ML20211H373
| ML20211H373 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/27/1999 |
| From: | Langenbach J GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1920-99-20476, NUDOCS 9909020076 | |
| Download: ML20211H373 (12) | |
Text
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GPU Nuclear, Inc.
Route 441 south NUCLEAR
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Middletown, PA 17057-0480 Tel 717-944-7621 August 27, 1999 1920-99-20476 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Possession Only License No. DPR 73 Docket No. 50-320 Request for Additional Information - License Amendment Request No. 77 Changes to Reflect Storage of TMI-l Radioactive Materials in the TMI-2 Facility This letter provides a response to the request for additional information (RAI) contained in your l
letter dated August 10,1999. Your August 10,1999 letter contained a RAI for both the TMI-l License Amendment Request (LAR) No. 285 and the TMI-2 LAR No. 77. To facilitate review, enclosure 1 provides the RAI response for both LARs. Following the response to the RAI is a i
revised license page mark-up, which incorporates our response to the RAI. Enclosure 2 provides a revised license page, which incorporates our response to the RAI.
The no significant hazards consideration analysis included in our June 29,1999 submittal bounds l
any changes made in this RAI response, thus no change to our analysis is required.
I If any additional information is needed, please contact Adam W. Miller of GPUN at (717) 948-8128 Sincerely, James W. Langenb h v
Vice President and Director, TMI AWM
Enclosures:
- 2) TMI-2 License Revised Pa e O$'O bI l
cc:
Region I Administrator TMI-2 Senior Project Manager TMI-1 Senior Resident Inspector File No. 99109 9909020076 990827 PDR ADOCK 05000320 P
1 METROPOLITAN EDISON COMPANY JERSEY. CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY d/b/a GPU ENERGY GPU NUCLEAR, Inc.
l Three Mile Island Nuclear Station, Unit 2 Possession Only License No. DPR-73 Docket No. 50-320 License Amendment Request No. 77 l
Additional Information
' COMMONWEALTH OF PENNSYLVANIA
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-) SS:
COUNTY OF DAUPHIN
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i This additional information on License Amendment Request 77 is submitted in support of Licensee's request to change Possession Only License No. DPR-73 for Three Mile Island Nuclear Station, Unit 2. All statements contained in this submittal have been reviewed, and all such statements made and matters set forth therein are true and correct to the best of my knowledge.
BY.
/
Vice President and D'
- ctor, I
Sworn and subscribed before me this
-N ay o 999.
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g Nq(ary Public t
Nota Suzantw C. MAlosik. Notary Pudic al mfhon My Member. Pennsylvania Assocation of Notanes 1
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1 i
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i Response to RAI for TMI-l LAR 285 and TMI-2 LAR 77 J
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1920-99-20476 Page lof 7 Request for Additional Information for TMI-1 LAR No. 285 4
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.
The licensee should modify the proposed license conditions to address the following items:
Description of tvoes of radioactive materials (excluding radwaste) oermitted to be l
moved between TMI Units 1 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). Contaminated 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 contamination control considerations.
Response
1he suggated response included above will be incorporated into a revised mark-up oflicense condition 2.h.(3), with the exception that the word " temporarily"is not included in our requested change. While the word " temporarily" correctly describes the staging ofradioactive components under thisprovision, we are concerned that the word might be perceived as being inconsistert with storing certain equipment (, e.g. the reactor coolantpump internals and motor, and certain purchased Bil-2 pump motors stillinstalledin Bil-2) untilneeded. As reflected in the change that we have made to the Bfi-2 license conditions, radioactive material will be managedin quantities that conform with the accident analysis attendant to IMI-2 as documented in the PDMS SAR. Quantities in excess of this amount would constitute an
. unreviewed safety question and would require prior NRC approval.
Description of the types of radwaste permitted to be moved between TMI Units 1 amil Radwaste shall be limited to dry active waste (DAW) and contaminated protective clothing. The following types ofradwaste (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 shall be stored at TMI Units 1 or 2.
Response
7he third sentence of the suggested response included above is incorporated into a revised mark-up oflicense condition 2.b.(4). Thefirst andsecondsentences of the suggestedresponse have not been incorporatedin the revised mark-up oflicense condition 2.b.(4) because we do not want to limit movement ofradwastefrom 7MI-2 to IMI-1 to DA W(Note - contaminatedprotective clothing is not considered radioactive waste, and is addressed in the revised mark-up oflicense
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condition 2.b.(3)). Since allradioactive waste generatedat 7MI-2 currently utili:es some portion of the IMI-Ifacility during itsprocessing/ disposal cycle, we believe that incorporating j
the suggested restrictions into the B11-1 license (i.e. restricting to DA W the wasteflowfrom Unit 2 to Unit 1) wouldseverely hamper the waste processing /shippingprocess in use at the site.
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'a 1920-99-20476 Page 2of 7 All waste generated at Mi-2 is intended to be processed, packaged and staged temporarily prior to disposal, utili:ing common sitefacilities whichfall under the Wi-1 license. As discussedlater, we have made the suggested changes to the corresponding condition in the IMI-2 license, to restrict movement ofradioactive wastefrom Unit I to Unit 2 consistent with the NRC's suggestions.
Source term. The storage of radioactive materials or radwaste generated at one unit and stored at the other omt 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.
Response
The suggested response included above regarding source term limitation will be incorporated into our revisedmark-up oflicense condition 2.b.(.1). We do not believe that the source term limit in the TMI-1 license which governs the radioactive materials being movedfrom Unit 2 to Unit 1 will be chcdlenged, since the amount ofradioactivity that can be generatedas radwaste or staged in theform ofradioactive materials while performing activities allowedduring PDMS is miniscule compared to the source terms associated with the various TMI-I accident analyses.
Any storage locations ofradioactive materials and radwaste must meet existing regulatory and proceduralrequirements.
2.
On page one of Enclosure 1 ofyour June 29 application, you stated that the purpose of this request is to be able to move radioactive materials between the TMi-i and TMI Units "as they currently are." The proposed license conditions provide no gua antee 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 material and radwaste generated at on unit and staged at the other unit will not change significantly in the future.
Response
This concern does not need to be incorporatedinto the TMI-1 license condition. The quantity of radioactive material and radwaste generated at TMI-2 and moved through 7MI-1 would only sigmficantly increase upon implementation ofdecommissioning activities. This is not anticipated to occur until the start ofdecommissioning of TMI-1. In addition, the required submittal ofa PSDAR to the NRC would alert the NRC of anypotential sigmficant increase in activities at TMI-2. As indicatedin our response above, all TML-2 radwaste will only be staged temporarily in the TMI-1facilityprior to disposal. As discussedlater with respect to the TMI-2 license, we have made a change to ourproposed condition to confirm that waste quantities at TMI-2 will be managed to conform with the accident analysis as documented in the PDMS SAR.
Quantities in excess of this amount would constitute an unreviewed safety question and would require NRC approval.
6 1920-99-20476 Page 3of 7 3.
The paragraph number for the second paragraph on page 2 of Enclosure 1 should be "(4)"
instead of"(5).
2
Response
Agreed.
TMI-1 LAR NO. 285 LICENSE PAGE MARK-UP FROM 6/29/99 SUBMITTAL (3)
GPU Nuclear, Inc., pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess at either TMI-l or TMI-2, and use in amounts as requirei any byproduct, source, or special nuclear material without restriction to chemical or physical form, for sample analysis, testing, instnament 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 I or Unit 2 site, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the-feeility either unit.
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); a"d (2) other equipment belonging to TMI Unit I when storage of si eis, quipment at TMI-2 is deemed necessary for load handling or consumination 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 byproduct and special nuclear materials as may be produced by the operation of the facility either unit. Radioactive waste may be moved from TMI Unit 2 to TMI Unit i under this provision for collection, I-
1920-99-20476 Page 4of 7 processing (including decontamination), packaging, and temporary storageprior to disposal.
The storage ofradioactive materials or radwaste generated at TMI Unit 2 and stored at TMI Unit 1 shall not result in a source term that, of released, would exceed that previously analyzed in the UFSAR in terms ofoff-site dose consequences.
Request for Additional Information for TMI-2 LAR No. 77 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 staff's position that the license conditions should be modified to address the following items:
Description of types of radioactive materials (excluding radwaste) permitted to be moved between TMI-l 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). Contaminated 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 contamination control considerations.
Response
1he suggested response included above will be incorix> rated into a revised mark-up oflicense condition 2.b.(4), with the exception that the word " temporarily"is not includedin our requested change. Aspreviously indicated, while the word " temporarily" correctly describes the staging ofradioactive components under thisprovision, we are concerned that the wordmight be perceivedas being inconsistent with storing certain equipment (e.g. the reactor coolantpump internals andmotor, and certainpurchased TMI-2 pump motors stillinstalledin 7MI-2) until needed. Radioactive material will be managedin quantities that conform with the accident analysis attendant to TMI-2 as documented in the PDMS SAR. Quantities in excess of this amount would constitute an unreviewedsafety question and wouldrequire prior NRC approval.
Description of the tyoes of radwaste permitted 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 from other sites shall be stored at TMI Units 1 or 2.
1920-99-20476 Page Sof 7
Response
With the exception of "and contaminatedprotective clothing"from thefirst sentence, all of the -
information in the suggestedresponse above will be incorporatedinto a revised mark-up of license condition 2.b.(5) Protective clothing is addressedin the revised mark-up oflicense comfition 2.b.(4).
bioprce term. The storage of radioactive materials or radwaste generated at one o
unit and 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.
Response
A newparagraph will be inserted into a revised mark-up oflicense condition 2.b.(5) to incorporate thefirst sentence of the suggestedresjxmse above. The secondsentence is not incorporated since any storage locations ofradioactive materials and radwaste must meet existing regulatory andprocedural requirements.
2.
PDMS SAR Section 7.1.3.1 states that "the fuel Handling Building may be utilized for the temporary staging of site-generated radwaste or other appropriate uses." Verify (by modifying the wording of the proposed license conditions) that you plan to continue to utilize the Fuel Handling Building for the temporant staging of site-generated radwaste and not as a long-term storage area of such site-generated waste.
Response
A revised mark-up oflicense condition 2.b.(5) limits the movement ofradioactive wastefrom IMI-1 to 7MI-2 to the temporary movement ofDA W(i.e. temporary staging) and operation of sharedliquidsystems. We believe that this change addresses the concern above.
3.
On page one of Enclosure 1 ofyour 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 generated at one unit and staged at the other unit will not increase in quantity of radioactive meterial and radwaste generated at one unit and staged at the other unit will not change significantly in the future.
Response
J The revised mark-up oflicense condition 2.b.(5) limits movement ofradioactive waste in IMI-2 from 1MI-1 to temporary staging. Also, the newparagraph added to the revised mark-up of
- license condition 2.b.(5) requires that staging ofradioactive materials or radwaste belonging to IMI-1 andstagedin TML-2 willnot result in a source term that, ifreleased, would exceed that l
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1 1920-99-20476 Page 6of 7
, previously analy: edin the PDMS SAR in terms ofoff-site dose consequences. We believe this concern is therefore adequately addressed.
1 TMI-2 LAR NO. 77 LICENSE PAGE MARK-UP FROM 6/29/99 SUBMITTAL (4)
GPU Nuclear Corporation, pursuant to the Act and 10 CFR Pads 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 Pans 30,40, and 70, to possess at the TMI Unit 1 or Unit 2 sites, but not separate, such byproduct and special nuclear materials whieh-remain-at-the-faeility subacquent to the c!canup following the March 28,1979, accident-as may be produced by either unit.
REVISED TMI-2 LAR NO. 77 LICENSE PAGE MARK-UP (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. Other than radioactive apparatus and components to be used at ThfI Unit 2, the radioactive apparatus and components that may be movedfrom Thil Unit i to Thil 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 Thil Unit I when storage of such equipment at Thil 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 whieh-remain-at-the-facility subacquent to-4he c!canup fc!!cwingahe March 28,1979, accident as may be produced by either unit. Radioactive waste that may be movedfrom Thil Unit 1 to Thil Unit 2 under this provision shall be limited to: (1) dry active waste (DA W) temporarily moved to Thil Unit 2 during waste collection activities, and (2) contaminated liquid contained in shared system piping and tanks. Radioactive waste that may be movedfrom Thil Unit 1 to Thil Unit 2 under this provision shall not include spent I
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1920-99-20476 Page 7of 7 fuel, spent resins, filter sludge, evaporator bottoms, contaminated oil, or contaminatedliquidjilters.
The storage ofradioactive materials or radwaste generated at Thil Unit I and stored at Thil Unit 2 shall not result in a source term that, sf released, would exceed thatpreviously analyzed in the PDhfS SAR in terms ofoff-site dose consequences.
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TMI-2 License Revised Page j
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- B.
Subject to the conditions and requirements incorporated herein, the Commission hereby licenses (1)
GPU Nuclear Corporation, pursuant to Section 103 of the Atomic Energy Act ("Act") and 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," to possess but not operate the facility; (2)
GPU Nuclear Corporation, Metropolitan Edison Company, Jersey Central Power and Light, and Pennsylvania Electric Company to possess the facility at the designated location in Dauphin County, Pennsylvania, in accordance with the procedures and limitations set forth in this license; (3)
GPU Nuclear Corporation, pursuant to the Act and 10 CFR Parts 30,40, and 70, to receive, possess, and use at any time any scaled sources for radiation monitoring equipment calibration; (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 instmment calibration or associated with radioactive apparatus or components to be used at either TMI-l or TMI-2. Other than radioactive apparatus and components to be used at TMI Unit 2, the radioactive apparatus and components that may be moved from 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 I when storage of l
such equipment at TMI Unit 2 is deemed necessary for load handling or contamination control considerations; and l
(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 as may be produced by either unit. Radioactive waste that may be moved from TMI Unit I to TMI Unit 2 l
under this provision shall be limited to: (1) dry active waste (DAW) temporarily moved to TMI Unit 2 during waste collection activities, and (2) contaminated liquid contained in shared system i
piping and tanks. Radioactive waste that may be moved from TMI Unit I to TMI Unit 2 under l
this provision shall not include spent fuel, spent resins, filter sludge, evaporator bottoms, j
contaminated oil, or contaminated liquid filters.
The storage of radioactive materials or radwaste generated at TMI Unit I and stored at TMI Unit 2 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 C.
This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations in 10 CFR Chapter I, and is subject to all applicable prodsions of the Act and to the Commission's rules and regulations, except for those exemptions from specific portions of the regulations granted by the Commission and still applicable, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Technical Soccifications The Tecimical Specifications, as revised through A = h-mt No., are hereby mcorporated into this license. The licensee shall maintain the facility in accordance with the Technical Specifications and all Commission Orders issued subsequent to the date of the possession only license.