied from a low mean value of 0.11 mmhos/cm at sampling points 2-2 and 4-1 to a high mean value of 0.15 mmho/cm

~at.

sampling point 1-1 (See Table VII-3). The lowest conductivity value of the 150 samples was 0.076 at sampling point 2-2.

l The highest individual conductivity value was 0.18 recorded at-sampling points 1-1, 1-2, 4-2, and 5-1.

Average of the mean specific conductance levels was 0.130 mmhos/cm.

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DUQUESNE LIGHT COMPANY Nuclear ~ Safety and Licensing Department Table VII-2 Summary of pH Levels 6/18/83 Sample Mean Standard Standard Range Investigation 2 Point pH Deviation Error Levels High.

LW High. LsW.

1-1 6.76 0.13 0.034 7.15 6.62 7.4 6.0 1-2 6.44 0.16 0.041 6.73 6.22 7.4 6.0 2-1 4.58 0.11 0.028 4.95 4.28 4.7 3.9 2-2 4.22 0.19 0.049 4.46 3.87 4.5 3.6 3-1 4.69 0.13 0.034 4.82 4.56 4.8 4.0 a

3-2 4.11 0.10 0.026 4.31 3.85 4.6 3.7 4-1 4.36 0.12 0.031 4.52 3.99 4.5 3.7 4 4.31 0.20 0.052 4.61 3.91 4.7 3.8 5-1 4.55 0.17 0.044 4.87 4.11 4.9 4.0 5-2 4.26 0.08 0.021 4.38 4.12 4.4 3.6 e

the arithmetic averages of the fifteen soil samples 1.

Mean values are obtained per sampling point. None of the ten sampling points exceeded the investigations levels.

2.

The investigation levels are 10*.

of the mean pH from the first 75 samples (15 samples taken on 5 dates 12/74, 6/75, 2/76, 6/76 and 12/76) obtained at each point. '

r DUQUESNE LIGHT COMPANY

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Nuclear Safety and Licensing Department TABLE VII-3 Summary of Specific Conductance Values

~ 6/18/83 Sample Mean of Specific Standard Standard Investigation 2 Point Conductance Levels 1 Deviation Error Rge Level Hg Low 1-1 0.15 0.015 0.004 0.18 0.12 0.58 1-2 0.14 0.022 0.006 0.18 0.11 0.66 2-1 0.12 0.018 0.005 0.14 0.096 0.48 2-2 0.11 0.014 0.004 0.12 0.076 0.42 3-1 0.12 0.020 0.005 0.15 0.091 0.40 3-2 0.14 0.018 0.005 0.17 0.10 0.40 4-1 0.11 0.015 0.004 0.14 0.096 0.38 4 0.14 0.019 0.005 0.18 0.108 0.42 5-1 0.13 0.024 0.006 0.18 0.099 0.38

'5-2 0.14 0.011 0.003 0.15 0.12 0.38 the arithmetic averages of the fifteen soil samples 1.

Mean values are obtained per sampling point.

None of the ten sampling points exceeeded the investigation levels.

2.

The investigation levels are based on a 100% increasee in the mean specific conductance values obtained for the first 75 samples per point.

-(15 samples taken on 5 dates 12/74, 6/75, 2/76, 6/76 and 12/76).

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N DUQUESNE LIGHT COMPANY Nuclear Safety and Licensing Department SOIL CHEMISTRY (ETS Reference 3.1.3.'10) (continued)

Discussion of Results

. June'1983:

-A-EH A. one-way analysis of ' variance was used to compare the.pH of June, 1983 samples with the. pH of June and December, 1978

samples, (See Table VII-4). No significant differences between June,-1983 a;.d June, '1978 were reported for all ten sample points.

Sampling points 2-1, 3-1, and 3-2 were significantly different at the 1% level and sampling point 2-2 was significantly dif ferent at the 5% -level for December,1978.

The mean-pH for all samples from June, 1983 was lower than those reported for' June, 1975; June, 1978; and December, 1978 but higher than December, 1974; February, 1976; June, 1976; and December,.1976 values (Figure 7-3).

The greatest change in mean pH between successive sampling periods occurred between December,

-1976 and June, 1978. The mean pH of all points for June, 1983 decreasd by 0.01 unit.

At the individual sampling locations only sampling point 1-2 had. a lower mean pH value than the average of the seventy-five baseline samples. Sample point 1-2 exhibited the greatest change from baseline:. s amples with a decrease of 0.4 pH units. An examination of the data indicates the usual variance in both the mean pH of all 150 points and in the mean pH's at the 10 individual points. None of the pH values exceeded the investigation levels established by the original seventy-five baseline samples.

-B.

Conductivity comparison of the conductivity values between samples obtained A-during June, 1983 with those obtained during December, 1978 indicates significant differences at the 1% level occurred at

'five (5) locations (See Table VII-4).

The values recorded at sampling point 2-1 were significantly different than those obtained for June, 1978 and December, 1978 at the 5% level.

A difference at the 5% level was recorded for sampling point 2-2 between June, 1983, and June, 1978.

The mean conductivity value for all 150 samples from June, 1983 was lower than any value previously recorded except June, 1978 (Figure.7-4).

Between successive sampling periods, the greatest The mean change occurred between December, 1976 and June, 1978.

conductivity decreased from 0.28 mmhos/cm to 0.125 mmhos/cm - a difference of 0.155 mmhos/cm.

At the ten (10) individual sampling locations, all sampling points had lower. mean conductance. values than the average of the previous baseline seventy-five samples (Figure 7-6).

The greatest change at an individual sampling location, between the June, 1983 samples and the original 75 samples, occurred at. sampling point 1 a difference of 0.18 mmhos/cm. The variance in the conductivity e

TABLE Vil-4 Comparison of pH and Specific Conductance Values June 1983 vs June 1978 and December 1978 pH*

Specific Conductance b

6/83 6/78 12/78 Significant'Iyb 6/83 6/78 12/78 Significantly d

Sampling Soit Expectsd Salt Points Tyge Deposi t ion Hean

>kan hean Different Hean Hean Hean Different 6/78 82/78 6/78 12/78 0.15 0.16 n.19 l-l Pope sitt Low 6.76 6.8 6.7 toan

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I-2 Pope sitt High 6.44 6.4 6.4 0.84 0.15 0.87 g-loam S,g 2-1 Wharton low 4.58 4.6 4.7 0.12 0.10 0.14 m,g allt loam AE 4g 2-2 Wharton High 4.22 4.3 4.3 0.11 0.10 0.15 gn milt loam g ll 3-8 Gilpin-Welkert High 4.69 4.7 4.6 0.12 0.12 -

0.11 gn shaly silt loan E3 aN 0.14 0.14 0.11 gh 3-2 Gilpin-Welkert Low 4.11 4.1 4.3 shaly sitt loan i*

4-l Cilpin channery low 4.36 4.4 4.4 0.11 0.10 0.12 l

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0.14 0.83 0.15 4-2 Cilpin channery High 4.31 4.3 4.3 mitt loam 5-l Wellaton sitt Law 4.55 4.5 4.5 0.13 0.12 0.13 loam 0.14 0.13 0.17 5-2 Wellston allt High 4.26 4.3 4.2 a - Expected low and high deposition levels are relative to each soll type b - Significantly different

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. 4.2 4.0 3.8 1-1 1-2 2-1 2-2 3-1 2-2 4-1 4-2 5-1 5-2 Sa=pling 1.ocations FIGUPI 7-5 10

Hean and 95 Percent Confidence 1.imits of Soit Conductivity at each Sampling Location for June, 1983.

(Data'for each sampling localion based on 15 samples).

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DUQUESNE LIGHT COMPANY Nuclect Sofety cnd Lic;nsing Dspertment SOIL CHEMSITRY (ETS Reference 3.1.3.10)

(continued)

DISCUSSION OF RESULTS (continued) data was similar to the variance in the pH data. The usual mean of all samples and the dispersion was observed for the individual sampling location ' means as compared to the five (5) previous sampling periods. None of the mean conductivity values exceeded the investigation levels established by the original samples.

Summary of June, 1983 Results As summarized in Table VII-4, the pH and specific conductance levels varied slightly. Tha fluctuations noted between years and seasons are a result of natural phenomena (i.e., flooding, soil moisture) to which terrestial biota are adapted. The 1983 soluble salts concentrations are considerably below the point where vegetation would be adversely affected.

Cooling tower drift did not affect either pH or conductivity in a measurable way.

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