ML20212A436
| ML20212A436 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/25/1987 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20212A364 | List: |
| References | |
| NUDOCS 8703030352 | |
| Download: ML20212A436 (11) | |
Text
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 AND EXEMPTION TO SECTION 50.36 OF THE COMMISSION'S REGULATIONS Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 l
Attorneys for Philadelphia Electric Company l
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-352 PHILADELPHIA ELECTRIC COMPANY APPLICATION FOR AMENDMENT OF FACILITY OPERATING LICENSE NPF-39 AND EXEMPTION TO SECTION 50.36 OF THE COMMISSION'S REGULATIONS Philadelphia Electric Company, Licensee under Facility Operating License NPP-39 for Limerick Unit 1 hereby requests that the Technical Specifications contained in Appendix A of the Operating License be amended by revising certain sections as indicated by a vertical bar in the margin of attached pages 6-17 and 6-18.
The proposed change would provide an extension of 30 days to the current 60 day requirement for filing the Semiannual Effluent Release Report.
Additionally, Licensee requests, pursuant to Section 50.12 of the Commissions Regulations, an exemption from the requirements of 10 CPR Section 50.36a(a)(2) in. -
order to provide an extension of 30 days to the current 60 day requirement for filing the Semiannual Effluent Release Report.
A.
Semiannual Effluent Release Reporting Requirements Discussion Current Technical Specification 6.9.1.8 on page 6-17 and on page 6-18 requires that the Semiannual Effluent Release Report covering the previous 6 months of operation shall be submitted within 60 days after January 1 and July 1 of each year.
This schedule presents difficulties in that the data from which this report is developed is dependent on the analyses of certain isotopes which may take a significant period of time to complete.
The length of time which it takes to deliver, analyze and receive the results of the analyses does not provide sufficient time for Licensee's proper preparation and final review of the report within the required 60 day period.
For example, a time period of approximately one week is required for the collection, packaging, and shipment of the sample to the vendor's laboratory located off-site.
The time period from receipt of the effluent sample by the analytical laboratory to the issue of final data to Licensee is approximately 45 days.
This turn-around time is typical of an analysis of this type because of the time required to perform certain portions of the analysis.
Additionally, this analysis is performed during a time of heavier than normal workload for the laboratory due to receipt of similar samples from many other utilities requiring similar analysis to meet the same semiannual deadlines.
Any unforeseen delay in the analyses would result in the necessity to submit an incomplete report in order to meet the 60 day reporting period.
A follow-up report containing the delayed data can be provided but does impose an added dimension to docketing, filing and later recovery of all the data by interested parties.
For the reason discussed above Licensee requests that the time period in Technical Specification 6.9.1.8 on page 6-17 and on page 6-18 be changed from 60 days to 90 days.
The additional 30 days to submit the Semiannual Effluent Release Report will ensure that an adequate period of time is available to analyze the samples, receive and review the data, prepare a report, and provide a reasonable amount af time for review by Licensee's management and technical staffs and to identify and correct errors.
This additional time period will eliminate the need for follow-up reports and reduce errors and omissions caused by compressed review time.
Safety Discussion The extension to the reporting requirement of the Semiannual Effluent Release Report by an additional 30 days will not l
increase the probability of an accident.
The increase in the period of time between the routine collection of samples from l
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the plant and the submittal of the report which contains the data obtained from these samples is not connected to the operation of the power plant in such a way which could have an effect on the probability of the occurrence of an accident.
Significant increases in radiological effluent releases that may be indicative of an inherent defect in plant design or operation and which may require a timely corrective action, are reported promptly under the provisions of 10 CFR Section 50.72 and 10 CFR Section 50.73.
Since this amendment requests the change to a reporting requirement which supplies data on radioactivity released in an effluent, it cannot create the possibility of an accident or malfunction of a different type than any evaluated previously in the FSAR.
This modification does not reduce the margin of safety as defined in the bases for any Technical Specification because the data presented by this report does not affect plant operations in any way which could impact public safety.
Significant Hazards Consideration Determination The Commission has provided examples of amendments which are i
considered not likely to involve Significant Hazards Considerations (Vol. 51 No. 44 Federal Register 7751).
One of the examples, example (i), is a purely administrative change to the Technical Specifications (a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature).. - _
The request to change the Semiannual Effluent Release Reporting requirement (Technical Specification 6.9.1.8) is similar to example (i) in that it is an administrative change to reporting requirements and does not affect reactor operation, accident analyses and has no radiological consequences, therefore the change does not involve a significant hazards consideration.
Operation of the Limerick Generating Station Unit 1 in accordance with this change would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated because the collection and analysis of routine plant data, and the preparation time to transmit the information to the NRC is independent of plant design and operational characteristics that can impact potential accidents.
Significant increases in radiological effluent releases that may be indicative of an inherent defect in plant design or operation, are reported promptly under the provisions of 10 CFR Section 50.72, 10 CFR Section 20.403 and 10 CFR Section 50.73 and are therefore not impacted by this amendment request; (2) create the possibility of a new or different kind of accident from any previously analyzed because the routine collection and transmittal of data does not establish a potential new accident precursor; (3) involve a significant reduction in a margin of safety because the transmittal of this routine plant data does not impact the health and safety of the public.
Justification for the Requested Exemption NRC regulations (10 CPR Section 50.12) provide for specific exemptions if the requested exemption is warranted as follows: (1) the exemption and the activities to be conducted are authorized by law, (2) operation with the exemption does not endanger life or property or involve undue risk to the health and safety of the public, (3) the common defense and security are not endangered, and (4) one or more special circumstances are present as definec in 10 CPR Section 50.12(a)(2).
10 CFR Section 50.36a(a)(2) of the Commission's Regulations require submission of the Semiannual Effluent Release Report within 60 days after January 1 and July 1 of each year.
An exemption is requested to this requirement in the Commission's Regulations to permit a 30 day extension of the current 60 day requirement for filing the report.
The change meets the conditions of 10 CFR Section 50.12 under which an exemption is warranted as described below:
(1)
The Requested Exemption is Authorized by Law The criteria established in 10 CFR Section 50.12 are satisfied in this case; and the Commission, therefore, has the authority under the Atomic Energy Act and its regulations i
to grant the requested exemption.
The activities to be authorized by the requested exemption do not violate any other applicable laws or regulations.
Thus, the Commission is authorized by law to grant this exemption request.
(2)
The Requested Exemption will not Present an Undue Risk to Public Health and Safety The effect of increasing the allowable reporting period for the Semiannual Effluent Release Report does not create an undue risk to public health and safety because the collection and analysis of this routine plant data, and the preparation time to transmit the information to the NRC is independent of plant design and operational characteristics that could impact potential accidents.
Further added assurance of protection of the public health and safety is provided by the prompt notification and reporting of serious effluent release problems in accordance with the requirements of 10 CFR Sections 50.73(a)(2)(viii), 50.72(b)(2)(iv), 20.403(a)(2) and 20.403(b)(2).
(3)
The Requested Exemption will not Endanger the Common Defense and Security The common defense and security are not endangered by this exemption request.
Only the potential impact on public health and safety is at issue and has been determined to be inconsequential in the preceding previous accident analysis, l
Therefore, revising the due dates for submitting this routine 4
data has no effect on the safeguards in place for the common defense and security.
(4)
Special Circumstances A special circumstance is present in the request under consideration in that the application of the regulation would not serve the underlying purpose of the rule.
The purpose of the rule as defined in 10 CFR Section 50.36a (a) is to keep releases of radioactive materials to unrestricted areas to as low as is reasonably achievable (ALARA).
Significant increases in radiological effluent releases that may be indicative of an inherent defect in plant design or operation and which may require a timely corrective action, are reported promptly as before under the provisions of 10 CFR Section 50.72, 10 CFR Section 50.73 and 10 CFR Section 20.403.
The reporting provision of 10 CFR Section i
50.36a(a)(2) addresses merely schedular aspects of the transmittal of routine plant data, and not the process for identifying problems, requiring prompt attention, of interest to the health and safety of the public.
The reporting period
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is only one facet associated with an ALARA evaluation.
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data submitted must be subjected to an evaluation process by the NRC in order to relate it to a measurement of the plants ALARA performance.
Further, additional information would be required for the evaluation process, such as the nature of the plant activities, in order to correlate the data to ALARA performance.
For these reasons, the evaluation of the data can only be a long term process, and an extension of 30 days in this process will have a negligible effect on the evaluation of a plant's ALARA program and hence the public health and safety.
Continued efforts to conform to the 60 day schedule will result in a need to respond to schedular deficiencies resulting in an ineffective utilization of resources with potential for incomplete / incorrect reports requiring additional submittals, revisions and corrections which would place an unnecessary burden upon and divert resources of the NRC and Licensee.
The Plant Operating Review Committee and the Nuclear Review Board have reviewed these proposed changes and have concluded that they do not involve any unreviewed safety questions or significant hazard considerations, nor will they endanger the health and safety of the public.
Respectfully submitted, PHILADELPHIA ELECTRIC COMPANY By
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Vice President.
COMMONWEALTH OF PENNSYLVANIA ss.
COUNTY OF PHILADELPHIA J. W. Gallagher, 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 Pacility Operating Licenses 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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Subscribed and sworn to before me this23 day
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Notary Public MELANIE R. CAMPANELLA Netary Public, Philadelphia, Philadelphia Co.
My Commission bpires February 12, 1590 4
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