ML20212A292
| ML20212A292 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/17/1986 |
| From: | Bauer E, Bradley E, Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20212A265 | List: |
| References | |
| NUDOCS 8612220368 | |
| Download: ML20212A292 (16) | |
Text
r BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277 PHILADELPHIA ELECTRIC COMPANY 50-278 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICE:1SES DPR-44 DPR-56 Edwarc G. Bauer, Jr.
Eugene J. Bradley Philadelphia, Pennsylvania 19101"i 2301 Market Street i
Attorneys for i
Philadelphia Electric Cor ;any J
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8612220368 861217 l'
PDR ADOCK 05000277 p
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket Nos. 50-277
- PHILADELPHIA ELECTRIC CONPANY 50-278 APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSES DPR-44 DPR-56 Philadelphia Electric Company, Licensee under Facility Operating Lic:nses Nos. CPR-44 and DPR-56 for Peach Bottom Atomic Power Station Unit Nos. 2 and 3, respectively, hereby requests amendment of the Technical Specifications contained in Appendix A P.o the Operating Licenses to reflect the addition of a radwaste treatment subsystem to treat / filter contaminated oily and chemical wastes currently stored at the Peach Bottom facility and
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to make other related Technical Specification changes.
The additional subsys.em will treat / filter chemical / oily waste prior
-o to ofisite release.
It is hereby requested that the Technical Spesifi cati.ons be amelded to include the new chemical / oily waste
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tre. tme nt nubsystem w. th ti ose listed on page 207, paragraph 4.
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The limiting conditions for operation, paragraph (4) on page 207 of the Technical Specifications lists three subsystems for treatment of liquid radwaste.
The proposed change would list a chemical / oily waste cleanup subsystem as a fourth subsystem to those listed in paragraph (4) page 207.
All of the proposed changes to the Technical Specifications are indicLted by a 1
vertical bar in the margin of the attached page 207 for Unit No.
2 and Unit No. 3.
Additionally, the Licensee proposes to exempt the new system from periodic surveillance and to make necessary editorial changes to the Technical Specifications in order to add clarity.
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Licensee has scheduled the installation of the new chemical / oily waste subsystem to begin December 1986, for completion in March 1987, and requests expedited amendment of the Technical Specifications in order that the new system may be promptly used upon installation completion.
The proposed physical mcdifications to the radwaste system would revise existing equipment and add piping and disposable filters between the existing chemical waste tank and the existing laundry drain tanks.
The proposed modifications are described in more detail in the following te::t with the general arrangement shown in sketch A and figure 9.2.1.a attached. s A
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Addition of the Chemical / Oily Waste Subsystem
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The existing radwaste treatment. facility at the Peach j
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Bottom Atomic Power Station do'es not have a subsystem for s
C ofchemica$)cilywastes.
Some of the ch'emical/ oily tr#atmen n
Kas,tes generated in#the past are presently 3 stored throughout the hiantindrums,creitingbothanALARAand_ahousekeepingi s
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s problem.
The proposed radhaste cleanup subsystem would, allow radwaste pyocessing of chemical / oily wastes prior to the treated s
liquid,being released to the discharge canal.
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The existing radwaste subsystems are shown schematically in figure,' 9.2.1.a attached.
There $re f5ur basic li' quid '-
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.n collection subsystems and hne environmental discharge'stbsystem which comprise the liquid r\\ 5.,.,
N adwastes ystem.
The fohr liquid s
collection subsystems consist ofk
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1.
The equipment' drain subsystem for igw conductivity v i s
wastes (high purity water) lb
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The floor drain subsystem,for higher conductivity 3
wastes.
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The chemical waste subsystem for laboratory and decontamination cleaning fluids.
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The laundry drain subsystem fet; treatment of 1 sundry.
s cleaning waches.
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The chemical waste and the laundry drain subsystems are described in, Sections 9.2.4.2.3 and 9.2'.4.2.4 of the Updated
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Peach Bottom Atomic Power Station FSAR.
The proposed chemical / oily waste subsystem would use the existing chemical waste tank for storage of wastes before treatment and the laundry drain tanks for storage of filtered liquids following treatment.
Batch releases of treated waste liquids from the existing subsystems require a sampling and analysis program as described in paragraph 4.8.1 of the Technical Specifications.
The liquid to be released is also required to be treated in accordance with the conditions described on page 207 including processing via the Waste Collector Filter and demineralizer, the Flcor Drain Filter, or the Fuel Pool Filter Demineralizer, prior to being discharged.
Liquid radwaste after filtration by these
. subsystems can be discharged from one of the three sacple tanks li, the radwaste treatment facility:
(1) the flocr drain sample tank, or (2) either of the two waste sample tanks Two laundry drain tanks are physically connected to the same discharge piping and also have the capability to discharge to the environment but are not described in the Technical Specifications.
The proposed chemical /cily waste subsystem would use these two laundry drain tanks as sample tanks for treated / filtered chemical / oily waste.
All of the radwaste subsystems sample tanks are designed so that each tank can be isolated after being filled with filtered liquid waste.
To preclude an erroneous analysis because
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of liquid input to a sample tank after taking a sample and to avoid releasing any of these liquids which were not part of the batch which was analyzed, a radwaste subsystem sample tank is isolated from the radwaste collection system after being filled.
Following isolation but prior to taking a sample, the liquid in a sample tank is' pumped in a closed recirculation mode thru a mixing eductor for a sufficient length of time to assure that the tank contents are homogeneous.
The liquid representative sample which is then taken is analyzed for isotopic activity and water purity.
After isolation, recirculation, sampling and analysis, the liquid in the sample tank is then either recovered for direct re-use in the plant, is released to the environment, or is recycled for further treatment.
If the liquid is not needed or is unsuitable for plant re-use, it is released to the discharge canal.
The radioactivity concentration in the liquid released to the discharge canal is controlled by the rate of release from the sample tank.
The large volume of liquid in the discharge canal dilutes the activity concentration of the liquid being
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released from the sample tank.
The rate of release is calculated.
t from the analysis of the sample which was taken as previously discussed above.
The proposed chemical / oily waste treatment system would be designed to release liquids in the same manner as the existing subsystems described earlier in the text and would use the same discharge line, instruments and con'trols as described above.
Radwaste liquids from the radwaste cample tanks may only be.
released through an existing single common discharge line and may only be released at a limited flow rate thru this line.
This single common discharge pipe (pathway) is shown in figure 9.2.1.a attached.
Two flow meters in parallel (one for high flow and one for low flow), a radiation monitor and an automatic shut-off valve are the instruments and controls provided on the single common discharge line.
The automatic shut-off valve closes if th'e preset release flow, discharge canal dilution flow, or the radiation limits are not within the preset values determined from the sample analysis.
The three radwaste subsystems (waste collector / floor drain collector and the Fuel Pool Filter Demineralizer) which are presently listed on page 207 of the Technical Specifications as discussed above, are not the only process systems capable of treating liquids prior to discharge, although the listed systems were the subsystems that were,most routinely used to process
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liquids at the time the Radiological Effluent Technical Specifications wer.e developed.
The laundry drain tanks were evaluated in the Final
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Safety Analysis Report along with the other radwaste subsyste-and they are physically connected to the existing common single discharge pathway to the circulating water system.
The proposed chemical / oily waste treatment system would incorporate both the chemical waste tank for chemical and oily waste storage and the existing laundry drain tanks for storage of treated liquid, prior to sampling and analysis for discharge via the existing common single discharge line to the circulating water system.
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filtration system would be added between the existing chemical waste tank and the. existing laundry drain sample tanks to capture and/or for adsorption of chemicals and filterables thereby removing radioactive particulates associated with liquid wastes containing discarded (transient) chemicals and oily wastes.
The chemical / oily waste' treatment system design would make use of a disposable activated carbon filtration system and have connections to accommodat use of a disposable demineralizer skid.
Oil / water separation techniques, including the installation of a mechanical oil skimmer in the chemical waste tank will-be provided to take advantage of natural oil / water phase separation.
(See sketch A attached).
Presently, the discarded (transient) chemicals, including sodium pentaborate and contaminated oils are periodically collected and. stored in containers at the Peach Bottom facility.
These wastes result from laboratory wastes, various testing, and leaks and spills in the plant.
Under the proposed system, the liquid wastes stored at the plant in containers would be transferred to the existing chemical waste tank for treatment thru the new filtration system as discussed above, to remove trace oil and organic chemicals and to filter out contaminated particulates.
The treated liquids would then be stored in the existing laundry drain tanks for sampling, analysis ls
- and release via the existing common single discharge line.
If it i
is determined, after sampling and analysis of the batch stored in the laundry drain tank, that the liquid is not within the limits.
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set for release, the contents seuld then be recycled to the chemical waste tank for _urther treatment.
Safety Analysis The proposed modification will improve overall plant operation by providing a dedicated method for treating oil / water emulsions and transient chemical waste.
The present treatment of chemical waste utilizes the waste collector and floor drain collector subsystems, which allows for the possibility of introducing organics into the cycle.
The organics could adversely af fect reactor cord. ant che,mistry, if they entered the e
system.
The proposed chemical /olly waste subsystem would consolidate and concentrate the organics in one dedicated system, thereby reducing the possibility of organics entering the condensate cycle via th'e other radwaste subsystems.
Since the chemical waste tank will be used to store the chemical / oily wastes prior to processing,.it will no longer be necessary to store containers of waste in various areas of the plant.
The containers stored throughout the plant have created both a housekeeping and an ALARA concern.
The chemical waste tank is located in a cell with eighteen inch shield walls, which are adequate for the low activity chemical / oily wastes.
The
~ laundry drain tanks will be used to store treated liquids which are so low in activity that shie'lding, although adequate, is not a concern.
Surveillance Recuirement Description and $sfety Analysis Licensee further proposes that the chemical / oily waste subsystem be included along with those systems that would be exempt from periodic demonstration of operability as described in paragraph 4b page 207 of the Technical Specifications, because unlike the waste collector and demineralizer and the floor drain filter; the chemical / oily waste subsystem is not required for routine treatment of plant wastes, but will be used only for periodic treatment of batch wastec.
The batch wastes, subsequent to processing, will be sampled and analyzed in accordance with the requirements of specification 4.8.1, prior to their release.
The non-availability of the chemical / oily waste subsystems would not adversely affect unit operation and the chemical / oily waste subsystem operability would be demcnstrated by the sampling and analysis of each batch to determine that the liquid analysis is below the limits prior to release.
Gased on the proposed subsystem use of the existing 4
tanks and based'on the proposed subsystem use of the existing common single discharge line, instrumentation and sample / analysis i
program, the proposed Technical Specification chang 2 and system modification will not impact the safe operation of the facility.
Proposed Editorial Chances After including the chemical / oily waste subsystem with the three process syctems described on page 207 of the Technical Specifications (i.e. waste collector filter and demineralizer,
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the floor drain filter and the fuel pool filter demineralizer),
a change in the manner by which the radwaste systems are presented (formatted) in the Technical Specifications is proposed.
A new format is proposed which would list the four process systems in a tabular form for ease of identification and for clarity of expression rather than merely include them in the body of the paragraph as is presently written.
Proposed Description Change Further, the use of terminology " Site Boundary" is proposed in lieu of the existing "unrectricted areas" in order to
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establish consistency in the language of the surveillance requirements, paragraph (4a), and that of the limiting condition for operation paragraph (4) on page 207.
The use of " Site Boundary" would also be consisterr. w:.th the terminology used in the Standard Technical Specificati1ns for General Electric Boiling Water Reactorc, NUREG-0123, devision.', (2 3/4.4.S, Specific Activity).
Cor:rection of Previous Oversicht Licensee proposes to correct tne seetion designation of the Special Report Specifiettion by changir.g the raragrap'a number f rom 6. 9. 3 to 6. 9. 2 cn page, 2(.'.
The Liceit.ee Event reporting requirements were originally numbered 6s0.2 and were subsequently deleted by Amendments 110 ar.d 113 fo.- Unit 2 and Unit 2, respectively, issued July 17, 1985.
The Special Report Specification was then tenumbered 6.9.2 in the same amendments.
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The proposed revision to page 207 would reflect this correctional change in paragraph numbers.
Significant Hazards Considerations The proposed changes to the Technical Specifications do not involve Significant Hazards Consicerations.
In order to support the No Significant Hazard'Concideration determination, necessary background supporting information is provided below, along with an evaluation of eacn of the three standards set forth in 10 CFR Cection 50.92.
(1) Operation in accordance with the proposed amendment does not invo3 ve a significant increase in the probability or enusecuences of an accident previously evalus.ted.
All liquid ra.dwaste controlled effluents to areas at or beyond the site boundary, discharge thru a single common pipe (pathway) to the circulating water system. 'The discharge is continuously monitored for radiation and liquid discharge flow rate.
The discharge flow rate is adjusted based on the' analysis of the batch, sampled prior to being discharged.
The release of the treated chemical / oily waste will also be discharged thru the same common pathway as the existing radwaste effluent after being sampled by the same sample analysis program used for the existing subsystems.
Therefore, absent any new pathway or any new type sample analysis program, the inclusion of the chemical / oily waste subsystem in the technical specifications listing as a viable processing system for treatment of radwaste chemical / oily waste -.,-
streams does not involve a significant increase in the
. probability or consequences of an accident previously evaluated.
(2) Operation in accordance with the proposed amendment does not create the possibility of a new or different kind of accident from a'ny accident previously evaluated.
The chemical / oily waste subsystem will utilize the laundry drain p
tanks, previously evaluated in the UFSAE.
The yearly waste volume to be discharged, and its activity concentration, are less than that previously evaluated in the UFSAR for the Laundry Drain Subsystem.
The new plant subsystem will improve plant operations and will not adversely affect the other radwaste subsystems; therefore, the addition of the chemical / oily waste subsystem and incorporation of the chemical / oily waste subsystem into the radwaste specifications will not create the possibility of a new or different kird of accident from any accident previously evaluated.
(3) Operation in accordance w'ith the propostd amendment does not involve a significant reduction in a margin of safety.
The treated effluent _ rom the chemical / oily waste subsystem will
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be discharged via the same single ccmmon discharge pathway as the effluents from the existing subsystems and will be sampled and analyzed under the same program as the other radwaste subsystems.
The laundry drain equipment and the chemical waste tank will be incorporated into the chemical / oily waste subsystem.
The laundry _
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drain equipment and the chemical waste tank to be incorporated, although not included in the existing radwaste specifications, were previously designed and installed under the same standards as the other existing radwaste equipment.-
After installation of the filters (which may include activated carbon and/or ion exchange resins), the completed treatment system will improve the operations of the radwaste facility, and by consolidation of the chemical / oily radwaste treatment system'into one integrated unit, will treat the waste more effectively than the existing subsystems.
Based on the design criteria used, the operational improvements and use of the existing, previously evaluated discharge patilway and monitoring / analysis program, the addition of the chemical / oily waste subsystem into the radwaste s,pecifications does not involve a significant reduci.icn in a margin of nafety.
Enviror. mental Consideration This amendment adds a fourth radwaste processing system to those described in the Technical Specifications, makes slight format changes and corrects a minor oversight by changing a paragraph number.
The Licensee has determined that the amendment would allow improvement in the overall plant operation by providing a dedicated method for treating oil / water emulsions and transient chemicals, involves no increase in the amounts and no change in the types of any effluents that may be released off-site and has also determined that there is no increase in the individual or cumulative occupational radiation exposure. n
The Plant Operations Review Committee and the Nuclear
' Review-Board have reviewed these proposed changes to the Technical Specifications and have concluded that they do not ir.volve unreviewed safety questions or involve significant Hazards Considerations and will not endanger _the health and safety of the public.
Respectfully submitted, l
PHILADELPHIA ELECTRIC CO.MPANY By h b4/- M CVice Presiddnt 4
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v-COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA J. W. Gallagher, being first duly sworn, deposes and says:-
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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, informaticn and belief.
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u Subscribed and sworn to 7h thforemethis// day of Jbk ea
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Notary Public MELkNIE R. CAMPANELIA Notory Public, Philadelphia, Philadelphia Co.
My Commission Expires February 12,1990 4
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