ML20211H400
| ML20211H400 | |
| 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 | |
| 1920-99-20474, NUDOCS 9909020080 | |
| Download: ML20211H400 (12) | |
Text
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l GPU Nuclear, Inc.
(
Route 441 South NUCLEAR Post Office Box 480 Middletown, PA 17057-0480 Tel 717 944 7621 August 27, 1999 1920-99-20474 U.S. Nuclear Regulatory Commission Attn: Document Control Desk -
Washington, DC 20555
Dear Sir:
Subject:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR 50 Docket No. 50-289 Request for Additional Information - License Amendment Request No. 285 j
Changes to Clarify Authority to Possess Radioactive Materials Without Unit Distinction This letter provides a response to the request for additional information (RAI) contained in your 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 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 any changes made in this RAI response, thus no change to our 10 CFR 50.92 analysis is required.
If any additional information is needed, please contact Adam W. Miller of GPUN at (717) 948-8128 Sincerely,
- 4.
James W. Langenbach Vice President and Director, TMI AWM
Enclosures:
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- 2) TM1-1 License Revised Page 020"09
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Region I Administrator g
TMI-1 Senior Project Manager TMI-l Senior Resident Inspector File No. 99110 9909020000 990827 PDR ADOCK 05000289 P
PDR j
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l METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY d/b/a GPU ENERGY GPU NUCLEAR, Inc.
Three Mile Island Nuclear Station, Unit i Operating License No. DPR-50 Docket No. 50-289 License Amendment Request No.-285 AdditionalInformation COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF DAUPHIN
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This additional information on License Amendment Request 283 is submitted in support of Licensee's request to change Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1. All statements contained in this submittal have been reviewed, and all such statements made and matters set forth therein are tme and correct to the best of my knowledge.
BY:
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O Vice President and I$ rector, MI Sworn and subs ribed before me this
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[Ngary Public Notaria! Scal Sura.ne C. M 100 ak. Notary Public Londonderry Twp, Dat;phin County My Commt.sion Expires Nov. 22,1995 MemMr. Penas/bania ASS 00ation of Natanes i
l Response to RAI for TMI-l LAR 285 and TMI-2 LAR 77 i
1 1920-99-20474 Page lof 7 Request for Additional Information for TMI-1 LAR No. 285 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) permitted to be moved between TMI IJnits 1 and 2. Radioactive materials shall be limited to contaminated components and apparatus which are outage related (e.g.,
conteminated 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
Ihe suggested response included above will be incorporated into a revised mark-up oflicense condition 2.b.(3), with the exception that the word " temporarily"is not includedin our requested change. 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 TMI-2) untilneeded. As reflected in the change that we have made to the IMI-2 license conditions, radioactive material will be managed in quantities that conform with the accident analysis attendant to TML-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 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.
Response
The third sentence of the suggested response included above is incorporated into a revised mark-up oflicense condition 2.b.(4). Thefirst andsecondsentences ofthe suggestedresponse have not been incorporatedin the revisedmark-up oflicense condition 2.b.(4) because we do not want
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to limit movement ofradwastefrom TMI-2 to TMI-1 to DA W(Note - contaminatedprotective clothing is not considered radioactive waste, and is addressed in the revised mark-up oflicense condition 2.b.(3)). Since allradioactive waste generatedat TMI-2 currently utili:es some portion of the TMI-1 facility during itsprocessing/ disposal cycle, we believe that incorporating the suggested restrictions into the 7MI-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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1920-99-20474 Page 20f 7 All waste.generatedat 7MI-2 is intended to be processed, packaged andstaged temporarily
. prior to disposal, utili:ing common sitefacilities whichfall under the IMI-I license. As discussedlater, we have made the suggested changes to the corresponding condition in the TMI-2 license, to restrict movement ofradioactive wastefrom Unit I to Unit 2 consistent with the NRC's suggestions.
1 Source termc The storage of radioactive materials or radwaste generated at one unit and stored at the other unit shall not result in a source term that, ifreleased, would exceed that previously analyzed in the SAR in terms of off-site dose l
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.
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Response
l The suggested response included above regarding source term limitation will be incorporated into our revised mark-up oflicense condition 2.b.(4). 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 I will be challenged, since the amount ofradioactivity that can be generatedas radwaste or staged in theform ofradioactive materials while performing activities allowed during PDMS is miniscule compared to the source terms associatedwith the various IMI-l accident analyses.
Any storage locations ofradioactive materials and radwaste must meet existing regidatory 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-l and TMI-2 l
- Units "as they currently are." The proposed license conditions provide no guarantee that the amount ofradioactive 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 7MI-1 license condition. 7hc quantity of radioactive material and radwaste generated at TMI-2 and moved through TML-1 would only sigmficantly increase upon implementation ofdecommissioning activities. This is not anticipated to occur until the start ofdecommissioning of TML-1. In addition, the required submittal ofa PSDAR to the NRC would alert the NRC ofanypotential sigmficant increase in activities at 7MI-2. As indicatedin our response above, all TMI-2 radwaste will only be staged temporarily in the TML-1facilityprior to disposal. As discussedlater with respect to the 7MI-2 l
license, we have made a change to ourproposed condition to confirm that waste quantities at l
IMI-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.
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1920-99-20474
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Page 3of 7 J
3.
The paragraph number for the second paragraph on page 2 of Enclosure I should be "(4)"
instead of"(5).
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Response
i Agreed.
TMI-1 LAR NO. 285 LICENSE PAGE MARK-UP FROM 6/29/99 SUBMITTAL 4
(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 i
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 the facility either unit.
l REVISED TMI-1 IAR 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 bc 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 I when storage of such equipment at TMI-2 is deemed necessary for load 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 byproduct and special nuclear materials as may be produced by the operation of the-facility either unit. Radioactive wa.ite may be moved from TMI Unit 2 to TMI Unit i under this provision for collection,
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J 1920-99-20474 Page 4of 7 processing (including decontamination), packaging, and temporary storageprior to disposal.
The storage of radioactive materials or radwaste generated at TMI Unit 2 and stored at TMI Unit i shall not result in a source term that, sf released, would exceed that previously analyt.ed 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 staffs 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
The suggested re.sponse included above will be incorporated 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 word might be perceivedas being inconsistent with storing certain equipment (e.g. the reactor coolantpump internals and motor, and certain purchased TML-2 pump motors still installed in 7MI-2) until needed. Radioactive materialwill be managedin quantities that conform with the accident analysis attetulant to TMI-2 as documentedin the PDMS SAR. Quantities in excess of this amount would constitute an unreviewed safety question and would require prior NRC approval.
Description of the tvoes 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 TM1 Units 1 or 2.
1920-99-20474 Page Sof 7
Response
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 of license condition 2.b.(5) Protective clothing is addressedin the revisedmark-up oflicense condition 2.b.(4).
Source term. The storage ofradioactive materials or radwaste generated at one unit and stored at the other unit shall not result in a source term that, ifreleased, 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 insertedinto a revisedmark-up oflicense condition 2.b.(5) to incorporate thefirst sentence of the suggestedresponse 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 temocrary staging of site-generated radwaste 4
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) andoperation of sharedliquidsystems. We believe that this change addresses the concern above.
j 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 generated at one unit and staged at the other unit will not 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.
Response
The revised mark-up oflicense condition 2.b.(5) limits movement ofradioactive waste in IMI-2 from IMI-1 to temporary staging. Also, the newparagraph addedto the revisedmark-up of license condition 2.b.(5) requires that staging ofradioactive materials or radwaste belonging to
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IMI-1 and staged in IMI-2 will not result in a source term that, ifreleased, would exceed that
l 1920-99-20474 Page 6of 7 previously analy: edin the PDMS SAR in terms ofoff-site dose consequences. We believe this concern is therefore adequately addressed.
J 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 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-l 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 vehich remain at the facility subsequent to the cleanup fc!!cveing 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-l or TMI-2. Other than radioactive apparatus and components to be used at Thil 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 TMI Unit I when storage of such 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 remain at the facility subsequent to the c!:anup fc!!cveing the March 23,1979, accident as may be produced by either unit. Radioactive waste that may be movedfrom TMI Unit 1 to Thil Unit 2 under this provision shall be limited to: (1) dry active waste (DA W) temporarily moved to TML 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
1920-99-20474 Page 7of 7 fuel, spent resins, filter sludge, evaporator bottoms, contaminated oil, or contaminatedliquidfilters.
I The storage ofradioactive materials or radwaste generated at TMI Unit
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1 and stored at TMI Unit 2 shall not result in a source term that, if released, would exceed that previously analyt.ed in the PDMS SAR in terms ofoff-site dose consequences.
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1 TMI-l License Revised Page N_
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_,. (2)
GPU Nuclear, Inc., pursuant to_ the Act and 10 CFR Parts 30,40 and 70 to receive, possess and use at any time any byproduct, source and special nuclear material as reactor fuel, sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission i
detectors in amounts as required for reactor operation; I
(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 required any byproduct, l
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 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 such equipment at TMI-2 is deemed necessary for load 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 byproduct and special nuclear materials as may be produced by the operation of either unit. Radioactive waste may be moved from TMI Unit 2 to TMI Unit I under this provision for collection, processing (includmg decontamination), packaging, and temporary storage prior to disposal.
The storage of radioactive materials or radwaste generated at TMI Unit 2 and stored at TM1 Unit I shall not result in a source term that, if released, would exceed that previously analyzed in the UFSAR in terms of off-site dose consequences.
This license shall be deemed to contain and is subject to the conditions specified in the c.
following Commission regulations 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level GPU Nuclect, Inc. is authorized to operate the facility at steady state reactor core power levels not in excess of 2568 megawatts thermal.
_(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No.
are hereby incorporated in the license. The GPU Nuclear, Inc.
shall operate the facility in accordance with the Technical Specifications.
Amendment No.
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