ML20211C824
| ML20211C824 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/17/1986 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20211C786 | List: |
| References | |
| NUDOCS 8610220032 | |
| Download: ML20211C824 (14) | |
Text
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BUFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION 1
In the Matter of Docket No. 50-277
-PHILADELPHIA ELECTRIC COMPANY 50-278 4
APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 & DPR-56 i
Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company i
I 0610220032 861017 j
1
a BEFORE THE 4I f
UNITED STATES NUCLEAR REGULATORY COMMISSION i
)
In the Matter of Docket No. 50-277.
l PHILADELPHIA ELECTRIC COMPANY 50-278 I
i l
APPLICATION FOR AMENDMENT j
OF i
FACILITY OPERATING LICENSES DPR-44 & DPR-56 i
i Philadelphia Electric Company, Licensee under Facility I
Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic i
Power Station Unit Nos. 2 and 3, respectively, hereby requests that the Environmental' Technical Specifications and Bases l
contained in Appendix B to the Operating License be revised,'nd a
1 that license conditions 3(d) in License No. DPR-44, and 3(c) in License No. DPR-56 be deleted, to reflect the issuance by the l
Commonwealth of Pennsylvania of National Pollutant Discharge I
i j
Elimination System (NPDES) Permit PA0009733 on September 27, 1985.
The permit contains thermal and non-thermal effluent j
limitations which assure protection of the environment.
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Previous amendments to the Environmental Technical Specifications (ETS) have deleted all Protective Limits and Report Levels, and all monitoring requirements, except for those relating to thermal effluent monitoring.
(See Peach Bottom Atomic Power Station Amendment Nos. 92 and 94 dated February 24, 1984 and Amendment Nos. 102 and 104 dated August 3, 1984.) As stated in the NRC letter approving. Amendment Nos. 92 and 94, deletion of thermal discharge monitoring requirements was " held in abeyance pending the NPDES 316 proceeding and litigation".
This Amendment Application proposes deletion of the last monitoring requirement (thermal discharge monitoring) since the 316(a) proceeding-has been resolved and effective thermal discharge requirements have been incorporated into the NPDES 4
Permit issued for the Peach Bottom Atomic Power Station by the Pennsylvania Department of Environmental Resources.
Further, the Application proposes revisions to the remaining provisions of Appendix B that reflect the prior deletion of all protective limits, report levels, and monitoring requirements.
Accordingly, Philadelphia Electric Company, Licensee under Facility Operating Licenses DPR-44 and DPR-56 for Peach Bottom Atomic Power Station Unit No. 2 and Unit No. 3, respectively, hereby proposes the deletion of Appendix B, pages 1, 11 and 1 through 53, and substituting therefor revised pages 1 through 3, which are attached hereto and incorporated herein by l
reference.
Further,' Licensee proposes the deletion of license condition 3(d) in License No. DPR-44, and 3(c) in License No.
An explanation of the proposed revisions follows:. - - - _ -
r
'l.
The revised NPDES Permit provides an effective thermal discharge program for the Peach Bottom Atomic Power Station.
The permit establishes operating limits, as well as monitoring and reporting requirements resulting from resolution of the NPDES 316 proceeding.
With the conclusion of this proceeding, deletion of the thermal monitoring provisions from the Peach Bottom ETS on I
current pages 5, Sa, and 5b, and the deletion of the thermal monitoring license conditions 3(d) and 3(c) for Unit No. 2 and Unit No. 3, respectively, is appropriate.
2.
The Application deletes the definitions, abbreviations, and symbols on current pages 1 through 4, since this terminology has been deleted from the ETS by previous amendments and the proposed deletion of the thermal discharge monitoring requirements.
3.
The Application reduces the level of detail in the description of the organization (Section 7.1.1 on current page 48) to reflect the limited scope of the 1
proposed Appendix B provisions and deletes the management organization chart (Figure 7.1.1 on current page 53).
The organization responsible for assuring compliance with the provisions of the ETS is the same organization responsible for nuclear safety and is adequately described in Section 6, Administrative Controls, of Appendix A to the Peach Bottom Operating License, including the management organization chart on Figure 6.2-1.
4.
The Application revises the review responsibilities for the safety review committees (Section 7.1.2 on current pages 48 and 49).
The proposed revisions are as follows:
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a)
The definition of environmental deviations in the current ETS is a failure to comply with a protective limit or report level, or when an event involving siy:41ficant environmental impact has occurred.
Since Protective Limits and Report.
Levels ~have been previously deleted from Appendix B,
the review tesponsibilities of the safety review committees need apply only to the review of events involving a significant environmental impact.
1 b)
The Application proposes a change that would remove the requirement for the Nuclear Review Board to (1) review proposed changes or modifications to plant 1
systems or equipment which may affect the l
environmental impact of the plant, (2) conduct i
periodic audits of plant operations, and (3) review all reported environmental deviations.
4 The radiological effluent release specifications nave been transferred to Appendix-A of the Technical Specifications, by a previous amendment, f
and Nuclear Review Board (NRB) review of activities
associated with this specification are conducted in accordance with the audit provisions of Section 6 of Appendix A.
For this reason and in response to the removal of all protective limits, report levels, and monitoring requirements from Appendix B,
it is not appropriate to retain the NRB audit requirement for the remaining provisions of Appendix B.
Activities that have environmental significance are the primary responsibility of station management and receive a high corporate priority through an organization dedicated to environmental matters under the control of a Director who reports to the Department Manager.
Limiting NRB activities to the nuclear safety-related requirements of Appendix A represents more effective utilization of NRB resources.
5.
The reporting requirements in Section 7.2 (page 40) and Section 7.4 (page 51) that are not rendered obsolete by the deletion of all Protective Limits, Report Levels.,
and Monitoring Requirements from the ETS, are retained in proposed Section III, Reporting Requirements.
The NRC letter transmitting Amendment Nos. 92 and 94, previously referenced, requested that copies of changes to the NPDES permit and any permit violations requiring notification to the permitting agency be sent to the appropriate Regional Administrator and Director, Office of Nuclear Reactor Regulation.
These reporting provisions have been incorporated into proposed Section III, Reporting Requirements.
The response time for the reports is based on a standardized period of 23 Company work days in order to eliminate the variations caused by weekends and Company holidays.
6.
The Application modifies the procedure requirements (proposed Section IV) to reflect the deletion of the Protective Limits, Report Levels, and Monitoring Requirements from the ETS, and to establish consistency with the review and approval' provisions of Section 6.0 to Appendix A of the Operating License.
7.
The Application nodifies the records retention requirements to reflect the deletion of the Protective Limits, Report Levels, and Monitoring Requirements from the ETS.
Further, the Application deletes the records retention requirement for off-site environmental radiation monitoring surveys from Appendix B since this requirement was incorporated into Appendix A, Specification 6.10.2.m, by Amendment Nos. 102 and 104 for Peach Bottom Unit Nos. 2 and 3, respectively.
Safety / Environmental Analysis This Application requests deletion of a now unnecessary monitoring requirement from Appendix B of the operating licenses, and other conforming changes.
None of the requested changes involve matters of safety or have any safety implications.
The
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NRC concluded in Amendment Nos. 92 and 94, previous referenced, that non-radiological environmental requirements are now under the jurisdiction of the U.S. Environmental Protection Agency i
(EPA) as established by the Federal Water Pollutant Control Act s
(FWPCA), as amended, and that these conditions in existing i
reactor operating licenses should be removed as a matter of law where the Licensee holds an effective National Pollutant Discharge Elimination System (NPDES) Permit.
The thermal requirements were retained only because of the pendency of a request by Licensee for alternative thermal effluent limitations pursuant to Section 316(a) of the FWPCA.
With the resolution of I
l this proceeding and the issuance of renewal NPDES permit on j
September 27, 1985, it is now appropriate to delete the remaining 4
thermal monitoring requirements.
The September 27, 1985 NPDES Permit No. PA 009733 l
provides for a real-time management system of thermal discharge l
limitations and monitoring requirements for the station.
The real-time management system deturmines the required number of l
cooling towers to be operated for various combinations of station j
power level, number of circulating water pumps operating and i
l Intake water 7-day moving average temperature.
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operation does not commence until the plant intake water 7-day moving average rises to 53 degrees F.
As the inlet water i
temperature increases in the Spring, the cooling towers will be j
sequentially loaded; and as the inlet temperature decreases in the Fall, the cooling towers will be sequentially unloaded.
When 1
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the moving average ~ decreases to below 53 degrees F, cooling tower operation will not be necessary.
For the following reasons, the real-time management system required by the NPDES Permit will have no adverse environmental. impact.
1.
The water temperature of the plant discharge, at the point of discharge, is. maintained equal to or below the sub-lethal temperature of the most sensitive species of' fish in the conowingo Pond.
The sub-lethal temperature criteria is conservative because no mortalities occur at this temperature.
This criteria is supported by 1,700 laboratory tests involving about 14,000 fish from the Conowingo Pond.
2.
'There is no mixing zone concept inherent in the management system.
Temperatures directly at the point of discharge are maintained below the sub-lethal temperature of the most sensitive representative important fish species.
3.
The real time management system provides a conservative criteria because the velocity of the discharge jet denies a small area to the fish.
Due to mixing in this small area the temperature at the boundary will be somewhat less than the temperature at the point of discharge.
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4.
Since the Summer plumes are surface oriented, the Peach Bottom Atomic Power Station thermal discharge
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essentially does'not affect a large portion of the Pond's water volume and the ecological communities within.
This is substantiated by the postoperational monitoring programe that have been conducted since 1974.
The reduction in the review responsibilities of the Nuclear Review Doard reflects the deletion of all protective limits and monitoring requirements from Appendix B and the primary role of the Board to focus on nuclear safety-related matters.
l l
The other revisions proposed by the Application i
establish consistency with'the deletion of all Protective Limits, Report Levels, and Monitoring Requirements from the ETS.
l Significant Hazards Consideration Determination i
The Commission has provided guidance concerning the application of the standards for determining whether license j
amendments involve no significant hazards considerations by i
3 providing certain examples (48 FR 14870).
One of the examples j
(vil) of actions involving no significant hazards consideration l
1s a change to make a license conform to changes in the i
regulations, where the license changes result in very minor changes to facility operations clearly in keeping with the regulations.
The deletion of the thermal monitoring provision 4
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and reduction in the review responsibilities of the Nuclear Review Board is similar to this example.
As explained previously, the Commission has recognized the shift in responsibility for the establishment of effluent limitations and monitoring requirements.
Another example (i) of actions involving no significant hazards consideration is a purely administrative change to the Technical Specification.
The other changes proposed by this application reflect the prior deletion of all protective limits and monitoring requirements from Appendix B and fits this example.
The proposed amendment does not constitute a significant hazards consideration since it does not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated.
The thermal discharge monitoring requirements which are proposed for deletion have no safety implications or bases.
They do not impact the cooling capability of systems associated with nuclear safety and have no effect on the probability or consequences of any accident.
(2) create the possibility of a new or different kind of accident from any accident previously evaluated because the thermal discharge does not impact the design considerations associated with nuclear safety.
(3) involve a significant reduction in a margin of safety since the requested changes involve no safety margins.
The effective NPDES Permit provides the necessary protection of the environment, and essential reporting provisions to the NRC and administrative controls of activities that may impact the environment are retained.
The Plant Operations and Review Committee and the Nuclear Review Board have reviewed the proposed changes to the i
Technical Specification and have concluded that they do not involve an unreviewed safety question or significant hazard consideration, will not endanger the health or safety of the public and will not have an adverse impact on the environment.
a Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY By:
'h Vice President
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COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF PHILADELPHIA S. L. Daltroff, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Application for Amendment of Facility Operating License and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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t Subscribed and sworn to TA before me this M day of hC A
A Notary Public MEl.ANIE R. CAMPANELLA Notary Public Philadelphia, Philadelphia Co.
My Commission Expres February 12,1993 J
CERTIFICATE OF SERVICE I certify that service of the foregoing Application was m:ide upon the Commonwealth of Pennsylvania, by mailing a copy thereof, via first-class mail, to Thomas R. Gerusky, Director, Bureau of Radiological Protection, P. O. Box 2063,liarrisburg, PA 17120; all this 17th day of October, 1986.
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Eugpe/J. Bradley
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Attorney for Philadelphia Electric Company
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