ML20205T227
| ML20205T227 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/28/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20205T230 | List: |
| References | |
| NUDOCS 8811140178 | |
| Download: ML20205T227 (5) | |
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v 0FFICE OF NUCLEAR RE ACTOR REGULATION SAFETY EVALUATION rep 0RT BEAVER VAll.EY POWER STATION, UNIT 2 SCHEDULAR EXEMPTION RE: REQUIREMENTS OF RM-50-2 i
Background
Beaver Valley Power Station (BVPS) consists of two PWRs Units 1 and 2 (Docket Hos. 50-334 and 50-412) located in Pennsylvania on the bank of the Ohio River, near the border with the State of Ohio. The Shippingport Atomic Power Station, which is being decomissioned, is on the same site. The construction pemit i
for Unit I was issued June 26, 1970 and it began comercial operation m
tober 1, 1976. The construction pemit for Unit 2 was issued May 3,19;-
The licensee. Duquesne Light Company, has submitted in its FSAR for BVPS-2 designs for liquid and gaseous radioactive waste treatment systems for which the design objectives were to meet the requirements in the Concluding State-i ment of Position of the Regulatory Staff in Docket RM-50-2 which are reproduced s
in the Annex to Appendix ! to 10 CFR Part 50. By so doing, and because the licensee's application for a construction pemit for BVPS-2 was docketed in October 1972 and therefore after January 1,1971 and prior to June 4,1976, the licensee met the specifications in a provision of Section 11.0 of Appendix !
which provides an alternative from performing a cost / benefit analysis (specified in that Section 11.0) to show that its radioactive effluent treatment systems 8811140178 870507 PDR ADOCK 05000334 P
.s 2-ID (v) include all items of reasonably demonstrated treatment technology which can, for a favorable cost / benefit ratio, effect reductions in dose to a surrounding population. The licensee chose to rely on the alternative provision in Section II.D and designed to meet the At.. ex.
The issues being addresseo by this SER are (1) whether the licensee, by choos-ing this course has placed himself in the position of being required to operate BVPS with the objective (among others) of maintaining radioactive effluert releases within the limitations of RM-50-2 in the Annex to Appendix 1 rather than those of Appendix 1 itself for BVpS-2, or, alternatively, to submit for BVPS-2 the cost / benefit analysis specified in Section 11.D of Appendix I, and 2)whetherthelicensee,asaresultofpreparingto'operateBVFS-2tomeet the effluent limitations specified in Appendix 1 itself (including preparing 1
its Radiolugical Effluent Technical Specifications (RETS) and Offsite Dose f
Calculation Manual (ODCM) with this objective) and fhiling to submit the Section 11.D cost / benefit analysis, needs a schedular exemption to its Operat-ing License te pemit temporary operation under Appendix ! pending remediation.
l By a letter of February 24, 1987, a staff position was comunicated to the licensee which indicated that the licensee is required to operate BVr5 to the requirements of RM-50-2, or to submit the cost / benefit analysis specified in t
Section 11.D. or to augment the containment vacuum pump exhaust filter system, or to obtain an exemption "lifting the requirement for fulfilling Paragraph D of Appendix 1 to 10 CFR Part 50."
The licensee responded in a letter dated U March 5, 1987, requesting a schedular exemption "from the requirements of s-
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v RM-50-2" pursuant to 10 CFR 50.12(a). The letter asked that the exemption remain in effect until six months after the issuance of a full-power license for Unit 2.
Evaluation The past actions of the licensee, i.e., FSAR design to meet the requirements of RM-50-2 and docketing of the application for the construction pemit for BVPS-2 on October 20, 1972, clearly meet the requirements of Section II.D of Appendix 1 which provides an alternative from submitting a cost / benefit analysis specified in Section II.D. This point appears to be generally acknowledged.
It can be argued that the licensee has, in a sense sometimes mployed in NRC icensing activities, by submitting in the FSAR systems designed to operate in accordance with the requirements of RM-50-2, committed to such operation and, therefore, should be held to that commitment. However, demon?tration of compliance with Section II.D or, in the alternative, with the Annex RM-50-2 is not a commitment to operate; it is a demonstration concerning how much equipment is to be contained in the design. In the case of BVPS, the specifics of 10 CFR Part 50 and its Appendix 1, and the history of the development of Appendix 1 affect the requirements to be imposed. Foremost is the fact that there is no specific basis in the regulations for imposing the limits in The RM-50-2 as requirements for the operation of a nuclear power plant.
quantitative requirements of Appendix ! itself stand alone, and no specific alternatives are set forth as applicable guidance.
In Section V.A Appendix !
clearly specifies that its guides for limiting conditions for operation shall Vbe applicable in any case in which an application for a pemit to construct
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O light-water-cooled nuclear power reactor was filed on or af ter January 2, 1971. Only for reactors for which the application was filed prior to January 2, 1971 is there specific provision for the use of other values. The applica-tion for the pemit to construct BVPS-2 was filed on September 25, 1972 and therefore the guides for limiting conditions for operation set forth in Appendix I are applicable to BVPS-2. Withregardtoissue(1),therefore,the licenseeiscorrectinpreparing(TechnicalSpecifications,anOffsiteDose Calculation Manual, and training) for operation of BVPS-2 to meet the guides set forth in Appendix ! itself.
With regard to issue (2), because the licensee has proceeded along the correct course, there is no need for remedial action by the licensee, and therefore, F M e licensee should have no need of a schedular exemption in this matter.
Further provision was made in Appendix ! for the case of plants for which applications for construction pemits had been filed prior to January 2,1971; 6
for many of these (with the shorter construction periods of those years, e.g., BVPS-1), the plant construction was either complete or nearly so, and thus backfitting was necessary to achieve ALARA releases. Appendix ! pemitted l
such plants to oe treated on a case-by-case basis with regard to the release levels to be achieved. Beaver Valley Unit 1 is a unit that came under this provision.
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'In sumary, the provision in Section 11.0 referencing RM-50 2 recognized the concurrent development of the plant designs and the quantitative ALARA guidance so as to avoid unnecessarily penalizing certain licensees, tat was not intended to impose upon any nuclear power plant the requirements of PM-50-2.
Thus, although in a sense sometimes employed in NRC's licensing procedures, the licensee, by designing to meet the requirements of RM-50-2 could be considered to have committed to operate to those requirements, there is no requirement for the licensee to operate in conformance with RM-50-2. The requirements of Appendix ! should govern.
l Principal Contributors l
l Jerry Swift Reviewer LeMsine J. Cunningham, Management Joe Scinto Legal Censultation Dated April 28,1987
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