ML20212K866
| ML20212K866 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/04/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20212K808 | List: |
| References | |
| NUDOCS 8703090439 | |
| Download: ML20212K866 (18) | |
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of :
- Docket No. 50-171 PHILADELPHIA ELECTRIC COMPANY :
AMENDMENT TO NOVEMBER 24, 1975 APPLICATION FOR AMENDMENT OF FACILITY LICENSE DPR-12 Edward G. Bauer, Jr.
Eugene J. Bradley 2301 Market Street Philadelphia, Pennsylvania 19101 Attorneys for Philadelphia Electric Company hf P
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of : .
- Docket No. 50-171 PHILADELPHIA ELECTRIC COMPANY :
AMENDMENT TO NOVEMBER 24, 1975 APPLICATION FOR AMENDMENT OF
'i FACILITY LICENSE DPR-12 Philadelphia Electric Company, Licensee under Facility License DPR-12 for Peach Bottom Atomic Power Station Unit No. 1, hereby requests that the Facility License and associated Technical Specifications (Appendi:. A) be amended as described in this Application.
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! Background l
i I Peach Bottom Atomic Power Station Unit 1 was a High Temperature, Gas Cooled Reactor (HTGR) located in Yor.c County, I
Pennsylvania, that was permanently removed from service and 4
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placed in a long-term-storage condition in 1978 as described more fully in the July 1978 Final Report, titled: Decommissioning Peach Bottom Unit 1. The facility is located adjacent to Peach Bottom Atomic Power Station Units No. 2 and No. 3, which are Boiling Water Reactors with generating capacities of.1098 MW
. each, that commenced commercial operation on July 5, 1974 and December 23, 1974, respectively.
By Amendment No. 6, dated July 14, 1975, the Commission modified Provisional Operating License No. DPR-12 to possess-but-not-operate status for Peach Bottom Unit 1. The NRC's Safety Evaluation and Negative Declaration and Environmental Impact Appraisal issued with the amendment determined.that the Peach ,
Bottom Decommissioning Plan, involving long-term on-site storage of residual radioactivity, would reduce the expense, personnel exposure, and risk of potential environmental effects from the dismantling operation by allowing the residual radioactivity to decay for about 50 years.
By Application dated November 24, 1975, Philadelphia Electric Company requested an extension of the expiration date of License No. DPR-12 from " December 24, 1975 to June 24, 1977, or until such further time as the Commission may deem appropriate".
The particular term of license was requested in view of the Commission's prior practice of extending the expiration date of DPR-12 for periods of only eighteen months. However, because of the Commission's prior approval of the Decommissioning Plan for Unit 1 it was recognized that the Commission might find it s .
appropriate to issue the " possession only" license for a longer term.
In an NRC letter dated April 2, 1976, Licensee was informed that in accordance with 10 CFR Part 2.109, License No.
DPR-12 was extended until the NRC staff acted on the November 24, 1975 Application. By correspondence dated May 7, 1986, as further explained in a telephone conference, the NRC requested additional information regarding the November 24, 1975 Application.
Specifically, the NRC requested that (1) the November 24, 1975 Application be amended to reflect the Licensee's plans for removal of residual radioactivity from Peach Bottom 1 (dismantle /DECON) and thereby make the facility acceptable for unrestricted access and to provide additional information relating to Licensee's long-term storage plans, (2) submit an environmental analysis, addressing the information outlined in 10 CFR Part 51.45(b), and (3) provide the information requested in Enclosure No. 2aof the previously referenced May 7, 1986 correspondence.
Long Term Plans While a precise schedule for removing the residual radioactivity from Peach Bottom Unit 1 cannot be identified at this time, Licensee acknowledges the desirability of ultimately removing residual radioactivity so as to permit release of the property for unrestricted use and termination of the license.
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' Deferring- final decontamination for another 40 years will ' permit substantial. reductions'in the residual radioactivity levels.
Consequently, long-term on-site storage of the residual radioactivity consistent with the previously approved plan and.
the current status of Peach Bottom Unit 1, followed by a final.
decontamination, is the alternative that would result in the lowest radiation exposure to workers, the lowest levels of radioactive waste for shipment to an off-site licensed burial facility, and the lowest overall expense. Further, deferral of dismantling activities will' avoid any adverse impact on-the operation of the adjacent units (Peach Bottom Units 2 and 3).
The final decontamination of Unit 1 is required only to release the property for unrestricted use and is not necessary to protect--
the health and safety of the public. Considering the stability, isolation, and-limited-quantity of the residual radioactivity remaining at the Unit 1 facility, as well as the Unit 1 inspection program, the potential health risk to the public is non-existent.
The operating Peach Bottom Units 2 and 3 are presently licensed through the year 2008. An extension of the Unit 2 and 3 license to the year 2014 is considered feasible based on the Commission's present policy of licensing facilities from the date of commercial operation. Further extension beyond 2014 may be feasible based on Electric Power Research Institute's (EPRI's)
Extension-of-Life studies and future technological advancements.
An extension of the Unit 1 possession-only license for a term of 40 years would permit integration of the Unit 1 final
' decontamination program with the most probable decommissioning date and decontamination program for Peach Bottom Unit Nos. 2 and 3.
Any detailed plans developed at this time.for the final decontamination program for the Unit 1 facility would not recognize expected improvements in decontamination / dismantling techniques, changes in the Commission's regulations, and the nation's off-site radwaste storage capabilities-forty years in the future. Consequently, such plans would be obsolete prior to their execution. For these reasons, Licensee believes that it is i'
appropriate to defer detailed planning for the removal of the residual radioactivity from Unit 1 to a time frame consistent with the conduct of similar activities at Peach Bottom Units 2 and 3.
{ License Amendment Request In response to the NRC's request of May 7, 1986, Philadelphia Electric Company, hereby amends its Application of November 24, 1975 to:
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- 1. Request an amendment to the Peach Bottom Unit 1 Facility License DPR-12 that extends the term of the License for forty years;
- 2. Request that references to the provisions of Parts 40 and 70 of the Commission's regulations be deleted from the License in recognition that all special nuclear i . _ _ . . . . _ _ _ _ _ _ _ , _ _ _ _ _ . _ . . _ , _ . . . _ . _ _ _ _ . _ _ . _ _ _ _ - _ _ _ . _ _ . .. ~
- c materi'aliand source material. has been ' removed f rom the Unit 1. facility;.
- 3. Request deletion of the reference to the fission product'
. trapping system since all adsorber beds associated with that! system have been removed from the Unit 1 facility;
- 4. Request deletion of the reference to neutron sources (license condition 2.B.(5)) since the' polonium-beryllium and tritium neutron sources are not present.on site, and.
the antimony-beryllium neutron sources in.the reactor core are in the deactivated condition as a result of antimony 124 decay (60 day half life).
- 5. Request the following~ revisions to Appendix A (Technical Specifications) of Facility License DPR-12:
- a. Appropriate editorial and format revisions to reflect the removal of sections 1 through 6 of the Technical Specifications by Amendment No. 6 dated July 14, 1975.
- b. Expand the definition of the Exclusion Areas (Section 1.0) to include the Radwaste Area as described in sections 6.7 and 6.8 of the Final Report, Decommissioning Peach Bottom Unit 1.
- c. Add several locked door / gates in the Exclusion Area barrier to the Administrative Controls Section, 2.l(b). These barriers were described in the Final
- Decommissioning Report; however, they were not contemplated prior to.the last Unit 1 Technical Specification amendment.
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- d. Revise various titles to reflect organizational changes since issuance of Amendment No. 6 to Facility License No. DPR-12.
- e. Change the reference to reporting requirements as
" abnormal occurrences" to " reportable events" in sections 2.l(b)3 and 2.2(c). This change would establish consistency with the nomenclature previously adopted by the NRC for reporting requirements,
- f. Delete the' requirement to include the Unit 1 annual report as a section of the annual report submitted for Units 2 and 3 (section 2.4.(a)). The Unit 1 ;
annual report is currently submitted as a separate report since the annual reporting requirements for Units 2 and 3 were superseded by the current monthly operating report. In any case, submittal e of all Unit 1 reports under its own docket number is consistent with good records management l practices.
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- g. Replace the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting requirement (section 2.4(b)) with a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification, followed up with a 30 day written report. This establishes
{ consistency with the License Event Reporting i
requirements of 10CFR 50.73, and consequently enhances implementation of the reporting process.
Proposed revisions to Facility License DPR-12 and Appendix A are indicated by a vertical bar in the margin.
Safety and Environmental Asselsment All of the proposed revisions to the Facility License, and its Technical Specification, with the exception of the expiration date, either revise obsolete provisions, or expand the scope of the' inspection and reporting requirements. These revisions improve the effectiveness of the License. Extending the expiration date of the License by 40 years has.no impact on the health and safety of the public, and offers several benefits, including a significant reduction in radiation exposure to workers involved in the final decontamination. The factors that justify long-term on-site storage of the residual radioactivity in the Unit 1 facility are discussed below. Additional information regarding the environmental aspects of long-term onsite storage, and the current and projected inventory of radionuclides residing within the decommissioned facility, is presented in the two documents entitled: (1) Environmental Report of the current Decommissioned Status of the Peach Bottom Unit No.
1, and (2) Information Requested .in Enclosure No. 2 of NRC Correspondence, dated May 7, 1986, which are filed herewith and incorporated herein by reference.
- 1. More than199.9 percent of the estimated 0.2 megacuries residual of radioactive material left within the-Unit 1 facility are the neutron activation products contained in the reactor vessel materials. The principal nuclides in the steel pressure vessel are Fe-55 and Co-60.
Radioactive decay of this residual activi*y over-the
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next 40 years will significantly reduce economic and radiological penalties to dismantle /decon. A reduction in the present gamma radiation-levels by a factor of approximately 200 is expected by the year 2026, resulting in lower man-rem exposure to personnel involved in the final decontamination, and lower radioactivity levels in the radwaste shipped off-site
. for burial.
- 2. Final decontamination would include the removal of the reactor vessel, primary coolant piping, and steam generators for shipment to a licensed burial site. The radioactive decay associated with long-term storage will reduce the quantity of airborne particulate that may be released to the environment during the cutting process.
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- 3. During the completed phase of the Decommissioning Program, nuclear fuel, and radioactive liquids and pressurized gases, were removed from the site. Further, piping penetrations into the containment structure have been sealed, except for the filtered vent installed in the equipment door. The contaminated materials and
. systems outside the Exclusion Areas have been
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decontaminated or shipped off-site for licensed burial.
Consequently, the probability-of a Design Basis Accident or lesser nuclear related accident has been eliminated during the long-term storage phase of the Unit 1 facility. Additionally, the potential for a release of radioactive material to the environment is highly improbable.
- 4. The numerous physical barriers surrounding the residual reactivity preclude exposure to the public and plant personnel. The only potential high radiation area in the Unit 1 facility is the cavity containing the reactor vessel. The cavity is enclosed by eight foot thick concrete walls, and all reactor vessel access ports have been sealed with shield plugs and blind flanges. Three foot thick concrete beams have been placed over the sealed reactor vessel access ports. The refueling floor crane needed to lift the beams has been physically (lifting hook and cables removed) and electrically deactivated (electrical control wire to crane motor cut). Most of the residual radioactivity outside the reactor vessel cavity resides in the primary coolant piping and steam generators as internal surface contamination (approximately 20 curies). The rooms enclosing these components have been sealed. All of these areas are further enclosed by the locked containment building and security fence.
- 5. Deferral of final decontamination of the Unit 1 facility would benefit from technological improvements developed over the next several decades in the areas of robotics, decontamination, and equipment disassembly techniques.
These advanced techniques would further reduce radiation exposures and radwaste quantities. Further, deferral would be compatible with the anticipated extension of radwaste storage capabilities in the future.
- 6. A chain link fence encloses the Unit 1 Exclusion Areas containing the containment and spent fuel pool building.
Access to the Exclusion Area requires authorized entry through the locked fence. Entry to the containment structure, the spent fuel pool building, or the radwaste area requires the use of an additional key to the doors of these buildings. All keys are under the control of Units 2 and 3 station supervision. The physical barriers to unauthorized entrance into the facility are inspected semi-annually to ensure that these barriers have not deteriorated.
- 7. Considering the fixed nature of the residual radioactivity, there is a very low probability of by-product material migration. A radiation survey is performed semi-annually to monitor for migration. The inspection includes a survey of radiation levels and surface contamination, as well as airborne particulate activity within the Unit 1 Exclusion Area. A ventilation filter, installed in the containmen,t l
structure for atmospheric pressure equalization, is checked semi-annually for the presence of airborne radioactive materials. Additionally, a radiological environmental monitoring program is performed at the Peach Bottom site as required by the Units 2 and 3 Technical Specifications. The program includes an examination of the environment by analyzing samples of surface water, drinking water, fish, and sediment.
Inspections and surveys performed to date have confirmed the absence of by-product material migration.
- 8. Unit 1 shares the same site with operating units (Peach Bottom Units 2 and 3), permitting continuous observation of the Unit 1 facility. The former Unit 1 Administration building is being used for the Emergency Operations Facility (EOF), Technical Support Center (TSC), and the backup radiochemistry counting facility, required by the Units 2 and 3 Emergency Preparedness Plan, and for classroom space and other miscellaneous support activities necessitating almost daily occupancy by plant personnel. Further, utilization of security, engineering, and health physics personnel from Units 2 and 3 provides ample and readily available man power resources at a nominal expense for an effective inspection program of the Unit 1 facility.
Consequently, the long-term on-site storage phase for Unit 1 is compatible with the long-term use of the entire Peach Bottom site.
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- 9. The_ Units 2 and 3 EOF and TSC are located within 50 feet of the Unit 1 Exclusion Area. Extensive dismantling activities associated with final decontamination of the Unit l' facility prior to the final shutdown of Units 2 and 3 would be disruptive to those support activities.
Significant Hazards Consideration Determination Extending the expiration date of the Unit 1 License by 40 years has no impact on the health and safety of the public considering the current decommissioned status of the facility; and offers several benefits, including a reduction in radiation exposure to workers involved in the final decontamination. A detailed discussion of the benefits is provided in the Safety and Environmental Assessment section of this Application. The other proposed changes to the license involve revisions to obsolete provisions, and expansion of the inspection, reporting, and administrative controls identified in the License.
The Commission has provided guidance for the application of the standards for determining whether a significant hazards consideration exists by providing examples of amendments that are considered not likely to involve significant hazards
! consideration (48 FR 14870). Examples of actions involving no significant hazards consideration are (1) purely administrative changes such as a correction of an error or a change in nomenclature, and (2) a change that constitutes an additional limitation, restriction, or control not presently included in the
technical specifications. The revisions proposed by this Application conform to one or the other of these examples.
The proposed changes do not involve a significant hazards consideration since these changes do not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated since the completed decommissioning program, as previously described in the Safety Analysis Section of this s
Application, has eliminated the potential for a Design i
. Bases Accident; 4
(2) create the possibility of a new or different kind of
!' accident from any previously analyzed because of the absence of any energy generating and by-product material transport mechanisms in a decommissioned facility; (3) involve a significant reduction in a margin of safety because the long-term on-site storage of residual radioactivity would reduce personnel exposure, levels of radioactive waste shipped to a burial site, and risk of potential environmental effects from the dismantling 4 operation by allowing residual radioactivity to decay for at least 40 years following termination of power operations.
The Plant Operating Review Committee and the' Nuclear Review Board have reviewed these proposed changes and have i
concluded that they do not involve any unreviewed. safety questions or significant hazards consideration, nor will they
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endanger the health and safety of the public.
Respectfully Submitted, Philadelphia Electric Company By h bl8-o M UVice President d
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1.
COMMONWEALTH OF PENNSYLVANIA :
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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 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,
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information and belief.
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Subscribed and sworn to before me this ay of / W A, l? 0 I
Ye/ /
Notary Public MCIANIE R. CAMPANEM Notary Public, Philadelphia. Philadelphie m.
My Commission Espires Februsy u, m
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PHILADELPHIA ELECTRIC COMPANY DOCKET NO. 50-171 PEACH BOTTOM ATOMIC POWER STATION UNIT 1 AMENDMENT TO LICENSE Amendment No. 7 License No. DPR-12
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Philadelphia Electric Company (the licensee) dated complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the'Act) and the Commission's rules and regulations set forth in 10 CF9 Chapter 1; B. The facility will be maintained in co,nform ty eith the ,
application, the provisions of thh Act, and the rules and regulations of the Commission; C. There is reasonable assurance: (i) that the activities, authorized by this amended license can be conducted >
without endangering the health and safety of the .
public, and (ii) that such activities will be cendactead in compliance with the Commission's regulations; ,
D. The licensee is technically and financially qua1.ified to engage in the activities authorized by,this amended license in accordance with th'e rules and regulations of the Commission; E. The licensee has satisfied the applicable provisions of 10 CFR Part 140, " Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; L F. The issuance of this amended license will nor be inimical to the common defense and security or to the health and safety of the public; and j.
G. The possession and storage of byproduct material as -
authorized by this amended license will be in !
accordance with the Commission's regulations in 10 CFR ;
Part 30 including 10 CFR Section 30.33.
- 2. Accordingly, License No. DPR-12, as amended, is hereby amended in its entirety to read as follows: ,
c___________ ______ _ ____ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ ____________________a _ _ . _ _ _ _ ______
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'9 A. This amended license applies to the Peach Bottom-Atomic Power Station Unit 1, a decoms.lssioned high-temperature, gas-cooled demonst ation power reactor and.
associated equipment (the facility)' owned by-the Philadelphia Elect?.4c Company. The facility is located-g;,'
4 , at the licensee'r s'ite in York' County, Pennsylvania, 63, and is descrjbed in the application for license dated
[ 3 July 25, 1960,, and amendme.~.ts thereto including the
\i amendment dated ;_
- B. Subject to the' conditions and requirements incorporated herein, the Commission hereby licenses Philadelphia Electric Company
, , (1) Pursuant to Section 104(b) of the Act and 10 CFR )
M b Part 50, " Licensing of Production and Utilization 4
un Facilities," to possess, but not operate, the i reactor.as a utilization facility.
(2) Pursuant to the Act and 10 CFR Part 30, " Licensing l
, of Byproduct Material," to possess, but not to
, r.eparate, such byproduct material as may have been
' proIuced by operation'of the facility. ,
1 C. This license 'hhall be deemed- to contain and be subject )
to the conditions specified in Part 20,.Section 30.34 ,
I of Part 30, Sections 50.54 and 50.50 of Part 50, 10 CFR Chapter I, and to all applicable provisions of the Act J 3,'
and to the~ rules, regulations, and orders of the j Ccmmission now c or hereafter in effect and is subject to the addi'tional conditions specified below:
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PL!1adelphia Electric Company shall not reactivate the facility without prior approval of the
- Commission; ]
(2) Philadelphia Electric Company shall not dismantle 5 or dispose cf the facility without prior approval I
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of the Commission. !
1 (3) Tephnical Specifications.
l The-Technical Specifications contained in Appendix l
, A attached hereto , Designated " Change No. 20 to !
the Technical Specifications") are hereby l (
incorporated in this l'. cense. Changes therein may j t! be mnde only when authcrized by the Commission in accordance with the provisions of 10 CFR Part 50, Section 50.59.
D. Tuls amended license is effective as of the date of issuance and shall expire on .
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