ML20210U757

Forwards Info Received from Gpu Nuclear,Inc on 990820 in Preparation for 990823.Requests Info Be Docketed

ML20210U757
Person / Time
Site:	Three Mile Island
Issue date:	08/20/1999
From:	Colburn T NRC (Affiliation Not Assigned)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9908200201
Download: ML20210U757 (8)

Text

Id v

]

i j

Note To: Document Control Desk From: Timothy G. Colburn, Senior Project Manager, Section 1 ,

Project Directorate 1 )

Division of Licensing Project Management i

Subject:

Docketing of Material The attached information in preparation for a Monday, August 23,1999 conference call was  !

. received from GPU Nuclear, Inc. on Friday August 20,1999. Please docket. l Timothy G. Colburn, Docket No. 50-289 I

i D6/  ;

200071  !

9908200201 990820 PDR ADOCK 05000289 P PM .

y

s m e-2 o -s9

~

macceran> un.om covmx1saccerensnow IntiEJGNEENG& JREGEL41GRTATTADtS asrserioan .

g T~t m Co { 10avH ( N R C- TD31-I Aaiek Yh F.

v atasc Adam M tils- [Tmi LtEurd,vn.)

y v-cmaans:

R Ar*To Iktm Poids" b In wdw b-23-91 10 dm Tele cwid ( 8 vile Ltle 0 6 to-375-55 37) c

. wTAL NUMEER OFPAGES MCE.l@MG COHrA SBEET

~10 CONFDtM 1EEROG9EES - OR if ntEREAJtE ANYM908LEMS -

-CDNTACT-SUE norrtnear pgy) us. gut 1

10*d BN-m 01 DNISN3317 T/IW1 WOdd PS:80 666T-03-Dre

W E

'~ .

i

~

I RAI Talking Points for TMI-IfrMI-2 LAR's 285/77 Page 1 of 6 ~

Request for Additional Information for TMI-1 1.AR No. 285

1. He proposed revised license conditions contain insufficient information concerning the types of radioactive materials and radwaste that can and cannot be moved between units. The licensee should modify the proposed license conditions to address the fb!!owing items:

Descrintion of tvnes of r=Ain=ceive materials (excludinn radwaste) nermitted to be moved between TMI Units 1 and 2. Radioactive materials shall be limited to contaminated components and apparatus which are outage related (e g., cont =ia= tad scaffolding, tools, protective clothing, portable shielding, decontamination equipment). Contaminated equipment (e.g., reactor coolant pump intemals and motors) from on unit may also be stored temporarily in the other unit, if necessary, due to load handling and contamination control considerations.

The suggested response included abon will be incorporated into a revised mark-up oflicense condition 2.b.(3), with the exception that the word

• temporarily

• is not included in our requested change. While the word

" temporarily" correctly describes the staging of radioactive components under this provision, we are concemed that the word might be perceived as being inconsistent with storing certain equipment (, e.g. the reactor coolant pump infomals and motor, and certain purchased TMI 2 pump motors stillinstalled in .

TMI-2) until needed As reRected in the change that we have inade to the TMI-2 license conditions, radioactive materialwill be managedin qdantities that cont 6rm with the accident analysis attendant to TMI-2 as documentedin the PDMS SAR. Quantities in excess of this amount would constitute an unreviewed sakty question and would require prior NRC approv:1.

Descriotion of the tvoes of radwaste oermitted to be moved between TMI Units 1 an Radwaste shall be limited to dry active waste (DAW) and contammated protective clothing. He following types of radwaste (generated at TMI Units 1 or 2 ) may not be moved between units: spent fuel, spent resins, filter sludge, evaporator bottoms, contaminated oil, or contaminated liquid filters. No radioactive wastes from other sites shallbe stored at TMI Units 1 or 2.

The Mrst and third sentences of the suggested response included above will be incorporatedinto a revised mark-up oflicense condition 2.b.(4). However, the wording in the revised merk-up oflicense condition 2.b.(4) will not limit mowment of redroactive waste from TMI-2 to TMI-1 to DAW (Note - conterrinated protective clothing is not considered radioactive waste, and is addressed in the revised mark-up oflicense condition 2.b.(3)). Since all radioactive waste generated at TMI-2 currently utilizes some portion of the TMI-1 facility during its processing / disposal cycle, we believe that incorporating the suggested restrictions into the TMI-1 license (i.e. restricting to DAW the waste Mow from Unit '

2 to Unit 1) would sentely hamper the weste processing / shipping process in uw c-at the site. AII waste genereted at TMI-2 is intended to be pmcessed, packaged l' and steged temporarily prior to disposal, utilizing common site facilities which fall under the TMI-1 license. As discussed later, we have made the suggested changes to the corresponding condition in the TMI-2 license, to restrict movement of radioactive waste from Unit I to Unit 2 consistent with the NRC suggestions. i f

01 DNISN3311 T/lW1 WOM.d t$:80 666T-02-Dn0

- E0*d' BDW-DBN

RAI Talking Points for TMI-lfl'MI-2 LAR's 285n7 Page 2 of 6 Source term. 'Ihe storage of radioactive matenals or radwaste generated at on unit and stored at the other unit shall not result in a source term that, if released, would exceed that previously analyzed in the SAR in terms of off-site dose consequences. To minimize any potential releases, the licensee shall ensure that significant quantities or radioactive materials and radwaste are stored in locations having controlled and monitored ventilation systems.

We have included such a source term limitation in the TMI-2 license (as discussed later), but do not believe that a source terrn limit is necessary in the TMI-1 license to govem the tedioactive materials being moved from Unit 2 to Unit

1. The amount of activity that can be generated as radwaste or staging of radioactive materials while performing activities allowed during POMS is miniscule compared to the source terms associated with the various TMI-1 accident analyses. Any storage locations of radioactive materials and redweste must meet existing regulatory and procedural requirements.

2. On page one of Enclosure 1 of your June 29 application, you stated that the purpose of this request is to be able to move radioactive materials between the TMI-1 and TMI-2 Units "as they currently are." The proposed license conditions provide no guarantee that the amount of radioactive material and radwaste generated at one unit and staged at the other unit will not increase in quantity in the future. Verify (by modifying the wording of the license conditions) that the quantity of radioactive rnaterial and radwaste generated at on unit and staged at the other unit will not change significantly in the future.

i Dris concern does not need to be incorporatedinto the TM-1 license condition. The quantity of

}

radioactive material and radwaste generated at TM1-2 and moved through TM-1 would only l significantly increase upon implementation ofdecommissioning activities. This is not anticipated; to occur until the start ofdecommissioning ofTM-1. In addition, the required submittal ofa l

PSDAR to the NRC would alert the NRC ofany potential signifcant increase in activities at Thil- ,

2. As indicatedin our response above, all TM-2 radwaste will only be staged temporarily in the '

TM.]facilityprior to disposal. As discussed later with respect to the TM-2 license, we have j made a change to ourproposed condition to confrm that waste quantities at TM-2 will be 1 managed to conform with the accident analysis as documented in the PDMS SAR. Quantities in excess ofthis amount would constitute an unreviewed safety question and would require NRC approval.

3. The paragraph number for the sec6ad paragraph on page 2 of Enclosure I should be "(4)" ins of"(5).

Agreed.

l 1

i BOW-DBN 01 DN!SN3317 t/1W1 WOdd' SS:80 6F T-One EO*d

n l

l RAI Talking Points for TMI 1/fMI-2 LAR's 285/77 Page 3 of 6 Request for Additional Information for TMI 2 LAR No. 77 l

1. The proposed revised license conditions contain insufficient information concerning the types of radioactive materials and radwaste that can and cannot be moved between units. It is the staffs -

position that the license conditions should be modified to address the following items:

Description of tvoes of radioactive materials (excludinn rad _ waste) cermitted to be moved between TMI-I and 2. Radioactive materials shall be limited to contaminated components and apparatus which are outage related (e.g., contaminated scaffolding, tools, protective clothing, portable shielding, decontamination equipment) Con-tammated equipment (e.g., reactor coolant pump internals and motors) from one unit may also be stored temporarily in the other unit, if necessary, due to load handling and .

l contamination control considerations.

The suggested response included abon will be incorporated into a revised mark-up oflicense condition 2.b.(4), with the exception that the word " temporarily"is not included in our requested change. As previously indicated, while the word l

• temporanly" correctly describes the staging of radioactive components under this provision, we are concemed that the word might be perceived as being inconsistent with storing certain equipment (e.g. the reactor coolant pump l intemals and motor, and certain purchased TMI-2 pump motors stillinstalledin TMI 2) until needed. Radioactive material will be managedin quantities that conibim with the accidsnt analysis attendant to TMI-2 as documented in the PDMS SAR. Quantities in excess of this amount would constihste an unreviewed safety question and would require prior NRC approval.

Descriotion of the tvoes of radwaste oermitted to be moved between TMI Units 1 and 2.

Radwaste shall be limited to dry active waste (DAW) and contaminated protective clothing. The following types of radwaste (generated at TMI Units 1 or 2) may not be moved between units; spent fuel, spent resins, filter sludge, evaporator bottoms, contaminated oil, or contaminated liquid filters. No radioactive wastes fmm other sites l

shall be stored at TMI Units I or 2.

With the exception of"and contaminatedprotective clothing"from thefirst sentence, all of the information in the suggested response above will be incorporated into a revised mark-up ofhcense condition 2.b.(5) Protective clothmgis addressedin the revised mark-up oflicense condition 2.b.(4)..

Source term. The storage of radioactive materials or radwaste generated at one unit ands stored at the other unit shall not result in a source term that, if released, would exceed that previously analyzed in the PDMS SAR in terms of off-site dose consequences. To minimize any potential releases, the licenses shall ensure that significant quantities of radioactive materials and radwaste be stored in locations having controlled and monitored ventilation systems.

A new paragraph will be inserted into a revised mark-up oflicense condition 2.b.(3) to

. incorporate the)1rst sentence of the suggested response above. The second sentence is not incorporated since any storage locations ofradioactive materials and radwaste must meet existing regulatory andprocedural requirements.

01 DN1SN3317 I/1W1 WO&i 95:80 666T-02-900 t*O 'd - NDW-3dN

m1.

RAI Talking Points for TMI 1/fMI-2 LAR's 285n7

- Page 4 of 6

2. PDMS S AR Section 7.1.3.1 states that "the fuel Handling Building may be utilized for the temporary staging of site-generated radwaste or other appmpriate uses." Verify (by modifying the wording of the proposed license conditions) that you plan to continue to utilize the Fuel Handling Building for the temoorary staging of site-generated radwaste and not as a long-term storage area of such site-generated waste.

A revised mark-up oflicense condition 2.b.($) limits the movement ofradioactive wastefrom Tb6-1 to Th6-2 to the temporary movement ofDA W(i.e. temporary staging) and operation of shared liquidsystems. We believe that this change addresses the concern above.

3. On page one of Enclosure 1 of your June 29 application, you state that the purpose of this request is to be able to move radioactive materials between the TMI l and TMI-2 units "as they currently." The proposed license conditions provide no guarantee that the amount of radioactive

-' material and radwaste genciated at one unit and staged at the other unit will net increase in quantity of radioactive material and radwaste generated at one unit and staged at the other unit will not change significantly in the future.

The revised mark-up oflicense condition 2.b.(S) limits movement ofradioactive wasts in ThG-2 from Th6-1 to temporary staging. Also, the new paragraph added to the revised mark-up of license condition 2.b.($) requires that staging ofradioactive matertals or radwaste belonging to TAG-1 and staged in Th6-2 will not result in a source term that, ifreleased, would exceed that previously analyzedin the PDMSSAR in terms ofof-site dose consequences. We believe this l concern is therefore adequately addressed TMI -1 LAR NO. 285 LICENSE PAGE MARK-UP i (3) GPU Nuclear, Inc., pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess at either TMI-1 or TMI-2, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis, testing,  !

instrument calibration, or associated with radioactive apparatus or components; (4) GPU Nuclear, Inc., pursuant to the Act and 10 CFR Parts 30 and 70, to possess at the - TMI Unit 1 or Unit 2 site, but not separate, such byproduct and special nuclear materials as may be produced by the operation of S: faci!!ty either unit.

I l

- SO*d- BDW-Ohf/ 01 DN!SN3311 I/IW1 WOdd 2.9:80 666T-02-000 l

. l RAI Talking Points for TMI 1/TMI-2 LAR's 285n7 Page 5 of 6 l REVISED TMI -1 LAR NO. 285 LICENSE PAGE MARK-UP (3) GPU Nuclear, Inc., pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess at either TMI-1 or TMI-2, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis, testing, instrument calibration, or associated with radioactive apparatus or components. Other than radioactive apparatus and components to be used at TMI Unit 2, the radioactive apparatus and components that may be movedfrom TMI Unit I to TMI Unit 2 under this provision shall be limited to: (1) outage-related items (such as contaminated scaffolding, tools, protective clothing, ' portable shielding and decontamination equipment); and (2) other equipment belonging to TMI Unit 1 when storage of such equipment at TMI-2 is deemed necessary for load l handling or contamination control considerations; \

(4) GPU Nuclear, Inc., pursuant to the Act and 10 CFR Parts 30 and 70, to possess at the TMI Unit 1 or Unit 2 site, but not separate, such l

byproduct and special nuclear materials as may be produced by the operation of the facilhy either unit. Radioactive waste may be moved from TMI Unit 2 to TMI Unit i under this provision for collection, j processing (including decontamination), packaging, and temporary storage prior to disposal. l TMI -2 LAR NO. 77 LICENSE PAGE MARK-UP i

(4) GPU Nuclear Corporation, pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components to be used at either TMI-1 or TMI-2; and (5) GPU Nuclear Corporation, pursuant to the Act and 10 CFR Parts 30,40, and 70, to possess at the TMI Unit 1 or Unit 2 sites, but not separate, such byproduct and special nuclear materials which ::=in at the f: ility cuhquent to th: 01 r;up fc!!crin;; th: Mrch 23,1979, ccident. as may be produced by either unit.

t 01 DN!SN3D11 t/1W1 WOBd LS:80 666t-0&Dnd 90*d BDW-DBN

a

. ' 40*d 10101

( ,

RAI Talking Points for TM1-1A'MI-2 LAR's 285n7 Page 6 of 6 REVISED TMI-2 LAR NO. 77 LICENSE PAGE MARK-UP ,

1 (4) GPU Nuclear Corporation, pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use in amounts as required any byproduct, l source, or special nuclear material without restriction to chemical or '

physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components to be used at either TMI-1 or TMI-2. Other than radioactive apparatus and conponents to be used at TMI Unit 2, the radioactive apparatus and conponents that may be movedfrom TMI Unit 1 to TMI Unit 2 under this provision shall be limited to: (1) outage-related items (such as contaminated scaffolding, tools, protective clothing, portable shielding and decontamination equipment); and (2) other equipment belonging to TMI Unit 1 when storage ofsuch equipment at TMI Unit 2 is deemed necessaryfor load handling or contamination control considerations ; and (5) GPU Nuclear Corporation, pursuant to the Act and 10 CFR Parts 30,40, and 70, to possess at the TMI Unit 1 or Unit 2 sites, but not separate, such byproduct and special nuclear materials ";hich rc=:in at the facility sub=;uent to the e!::nup fc!!c" ring the Mrch 23,1979, ::cident. as may be produced by either unit. Radioactive waste that may be movedfrom TML Unit 1 to TMI Unit 2 under this provision shall be limited to: (1) dry active waste (DA W) tenporarily moved to TMI Unit 2 during waste collection activities, and (2) contaminated liquid contained in shared system piping and tanks. Radioactive waste that may be movedfrom TMI Unit 1 to TMI Unit 2 under this provision shall not include spent fuel, spent resins, filter sludge, evaporator bottoms, contaminated oil, or contaminatedliquidfilters.

The storage of radioactive materials or radwaste generated at TMI Unit 1 and stored at TMI Unit 2 shall not result in a source term that, if released, would exceed thatpreviously analyzed in the PDMS SAR in terms ofoff-site dose consequences.

40*d BDW-3BN 01 DN!SN3317 I/IW1 WOdd BS:80 666I-02-D00