ML20081D096
| ML20081D096 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/07/1984 |
| From: | Bauer E, Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20081D092 | List: |
| References | |
| NUDOCS 8403150140 | |
| Download: ML20081D096 (12) | |
Text
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 AMENDMEhi TO MARCH 1, 1979 APPLICATION FOR AMENDMEhT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philtdelphia, Pennsylvania 19101 Attorneys for fh3 0!O ade W a M ee W e N pany 0
7 P
4 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of i
Docket Nos. 50-277 I
PHILADELPHIA ELECTRIC COMPANY 50-278 PMENDMENT TO MARCH 1, 1979 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 i
By letter dated July 11, 1978, the Division of Operating Reactors requested Philadelphia Electric Company (Licensee),
l inter alia, to submit a license amendment application to incorporate the applicable specifications of the Appendix I Model Technical Specifications (Radiological Effluent Technical Specification or RETS) enclosed with the letter into the Appendix "A" Technical Specifications for Peach Bottom Units 2 and 3.
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Accordingly, by application dated March 1, 1979, Licenseo requested an amendment to the Peach Bottom Atomic Power Station Unit 2 and Unit 3 Operating Licenses in response to the NRC i
request regarding the Appendix I Technical Speci fications.
The NRC staff at a meeting with the Licensee on June 29, 1982, requested revisions in the Licensee's Amendment Application and/or explanation of proposed exceptions to the Appendix I Technical Specifications.
Therefore, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom tomic Power Station Unit No. 2 and Unit No. 3 respectively, hereby amends its application of March 1, 1979 in its entirety, by requesting that the Technical Specifications incorporated in Appendix "A" of the Operating Licenses be amended by revising sections 3.2, 4.2, 3.8, 4.8, 6.0 and associated bases; by revising pages 11, iii, iva, vi, via (Unit 2), iv, iva, vi, via (Unit 3),
1, 2,
3, 4, 5, 6, 7,
8, 58, 59, 75, 84, 92, 93, 203-216, 248, 252, 254, 254a, 256, 257-259, 261.
The extent of these l
revisions has necessitated the inclusion of additiona) pages due
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to the organization of the Technical Specifications to meet the RETS reouirements.
Therefore, the Specifications are further l
modified by adding pages 216a-1 through a-5, 216b-1, b-2, 216c-1, c-2, 216d-1 through d-6, 216e, 216f-1 through f-7, 248a, 252a, j ~
256a, 259a, b, 261a, and 265-267.
All changes are indicated by a vertical bar in the margin of the attached revised pages.
The proposed changes conform to the intent of the model Technical Specifications.
However, certain of the model Technical Specifications are not applicable to Peach Bottom Atomic Power Station.
Additionally, the Licensee proposes several exceptions and alternatives to the administrative requirements regarding the implementation of the Model Technical Speci ficati ons.
These deviations are outlined as follows:
1.
Liould Holdup Tanks: The model Technical Specifications establishes operability and surveillance reouirements for level instrumentation on outdoor radioactive liauid storage tanks that are not surrounded by dikes.
All outdoor tanks at the station which have the potential for containing radioactive liquids are surrounded by dikes capable of holding the tank contents and have overflows and drains connected to the liquid radwaste treatment system.
2.
Continuous Liquid Releases: The model Technical Specifications identifies the radioactive liouid waste o
sampling and analysis program for both continuous and l
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botth releases.
All routine radioactive liould releases from the station are batch releases.
3.
Land Use Census:
a.
Dose assessment analysis to determine compliance with Appendix I hefs shown that a real residence does exict at the site boundary of maximum dose potential.
There is no reason to conduct an annual residence survey because it is not possible for a different residence to appear at a location with greater dose potential.
b.
The dose assessment analysis has also shown that the maximum dose to man occurs via the grass-cow-milk pathway.
The calculated dose at the maximun dose real dairy f arm is greater than the calculated dose at any hypothetical vegetable garden which could exist off-site.
Since this pathway could never be the limiting pathway, there is no benefit to be gained by performing an annual garden census.
4.
Gaseous Radwaste Trip Function: The radiation monitors on the gaseous radwaste system are provided with alarm indications, however, no trip functions are included in _
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o these monitors.
The holdup pipes in the offgas radwaste treatment system provide a nominal three day delay time in the passage of offgas radwaste to the main plant stack.
This extended holdup period provides suf ficient time for manual isolation of the offgas system should the radiation levels in the offgas system increase, to insure that the doses due to gaseous effluents do not exceed the Technical Specifications.
5.
Special Reports: Licensee proposes that Special Reports required as a result of the Radiological Ef fluent Technical Specifications be furnished to the Commission within 21 working days of the date of the event.
This s
requirement satisfies the intent of the model Technical Specification of 30 days from the date of the event.
This is consistent with the If censee's current Technical Specifications requiring written followup to, reportable occurrences which reouire prompt notification by s
defining the reporting period as ~ a period of 10 working days.
6.
Annual Radiological Environmental Operating Feport: The s
Licensee proposes to submit the' An'nual Radiological Environ'anntal Operating Report to the Commission covering the previous calendar year prior t'o May 31 of S
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each year.
Submission of the report by this date provides the necessary time required for preparation, consultant input and detailed review to ensure completeness and accuracy of the. submission to the Commis si on.
7.
Annual Radiation Dose Assessment Report: The Licensee proposes to submit the Annual Radiation Dose Asressment Report within 120 days af ter January 1 of each year.
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This period allows suf ficient time for the calculation of. radiation doses following publication of the radioactive releases in the Radioactive Effluent Release Report.
The turnaround time between the determination of all plant radioactive ef fluents and publication of the Radioactive Effluent Release Report is very short.
This turnaround time does not allow time for calculation of radiation doses in time for publication of the Radiation Dose Assessment Report within 60 days af ter January 1 of each year.
C.
Steam Jet Air Ejector Radiation Monitors: The steam jet air ejector radiation monitors are permanently wired 'in place and are not normally accessible.
Currently, these monitors are calibrated by analysis of an of fgas g:ab sampl e.
The design and installation of the steam jet l
air ejector radiation monitors makes it inadvisable to perform a source check as defined in the model Technical Specifications.
Additionally, performance of routine source checks would not be consistent with ALARA.
9.
Ground Water: The Branch Technical Position (March 1978) on radiological environmental monitoring states that ground water must be sc71tored only if likely to be affected.
There are no ground water sources that are likely to be af fected by Peach Bottom because the ground water flow at the site is toward Conowingo Pond and rx) wells exist between the plant and the pond.
10.
Drinking Water, I-131: The Branch Technical Posi tion recommends analysis for I-131 in drinking water only if the calculated dose is greater than 1 mrer/yr.
The maximum calculated dose to an individual from I-131 in drinking water is only 0.28 mrem /yr.
11.
Milk, Gamma Spectrometry: Experience obtained during seven years of operation of Peach Bottom indicates that nuclides other than I-131 from Peach Bottom releases have not been detected in milk.
The dose assessment analysis for Appendix I indicates that cesium-137 and 134 might have a mincr dose impact as a result of long-l l i l
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term buildup in soil with subsequent transfer to grass and milk.
Quarterly gamma spectrometry or cesium isotopic analyses on milk are adeauate to detect and evaluate the occurrence of any such effects.
12.
Food Products, Gamma Spectrometry: No crops grown in the vicinity of Peach Bottom are irrigated with water in which licuid plant wastes have been discharged.
13.
Green Leafy vegetation, I-131: The milk pathway, which
.results in a greater maximum dose to man than the vegetation pathway, is monitored at locations near the site and is a better indicator than vegetation sarples.
The Branch Technical Position requires this analysis only if milk sampling is not performed.
14.
Instrument and Channel Calibration: The definition of instrument and channel calibration (page 3 of the proposed Technical Specifications) has been revised to specify that "the known value of the parameter shall be injected into the channel or instrument as close to the pr' mary sensor as practicable".
The proposed revision i
acknowledges the diverse calibration requirements of primary sensors associated with different parameters.
For example: the injection of a known signal into 1.
primary sensors measuring flow or vibration is not practicable.
15.
PORC Review of ODCM: Licensee proposes that the Of fsite Dose Calculation Manual (ODCM) not be subject to PORC review and approval.
The expertise for developing and reviewing the ODCM resides with the of fsite engineering group, not with the members of PORC.
Adding this responsibility to the PORC will distract their attention from plant operating activities for which they have primary responsibility, and is therefore not in the interest of plant safety.
Additionally, Licensee proposes that technical specification 3.8.C.8c be deleted.
Licensee is unaware of any technical basis that the Standby Gas Treatment System be available when purging the primary containment via the Reactor Building Ventilation Exhaust System.
As permitted by technical specification 3.8.C.8b, the primary containment may be purged via the Reactor Building Ventilation Exhaust System (REVES) whenever primary containment integrity is not required.
Appropriate isolation features are available to terminate primary containment purging via RBVES in the event this release path becomes unavailable.
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Upon approval of the Technical Specifications contained herein, licensee requests a period cf 6 months from the date of approval for implementation of Technical Specifications proposed in this amendment.
This period is reauested for the preparation and PORC approval process of additional Health Physics and Chemistry procedures necessary for the administrative control of the Radiological Ef fluent Technical Specifications and the i
Of f site Dose Calculation Manual.
Additionally, existing t
procedures must be carefully reviewed and modified as necessary to ensure that the performance of plant activities currently performed are consistent with the Radiological Ef fluent Technical Speci ficati ons.
The methodology to be used in the calculation of of f-site doses due to radioactive gaseous and liquid ef fluents, and details of the environmental radiological monitoring program are set forth in a document titled "Of fsite Dose Calculation Manual, Peach Bottom Atomic Power Station, Units 2 and 3, Philadelphia Electric Company", Revision 0, which is filed herewith and incorporated herein by reference.
The Plant Operation Review Committee and the Operation and Safety Review Committee have reviewed this Amendment and the changes to the Technical Specifications proposed herein and have concluded that they do not involve an unreviewed safety question
or a significant hazard consideration, and will not endanger the health and safety of the public.
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