ML20212B113

Advises That 861231 Request for Change from Requirements of RM-50-2,specified in Annex to App I of 10CFR50,does Not Comply W/Requirements of App I.Staff Position Re Util Request to Control Activity Releases & Recommendations Encl

ML20212B113
Person / Time
Site:	Beaver Valley
Issue date:	02/24/1987
From:	Tam P Office of Nuclear Reactor Regulation
To:	Sieber J DUQUESNE LIGHT CO.
References
TAC-63996, NUDOCS 8703030477
Download: ML20212B113 (6)

Text

r February 24, 1987 Docket No. 50-334 DISTRIRUTION and 50-412 6)

NRC PDR Local PDR PAD #2 Rdg Mr. J. D. Sieber, Vice President T. Novak Nuclear Operations OGC-Bethesda Duquesne Light Company E. Jordan Post Office Box 4 B. Grimes Shippingport, PA 15077 J. Partlow N. Thompson Mr. J. J. Carey, Senior Vice President P. Tam Duquesne Light Company D. Miller Nuclear Group ACRS (101 Post Office Box 4 Gray File Shippingport, PA 15077

Subject:

Beaver Valley Units 1 and 2 - Use of 10 CFR 50 Appendix I Versus Annex RM-50-2 (TAC 63996)

By letter dated December 31, 1986, you requested a change from the requirements of RM-50-2, specified in the Annex to Appendix I of 10 CFR 50. RM-50-2 sets limits on the total site doses and site activity releases. Your proposed departure from the RM-50-2 requirement is to set release limits for each unit individually, as is currently done for Unit 1.

Your proposal, however, does not comply with the requirements of Appendix I.

Specifically, you have not considered all other possible candidate systems that, if installed, could further reduce releases. The enclosure discusses the subject matter in detail and outlines three alternatives for your consideration.

We request your prompt action to resolve this matter.

Sincerely, Peter S. Tam, Project Manager PWR Project Directorate #2 Division of PWR Licensing-A

Enclosure:

As stated cc: See next pages LA PM: PAD # . PD: PAD #2 DP r PTam:h ( LRubenstein 2V /87 2/2./8 3 2/uj/87 8703030477 870224 PDR ADOCK 05000334 p PDR

. f-

,. Mr. J. D. Sieber Beaver Valley 1 Power Station Duquesne Light Company cc:

Mr. W. S. Lacey Pennsylvania Power Company Station Superintendent 1ames R. Edgerly

-Duquesne Light Company Post Office Box 891 Beaver Valley Power Station New Castle, Pennsylvania 16103 Post Office Box 4 Shippingport, Pennsylvania 15007 Mr. Jess T. Shumate, Commissioner State of West Virginia Department Mr. S. Sovick, Acting Supervisor of Labor of Licensing 1800 Washington Street, East Duquesne Light Company Charleston, West Virginia 25305 Post Office Box 4 Shippingport, Pennsylvania 15077 David K. Heydinger, M.D.

State Director of Health Mr. John A. Levin State Department of Health Public Utility Comission 1800 Washington Street, East Post Office Rox 3265 Charleston, West Virginia 25305 Harrisburg, Pennsylvania 171?O Regional Administrator, Region i Gerald Charnoff, Esquire U.S. Nuclear Regulatory Comission Jay E. Silberg, Esquire 631 Park Avenue Shaw, Pittman, Potts and Trowbridge King of Prussia, Pennsylvania 1o406 2300 N Street, N.W.

Washington, DC 20037 Mr. R. Janati Bureau of Radiation Protection

Charles E. Thomas, Esquire Pennysivania Department of Thomas and Thomas Environmental Resources i 212 Locust Street P.O. Rox 2063 Box 999 Harrisburg, Pennsylvania 17120 Harrisburg, Pennsylvania 17108

, John D. Burrows, P.E.

l Marvin Fein Director of Utilities Utility Counsel State of Ohio City of Pittsburgh Public Utilities Comission

, 313 City-County Building -

180 East Broad Street Pittsburg, Pennsylvania 1591n Columbus, Ohio 43266-0573 Resident Inspector U.S. Nuclear Reculatory Comission Post Office Box 298 Shippingport, Pennsvivania 15077 l

r

'\ , -'

. Mr. J. J. Carey \

Duquesne Light Company +

Reaver Valley 2 Power Statioit~

f CC*

Gerald Charnoff, Esq. Mr. R. E. Martin, Manager Jay E. S11 berg, Esq. Regulatory Affairs-Shaw, Pittman, Potts & Trowbridae Duquesne Light CcN any 2300 N Street, N.W. Reaver' Valley Two Pro,iect '

Washington, DC 20037 P. O. Box 328 s

Shidpingocrt,Pennsylvenia 15077 ,

Mr. C. W. Ewing, Ouality Assurance Zori Fettin Manager , Assistant Counsel Quality Assurance Department Governor Energy Council Duquesne Light Company 1625 N. Front Street P. O. Box 186 Harrisburg, PA 15105 Shippingport, Pennsylvania 15077 John O. Rurrows, P.E.

Director, Pennsylv Director of Utilities Management Agency.ania Emergency State of Ohio Room B-151 Public Utilities Commissicn Transportation A Safety Ruilding 180 East Rroad Street Harrisburg, Pennsylvania 17120 Columbus, Ohio 43?66-0573 i s Mr. T. J. Lex Bureau; cf Rediation Prctcetion  ;

Westinghouse Electric Corporation PA Department of Environmental Power Systems Resources P. O. Rox 355 ATTN: R. Janeti Pittsburgh, Pennsylvania 15230 P.O. Pox 2063 Harrisburg,Pennsy1Vdnia 17120 '

Mr. P. RaySircar Stone & Webster Engineering Corporation 3VPS-2 Records Haragement Supervisor P. O. Box 2325 Ouquesne Light Company Boston, Massachusetts 02107 Post Office Fox;4 Shippingport, Pennsylvania 15077 Mr. J. Reall U. S. NRC John A. Lee, Esq.

P. O. 181 -

Duquesne Light Company Shippingport, Pennsylvania 15077 1 0xfcid Centre 301 Grant Street Mr. Thomas E. Murley, Regional Admin. Pittsburgh,-?ennsylvania 15279 s I

U. S. NRC, Region I 631 Park Avenue King of Prussia, Pennsylvania 15229 k

j

_ - _ . _ _ . . _ _ _ , _ _ . . _ . . ,.._.._ _ , .. . _ . _ . , _ _ _ , _ _ _ _ - . ._._ - - . , . _ , , _ , . . , , , . , , , . - - _ . ..._,___-.,,,,.4 -

.- . . ~ _-- . . . . - - .- . .

, t t

STAFF POSITION REGARDING DUQUESNE LIGHT'S REQUEST TO CONTROL ACTIVITY RELEASES IN ACCORDANCE WITH APPENDIX I LIMITS

Background

Both Appendix I and the Annex (RM-50-2) to Appendix I of 10 CFR Part E0 provide numerical guides for design objectives and limiting conditions for l operation te mee+. the criterion "As Low As Reasonably Achievable" for l.

radioactive materials in light water cooled nuclear reactor effluents. The

[-

Annex to Appendix I (RM-50-2) was reserved as an alternate guide, if desired.

for nuclear power stations that submitted their construction pemit between

[ January 2, 1971 and June 4, 1976. Beaver Valley's construction pemit fell in thit time period and Duquesne Light chose to design their two-unit site to meet  :

the design objectives of RM-50-2, as confirmed by Amendment 3 to the Beaver Valley 2 FSAR. The use of RM-50-2 instead of performing the cost / benefit analysis imposes limits on a site which are more restrictive than the option of applying Appendix I for each individual reactor unit. By committing to j -

RF-50-2, Duquesne Light avoided addressing the requirements of Appendix I to i consider all effluent control systems not included in the plant design that are practical for reducing activity releases and to justify the exclusion using a l

cost versus population dose assessment (i.e., cost / benefit analysis).

1 i The requirement for controls on the site effluents to RM-50-2 was chosen by

. Duquesne Light for Beaver Valley 2 (and, therefore, are to be applied to Unit 1)

! and are documented in Amendment 3. Both the Beaver Valley Unit 2 SER and the j FES reconfirmed the use of RM-50-2. Beaver Valley Unit I has been operating, howevne, with its effluent control consistent with the Appendix I limits as a

[.

i result of Duquesne Light Company's adopting the staff radiological efflucnt technical specifications (RETS) for Unit 1. It should be noted that the dose

)i i

limits for a one-unit site do not depart significantly from the site require-

p L. ; ment of RM-50-2. It is only when more than one unit is operating does RM-50-2 L

becoM significantly more restrictive than Appendix I.

A W

I.

n I;

-- .. - -- 5._ J. - ._,_ - - , . , , , ~ . , , . , _,--,.,,___,,---,_m_ ._wm._,mm,.m._#....-%- -

O i

Duquesne Light comented on the DES for Unit 2 stating the intent to operate Unit 2 independently o'f Unit I and impose Appendix I limits to Unit 2, just as were being used on Unit 1. The staff response to Duquesne's coment was con-tained in the FES, and essentially stated the staff position was unchanged, still requiring RM-50-2 as the effluent controlling methodology for the Beaver Valley Unit I and 2 site.

?

In addition to the earlier 3

coment on the DES, Duquesne Light submitted a letter dated December 31 '1986, which requested application of Appendix I limits on Unit 2 as well as Unit 1 instead of the site limits of RM-50-7. Duquesne Light's position is that the staff was advised over a' year ago of their intent to apply Appendix I without any staff objection through their preparation of the Offsite Dose Calculation Manual (ODCM) and Technical Specifications for Unit 1 (which reflect Appendix I) and the Unit 2 ODCM and Technical Specifications which are identical to Unit 1 and are under staff review. Duquesne Light also stated that ,

imposition of the site limits of RM-50-2 would require changes in the existing Unit I and Unit 2 ODCMs and Technical Specifications.

Recommendation l

l Considering the above infomation, it is the staff's position that there are three options for resolution of this issue.

1. The Unit I and Unit 2 Technical Specifications. ODCMs and the plant j operating procedures should be modified and written to reflect the dose l and activity limits set forth in RM-50-2, as committed to in Amendment 3 of the Beaver Valley 2 FSAR.

1

2. To apply Appendix I for each unit instead of RM-50-2, for the site Duquesne Light will be required to adhere to all of the requirements of Appendix I. This includes addressing systems not included in the design to reduce effluent releases and justification of their exclusion on a

, cost / benefit basis. In particular, both Beaver Valley Unit I and Unit 2 1 -

. - - - , ~ - - - - - .

l 4

O do rot have an adequate containment vacuum pump exhaust filter system that will effectively remove radioactive iodine. The Unit 2 SER pointed out this problem and stated no iodine removal credit can be allowed for pred,icting operational activity releases for what is essentially a low volume containment purge. The staff's preliminary evaluation indicates 1 that with an effective charcoal filter system with proper humidity control to keep the charcoal dry, a reduction of approximately 80% in population thyroid doses can be achieved. Appendix I limits can be granted for each unit if the subject filtration system is fixed or if a cost / benefit analysis on modifying the system shows it is not warranted.

3. The dose design limits per reactor Unit of Appendix I may be applied and the requirements of RM-50-2 waived if an exemption is granted lifting the requirement for fulfilling Paragraph D of Appendix I to 10 CFR Part 50.

If this approach is chosen, Duquesne Light will need to submit a formal request for this exemption along with justification.

i Principal contributor R. Fell

~

l i

E _-