ML20246F367
| ML20246F367 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/23/1989 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20246F371 | List: |
| References | |
| NUDOCS 8908300294 | |
| Download: ML20246F367 (26) | |
Text
o
.i 10 CFR 50.90 J
{
PHILADELPHIA ELECTRIC COMPANY j
NUCLEAR GROUP HEADQUARTERS
$55-65 CHESTERBROOK BLVD.
WAYNE, PA 19087-5691 (115) 640 6000 August 23, 1989 Docket No. 50-171 License No. DPR-12 4
U.S. Nuclear Regulatory Comission f
ATTN: Document Control Desk Washington, D. C. 20555
SUBJECT:
Peach Bottom Atomic Power Station, Unit 1 Technical Specifications Change Requert
Dear Sir:
Philadelphia Electric Company hereby submits an amendment to its November 24, 1975 Application for Amendmer t as amended March 4,1987, in accordance with 10 CFR 50.90, requesting changes to the Technical Specifications (Appendix A) of License No. DPR-12 for the deconnissioned facility, Petch Bottom Atomic Power Station Unit e
No. 1.
This submittal reflects changes requested by NRC correspondence dated September 7, 1987, P. B. Erickson, NRC to W. M. Alden, PECo.
Information supporting this Change Request is contained in Attachment I to this letter, and the proposed replacement pages are contained in Attachment 3.
The proposed License Conditions remain as filed on March 4, 1987, and are resubmitted as for ynur reference.
If you have any questions regarding this matter, please contact us. The Licensing Engineer for tMs Change Request is Paul Blackiston (215-640-6787).
Very truly yours,
. 0.
o 8908300294 890823 G. A. Hunger, r.
.2 PDR ADOCK 05000171 Director P
PNU Licensing Section Nuclear Support Division Attachments 1, 2, and 3 l
l cc:
W. T. Russell, Administrator, Region I USNRC foO[
T. P. Johnson, USNRC Senior Resident Inspector
' l 1
y' COMMONWEALTH OF PENNSYLVANIA f
ss.
COUNTY OF CHESTER l
-D. R. Helwig, being first duly sworn, deposes and-says:
That he is Vice President of Philadelphia Electric Company, the Applicant herein;.that he has read the att' ached request'(number 86-18) for changes to Peach Bottom Facility Operating License DPR-12, 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.
f t
/
Vice P sident Subscribed and sworn to s
before me this M day of
. d 1989.
t hLYtthlg)$, YK Erdj/
Notary Public NOTARIAL $EA CATHEnlNE A. MENDEI. Notary Pu%c
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Media Boro. Delaware Co.
L Whr CommlB9 ion Expires Sept 4.1989 l
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c; TSP 86-18374 - WC3-s h.Yj
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ATTACHMENT 1 PEACH. BOTTOM ATOMIC POWER STATION UNIT NO. 1' Docket No. 50-171 License No. DPR-12 y.
TECHNICAL SPECIFICATIONS CHANGE REQUEST' No. 86-18=
" Changes to' License Conditions and its. Technical.
Specifications" Supporting Information for Changes - 18 pages
Docket No. 171' License No. 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 (Appendix A) be amended as described in this Application.
===.
Background===
Peach Bottom Atomic Power Station Unit 1 was a High Temperature, Gas Cooled Reactor (HTGR) located in York County, j
Pennsylvania, that.was permanently removed from service and
,placed in'a long-term storage condition in 1978 as described more fully in the July 1978 Final Report, titled: Decommission *1ing
' 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 _ _ _____ _ ---. _ - _ _ _ -
Docket No. 171 License No. DPR-12 dismantling operation by allowing the residual radioactiv3ty to
-decay for about 50 years.
By Application dated November 24, 1975, Philadelphia Electric Company requested an extension of the expiration date of l
License No. DPR-12 from." December 24, 1975 to June 24, 1977, or l
L 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 appropriate to issue the " possession only" license for a longer l
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 the NRC requested additional information regarding the November 24, 1975 Application.
Specifically, the NRC requested that (1) the November i
24,.1975 Application be amended to reflect the Licensee's plans I
for removal of residual radioactivity from Peach Bottom 1 (dismantle /DECON) and thereby make the facility acceptable for unrestricted access and to provide addit.ional information relating to Licensee's long-term storage p)ans, (2) submit an _ - _ _ _ - - _
i y
p v
.c Docket Ncx 171 i
License No. DPR-12 l.
environmental' analysis, addressing the information outlined in 10 CFR Part151.45(b), and (3) provide.the information requested in
. Enclosure No. 2 of the previously referenced May 7, 1986 correspondence.
Accordingly, by Application dated March'4, 1987, Philadelphia Electric Company amended its November 24, 1975 Application to reflect changes requested in the NRC's May 7, 1986 correspondence.
Subsequently, by correspondence dated September 7,
1988,.
P.
B. Erickson, NRC to.W. M. Alden, PECo, the NRC
- requested four changes to the PBAPS Unit 1 Technical Specification proposed in the March 4, 1987 Application.
These
. changes involved additional requirements dealing with water intrusion, effluent releases, reporting, and record keeping.
The Application propose.= changes to the PBAPS Unit 1 Technical Specifications to reflect this request.
The revisions to the March 4, 1987 Application are LGentified by a vertical bar in the margin.
Further, the September 7, 1988 letter from the NRC requested (1) the installation of a water level monitor and alarm system for the detection of water intrusion into lower level
- spaces of the Frach Bottom Unit 1 containment, and (2) a study of the need for a cathodic protection system for below ground structures.
A response to these two requests were submitted by correspondence dated December 10, 1988 and July 12, 1989, i - _ _ _ _ _ _ _.
~$.
O '
Docket No. 171 o_
License No. DPR-12 respectively, and are repeated in enclosure 1-filed with this application.
- Long Term Plans Whileia 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.
. Deferring' final decontamination for another 40 years will permit substantial reductions in the residual radioactivity levels.
' Consequently, Icng-term on-site storage of the residual radioactivity consistent with the previously approved plan and the current status of Peach Bottom Unit 1, foll-owed 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 j
dismantling activities will avoid any adverse impact on the operation of the adjacent units (Peach Bottom Units 2 and 3).
cThe final decontamination of Unit 1 is required only to release the property for unrestricted use and the dE ferral of this activity will not endanger 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 !
t 4
Docket No. 171 Licence No. DPR-12 as the Unit 1 inspection program, the potential health risk to tne 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 cperation.
Further extension beyond 2014 may be
- feasible based on Electric Power Research Ibstitute's (EPRI's)
Extension-of-Lifs studies and future technological advancements.
An extension cr the Unit 1 possession-only license for a term of 40 years would permit integration of the Unit 1 final decontamination program with the mc.?i probable decommissioning date for Peach Bottom Unit Nos. 2 and 3.
Any detailed plans developed at this time for the final decontamiantion 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 many years in the future.
Consequently, such plans would be obsolete prior to their execution.
For these reasons, Licensec believes that it is appropriate to defer detailed planning for the removal of the residual radioactivity from Ur.it 1 to a time frame cohcistent with the conduct of similar cctivities at Peach Bottom UGits 2 l
and 3.
License Amend. ment Request _ - _ - - - _ - _
[~'
I.
YF Docket Ho. 171 License No. DPR-12 In response to the NRC's request of May 7, 1986 and September 7, 1988, Philadelphia Electric Company, hereby amends l
its Application of November 24, 1975 to:
1.
Request an amendment to the Peach Bottom Unit 1 Facility l
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 q
l the License in recognition that all special nuclear i
material and source material has been removed from the Unit i 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 t'eference to neutron sources (license condition 2.B.(5)) since the polonium-beryllium and tritium neutron sources F.re 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).
j 5,
Request the following revisions to Appendix A (Technical Specifications) of Facility License DPR-12:
i I
a.
Appropriate editorial and format revisions to reflect the removal of sections 1 through 6 of the 1 !
i
'9 0
i Docket No. 171 License No. DPR-12 1
l a
Technical Specifications by Amendment No. 6 dated July 14, 1975.
b.
Expand the definition of the Exclusion Areas q
(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.
Delete the reference to the Information Center (section 1.0) since the use of the facility as a public information center has been discontinued.
d.
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.
e.
Revise various titles to reflect organizational changes since issuance of Amendment No. 6_to l
Facility License No. DPR-12.
(
f.
Change the reference to reporting requirements as
" abnormal occurrences" to " reportable events" in d
sections 2.l(b)3 and 2.2(c).
This change would j
establish consistency with the nomenclature previously adopted by the NRC for reporting i
requirements. l' l
l
..r.
Docket No.-171 License No'. DPR-12 g.-
Add two additional reportable events (section 2.1(b)3) to reflect the NRC's September 7,'1988 request.
These involve effluer.t releases and water accumulation in the containment.
The limits for these two parameters are identified in proposed specifications 2.l(b)8 and 2.1(b)9.
The limit.for water accumulation of 500 gallons is equivalent to approximately 85% of the storage capacity of the containment sump, h.
Add the record keeping requirements of regulation 10 CFR $0.75(g) to section 2.2 as requested in the LNRC's September 7, 1988 letter.
These requirements involve records of contaminated spills, as-built plant drawings, and decommissioning cost estimates.
i.
Expand section 2.3 (Periodic Inspections) to reflect the NRC's Geptember 7, 1988 request.
The proposed changes would esthblish monthly inspections of the containment for water intrusion and the radiological analysis of accumulated water.
Further, a provision to inspect the exclusion area barriets is added to reflect the surveillance program described in the July 1978
)
report titled: Decommissioning Peach Bottom Unit 1.
j Deletc the requirement to include the Unit 1 annual report as a section of the annual report submitted I
1 lL__--------------_----------
Docket Nc. 171 i
License No. DPR-12 for Units 2 and 3 (section 2.4.(at).
The Unit 1 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 of all Unit 1 reports under its own docket number is consistent with' good records management practices, k.
Replace tile 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting requirement (sectica 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 Repcrting requirements of 10CFR 50.73, and consequently enhances implementation of the reporting process.
Further, the written report would be required to be submitted in accordance with 10 CFR 50.73 as requested in the NRC's September 7, 1988 letter.
Finally, a requirement to include in the annual report the results of the radiological analysis of accumulated water in the containment, along with the corrective actions, is proposed in response to j
Proposed revisions to Facility License DPR-12 and Technical Specification (Appendix A) are identified by a vertical bar in the margin. l
.4 4
l Docket No. 171 License No. DPR-12 L
' Safety and Environmental Assessment ll All of the prcposed revisions to the Facility License, and its Technical Specification, with the exception of the
.expirotion date, either reviss obsolete provisions, or expand the j:
scope of the inspection, reporting and administrative control requirements.
These revisions improve the regulatory
- effectiveness of the License.
Extending the expiration date of the' License by 40 years har no impact on the health and safety of
,. the public, and offers-several benefits, including a significant i
reduction in radiation exposure to workers invclued in the final deconta.tinat ion.
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 were filed with the March 4, 1987 Application.
1.
More than 99.9 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.
i l - _ _ _ _ _ _ _ __ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
___________m
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Docket No. 171 License No. DPR-12 Radioactive decay of this residual activity over the i
next 40 years will significantly reduce the erzonomic and radiological penalties to dismantle /decon#
A reduction in the present gamma radiation levels by a factor of
'approximately ?.00 is expected by the year 2026, resulting in lower man-rem exposure to personnel involved in the final decontamination, and lower l
radioactivity levels in the radwaste shipped off-site for burial.
2.
Final decontamination would include the removal of the reacter vessel, primary coolant piping, and steam generators for shipment to a licensed burial site.
The radioactive decay associated with long-term storage will 1
reduce tne quantity of airborne particulate that may be l
released to the environment during the cutting process.
3.
During the completed phase of the Decommissioning Program, nuclear fuel, radioactive liquids and pressurized gases, were removed from the site.
- Further, l
l piping penetrations into the containment structure have been sealed, except for the filtered vent installed in I
the equipment door.
The contaminated materials and systems outside the Exclusion Areas have been decontaminated or shipped off-site for licensed burial.
Consequently, the probability of a Design Basis Accident or a lesser nuclear related accident has been eliminated during the long-term storage phase of the Unit 1 l l
L___
F
.1 s
L
. Docket No. 171 s
License No. DPR-12 facllity.. Additionally,'the potential for a release of radioactive material to the environment is highly improbable.
4.
The numerous physical barriers surrounding the' residual L
reactivity preclude exposuie to the public and plant persont.e1.
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 &ccess ports have been sealed with shield plugs and blind flanges.
Three foot thick concrete beams have been placed over the sealed reactor vessel acces9 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 decontaminatfori 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. --_____. _-_- -_ __
i Docket No. 171
]
License No. DPR-12 1
v 1
1 These advanced techniques would further reduce r6diation i
1 exposures and radwaste quantities; Furth9r, deferral i
would be compatible with the anticipated extansion<of radwaste storage capabilities in the future.
6.
A chain link' fence encloses the Un5t 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 und&r the control of Units 2 and 3 station supervision.
The' physical barriers to unauthorized entrance into the facility are inspected sen.i-ann'ually to ensure that these barriers have not degraded.
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 ailborne particulate activity within the Unit 1 Exclusion Area.
A ventilation filter, installed in the containment structure for atmospheric pressure equalization, is checked semi-annually for the presence of airborne radioactive materials.
Additionally, a radiological - _ _ _ _ _ - -
J
- c 3 Docket No. 171
'T License No. DPR-12 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.
Insp?ctions 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 support facilities, and the backup radiochemistry counting facility, required by the Units 2 and 3 Emergency Preparedness Plan, and for classroom space, training simulator 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.
9.
The Units 2 and 3 emergency support facilities are located within 50 feet of the Unit 1 Exclusion Area.
' 1
Docket No. 171 u
b
-License No. DPR-12 r
L Extensive dismantling activities associated with final decontamination of the Unit 1 facility prior to the final. shutdown of Units 2 and 3 would be disruptive to those support activities.
't 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' L
- 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
]
I nomenclature, and (2) a change that constitutes an additional I
limitation, restriction, or control not presently included in the i
I 1.
?.
Docket No. 171
' Licence No. DPR-12
. technical specifications.- The revisions proposed by this Application' conform to one or tbe other of'these examples.
The prcposed changes do not involve a significant h'azards 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 and' Environmental Assessment-section of this Application, has eliminated the
' potential for a Design Bases Accident; (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 the 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 operation by allowing residual radioactivity to decay for at least 40 years following termination of power operations.
The additional inspection, reporting, and administrative controls proposed for the Technical Specifications assures that the facility will be 1 i
l Docket No. 171 License No. DPR-12 maintained in a condition that will have no impact on the health and safety of the public.
The Plant. Operating Review Comunittee and the Nuclear Review Board have reviewed these proposed changes and have concluded that they do not involve a significant hazards consideration, nor will they endanger the health and safety of the public.
I _
ENCLOSURE I 1)
Correspondence dated December 16, 1988, J. W. Gallagher, PECo to NRC 2)
Correspondence dated July 12, 1989, D. R. Helwig, PECo to NRC 1
._-____-______-_-_______-_-_-______-__-__-_______-______---_________-._-_-___-___--____-___--__-____._J
h i
J-PHILADELPHIA ELECTRIC COMPANY.
2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA 19101 (21s) sai.soon December 16,195]EF JOSEPH W. G ALLAGHER
. vie
- m...um Docket Nos. 50 m l U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555
SUBJECT:
~
Peach Bottom Atomic Power Station Unit 1 NRC Request for Information
REFERENCE:
- 1) Correspondence. dated September 7, 1988 P. B. Erickson, NRC, to W. M. Alden, PECo
- 2) Corresponded.ce dated November 15, 1988 J. W. Gallagher, PECo, to P. B. Erickson, NRC
- 3) Peach Bottom Atomic Power Station Unit 1 License Amendment Application filed March 4, 1987
Dear Mr. Erickson:
(
This letter provides information requested in reference (1) regarding the March 4, 1987 License Amendment Application (reference 3)).
The Application proposes a 40 year extension of the expiration date for the Peach Bottom Unit 1 porsession-only license.
Responses to the requested information are provided as follows:
1.a Recuest The Technical Specifications (TS) do not discuss controls or alarms with respect to intrusion of water into lower level spaces at Peach Bottom Unit 1 such as the containment sump.
TS should be proposed with respect to alarms for the detection of such water entry, limits on the water levels and actions to be taken in the event water levels exceed the TS limits.
A water level monitoring and alarm system should be installed if none exists.
1.a Resconse The current physical and radiological status of the Peach Bottom Unit I
1 decommissioned facility does not warrant the costs associated with the installation, maintenance and testing of a water detection system in the containment structure.
This conclusion is based on 1) the low
'c probability of significant ground water intrusion, 2) the insignificant contamination levels expected in the event water intrusion occurs and 3) the low probability that the accumulated water j
would exit the containment structure.
Surveillance and reporting I
svm xn--
i
[- '.
1
~.
Mr. P.1B. Erickson Page 2 provisions are in-place to detect any deviations from current condit,ionsf.to assure implementation'of appropriate corrective measures.
Further discussion is presented below.
The containment structure consists of a vertical cylindrical steel shell with ellipsoidal heads, top and bottom.
The thickness of the bottom head varies between 3/8 and S/8 inches.. The bottom head is embedded in concrete with approximately three feet of concrete on both sides of.the steel head (see figure 1).
The containment is inspected i
on a semi-annual basis and, to date, no water accumulation has been observed in the containment.
Considering the design of the containment structure and the absence of ground water intrusion in the past, the probability of significant inleakage of water is low.
Any ground water intrusion into the containment would not.
reach significant levels of contamination because significant contamination levels do not exist in the below grade region of the removed from the site during'g systems were drained and the fluids containment.
Fluid containin the decommissioning program, thus eliminating a potential source of contamination.
Removable surface contamination levels in accessible areas are less than 100 dpm.
The overall radiological condition of the facility has been stable since completion of decommissioning in 1978.
The contaminated vessels in the lower region of the containment have been removed with the j
exception of several small vessels associated with the chemical I
a cleanup system.
Radiation levels on these vessels are less than 1 mR/Hr on contact.
Drainage within containment is such that any ground water instrusion would drain to the containment sump without contacting these vessels and would be detected during periodic inspections.
It is highly improbable that the inleakage would find a flow path to exit the containment.
A radiological analysis will be performed, if there is sufficient water accumulation to obtain a sample.
The results of the analysis, along with an evaluation of the source of the water, would be reported to the NRC.
If contaminated water were to accumulate, corrective action would be taken to prevent an uncontrolled release.
1.b Request With respect to water entry, the licensee should provide an analysis of the below ground structures with respect to a loss of integrity thru metal corrosion or other mechanisms.
Is a cathodic protection system needed and is one maintained to reduce the likelihood of corrosion?
If so, specify the operating and maintenance requirements for the system.
1.b Resoonse The Peach Bottom Unit I containment vessel represents the only exclusion area below ground structure subject to possible corrosion.
A cathodic protection system for protection of this structure is in place, and its power supply is confirmed operable during the semi-annual inspection.
As stated in reference (2), a study will be
_______.____m._-__._-____m_.___m_-___-_-
I Mr., P. B. Erickson Pcga 3 i
performed, starting in early 1989, to assess the need for corrosion-protection; and if such nrotection is needed, the operating and l -
maintenance requirements will be identified.
The results of this study Will be submitted to the NRC by June 30, 1989.
l Request (2)
Limits on the release of radioactive effluents should be established with respect to 10 CFR 20 Appendix B Table II.
The following has been found acceptable for Humboldt Bay Unit 3:
a)
Liquid Effluents Radioactive waste discharges to offsite locations shall not exceed the limits given in 10 CFR 20, Appendix B, Table II, Column 2, on an instantaneous basis.
b)
Gaseous Effluents Gaseous ef?luents shall not result in offsite ground level i
concentre'. ions exceeding the limits given in 10 CFR 20, Appendix B, Table II column 1, on an instantaneous basis.
j l
1
Response
-The requested effluent limits will be submitted in an amended i
application within four months of NRC approv:1 of the response to the issue (s) identified in reference 1.
l l
Request (3)
Reporting requirements should be added to state that operations or ccnditions prohibited by the TS shall be reported in accordance with 10 CFR 50.73 (Licensee Event Reports).
I i
Response
The requested reporting requirement will'be submitted in an amended application within four months of NRC approval of the response to the i
issues identified in reference 1.
Request (4) necordkeeping requirements of (10 CFR 50.75(g)) of the new decommissioning rule of Jure 27, 1988 (53 FR 24051) should be added to the TS.
__w
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j i
y Paga.4 l
Mr1 P. B. Erickson Lo.
' ]
- Responsa _
j
. The re. quested recordkeeping requirements will be submitted in an amended application within four months of NRC approval of the response to the issues identified in reference 1.
1 1
Should you have'any questions regarding this matter, please j
do not hesitate to contact us.
i Very truly yours, UCB:mls Attachment
^
cc:
P..B.
Erickson, USNRC W. T. Russell, Administrator, Region I, USNRC T. P. Johnson,1USNRC Senior' Resident' Inspector T.
E. Magette, State of 14aryland J.
Urban, Delmarva Power J. T. Boettger,.Public Service Electric & Gas
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SECT. 7 -7 Peach Bottcm Atomic Power Station - Unit 1
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contairene.nt vessel Figure 1
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PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.
WAYNE PA 19087-5691 (2:51 sao sooo July 12, 1989' Docket No. 50-171
'U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station, Unit 1 NRC Request for Information
REFERENCE:
- 1) Correspondence dated September 7, 1988 P. B. Erickson, NRC, to W. M. Alden, PECo
- 2) Correspondence dated November 15, 1988 J. W. Gallagher, PECo, to P. B. Erickson, NRC
- 3) Peach Bottom Atomic Power Station, Unit 1 License Amendment Application filed March 4, 1987
- 4) Correspondence dated December 16, 1988, J. W. Gallagher, PECo to NRC J
Dear Sirs:
This letter provides a response to a request for information received from the NRC in reference correspondence (1) l regarding the March 4, 1987 License Amendment Application (reference 3).
The Application proposes a 40 year extension of the expiration date for the Peach Bottom Unit 1 possession only license.
Referenced correspondence (4) responded to requests for information except for the second part of request 1 in the NRC's letter.
This request and.our response are stated below.
Request With respect to water entry, the licensee should provide an analysis of the below ground structures with respect to a loss of Q
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\\' Dbcum:nt Control Desk July 12, 1989 i'
-Page 2
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integrity through metal.currosion or other mechanisms.
Is a hl
- cathodic protection system needed and is one maintained to reduce i
the likelihood of corrosion?
If so, specify the operating and maintenance requirements for the system.
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4 1
Response
1 The Peach Bottom Unit 1 containment vessel represents the.
3 only exclusion area below ground structure subject'to possible l
corrosion.
During the original construction of Unit 1, excavation was made to clean. sound rock.
Ground water levels were controlled to below the level of excavation and lean concrete was place? on top of the sound rock.
The steel containment shell was set and concrete was placed.to support the liner.
The minimum depth of concrete
.between the liner and the rock is 1 foot with the depth in most
{
places being approximately 3. feet.
Water stops are located at' concrete construction joints above elevation 110' - 6",
to prevent
' water instrusion.
Concrete was also placed'inside the curved liner bottom to create a bottom floor.
A drainage sump is located in the flo9r and is inspected on a regular basis.
As an additional measure, a ground level interceptor moat aurrounds the containment liner to trap and remove surface water runoff trying to seep between the liner and the concrete foundation.
This moat is covered to minimize the amount of water accumulated
.l from rain and snow.
When Peach Bottom Unit I was designed and constructed in the early 1960s the mechanisms of corrosion were not as widely I
understood as they are today.
The corrosion rate of steel in contact with concrete was generally assumed to be the same as for Steel in contact with soil.
Present' day information shows that steel embedded in concrete corrodes at a much slower rate than steel i
in' contact with soil.
Because of the lack of information on the corrosion rates of steel in the 1960s, a cathodic protection system was installed for the Peach Bottom Unit 1 containment.
I The existing cathodic protection system provides protective t
current to the containment liner as well as nearby underground I
piping.
The effect of this system is measured by three zinc reference electrodes.
The existing cathodic protection system is presently tested every six months.
PECo plans to continue operating
[
the rectifier to supply the currents, and the testing every six months to verify operation, as long as the system remains operational.
However, if the system should fail, PECo does not plan to'effect any major repairs to return the system to operation.
Cathodic protection of embedded steel (whether it is reinforcement bars or containment liners) in properly designed and I
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Documsnt Control Desk July 12, 1989 l
Page 3.
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constructed structures is normally not required because of the protective properties of the concrete.
In the akaline concrete environment, the steel quickly develops a passivating iron oxide film that prevents corrosion and makes. additional protection i
unnecessary.
High concentration of chloride or sulfates in the presence of oxygen and moisture may destroy the passivating film and initiate corrosion of the steel.
However, the integrity of the protective film is assured by completely encasing the steel in good quality concrete that is dense, impermeable and of sufficient cover to resist intrusion of harmful corrosive elements.
As long as the integrity of the concrete is maintained, corrosion of the embedded j'
steel is generally prevented.
o During initial plant construction in 1962, soil and water I
resistivity measurements were taken at various locations in the area i
of Unit 1.
The resistivity of both the water and soil are relatively high indicating that aggressively corrosive soil conditions are not.present at the site.
Additional testing also shows that chloride and sulfate levels are relatively low indicating that the soil is not aggressively corrosive.
This testing confirms that the two most harmful constituents to steel in concrete are present only in very low levels.
If Unit 1 was built today, a cathodic protection system would not likely be supplied.
There are no other mechanisms for failure of the containment structure that would allow for water instrusion.
The containment penetrations are located above ground except for three 2 i
inch pipe penetrations that exit at the 112 foot elevation, 4 feet below ground elevation.
These pipes exit into a concrete enclosed cavity that isolates the pipes from the underground environment.
The pipes were cut and capped several feet from the containment vessel during the decommissioning program.
There are no degradable materials between the pipe cap and the containment vessel.
j Conclusions 1.
The design of Unit 1 makes it very difficult for ground water to even reach the exterior of the containment liner to start the corrosion process.
The concrete layer between the rock and the containment liner serves as a barrier to prevent water migration to the liner shell.
2.
The Cathodic protection system, installed in 1964, continues to provide cathodic protection current to the concrete reinforcing bars and containment liner shell.
Zinc reference electrodes encased in the concrete during construction continue to indicate that cathodic protection potentials have been realized.
3.
Based on the present understandings of various corrosion mechanisms, the steel containment liner at Peach Bottom L
..LDocument' Control D3sk:
July 12, 1989 Page.4
.e-should not' corrode.under.the present environmental conditions erfany anticipated future conditions even
-i without an operating cathodic protection system..Should
.the~ existing cathodic protection system fail, PECo.does not plan to effectEany major repairs to return it to operation.
4.
' Inspections of the containment drain sump will detect any
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collection of water, whether from ground water intrusion or other scurces.
Very truly yours, D. R. Belwig Vice President Nuclear Services' Department Lcc:
W. T. Russell, Administrator, Region I, USNRC P. B. Erickson, USNRC T. P. Johnson, USNRC Senior Resident Inspector.
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ATTACHMENT 2 PEACH BOTTOM ATOMIC POWER STATION UNIT NO. 1 Docket No. 50-171 License No. DPR-12 LICENSE CONDITION CHANGES LIST OF ATTACHED PAGES 1
2 l
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fi, PHILADELPHIA ELECTRIC' COMPANY -
DOCKET NO. 50-171 PEACH BOTTOM ATOMIC POWER STATION UNIT 1 4.MENDMENT TO~ LICENSE 1.
Amendment No. 7 License No. DPR-12 1.
The Nuclear Regulatory Ccmmission (the Commission) has found that:
The application for amendment by Philadelphia Electric A.
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 CFR Chapter 1; The-facility will be maintained in conformity with the B.
and the' rules application, the provisions of the Act, and regulations ~of the' Commission; There is reasonable assurance:
(i) that the activities Li C.
. authorized by this amended license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; The licensee is technically and financially qualified.
D.
to engage in the activitics authorized by this amended license in accordance with the rules and regulations of the Commission; The licensee has satisfied the applicable provisions of E.
10 CFR Part 140, " Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; The issuance of this amended license will nor be F.
inimical to the common defense and security or to the health and safety of the public; and r
The possession and storage of byproduct material as G.
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.
Accordingly, License No. DPR-12, as amended, is hereby 2.
amended in its entirety to read as follows:
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A.
'_This amended license applies to the Peach Bottom' Atomic
. Power Station' Unit 1, a decommissioned high-temperature, gas-cooled demonstration power reactor and associated equipment (the facility) owned by.the Philadelphia Electric Company._ The facility is located at the licensee's site in York County, Pennsylvania,'
and is described in the application 1for.licenseLdated July 25, 1960, and amendments thereto including the 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 Part 50, " Licensing of Production and Utilization Facilities," to possess, but not ooerate, the reactor as a utilization facility.
(2)~ Pursuant to the Act and 10 CFR Part 30, " Licensing of Byproduct, Material," to possess, but not to separate,.such byproduct material as may have'been produced ~by operation of the_ facility.
C.
This license shall be deemed to contain and be subject to the conditions specified in Part 20, Section 30.34 of Part 30, Sections 50.54 and 50.50 of Part 50, 10 CFR Chapter I, and 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 below:
(1)
Philadelphia Electric Company shall not' reactivate the facility without prior approval of the Commission; (2)
Philadelphia Electric Company shall not dismantle or dispose of the facility without prior approval of the Commission.
(3)
Technical Specifications The Technical Specifications contained in Appendix A attached hereto (Designated " Change Pa. 20 to the Technical Specifications") are hereby incorporated in this license.
Changes therein may be made only when authorized by the Commission in accordance with the provisions of 10 CFR Part 50, Section 50.59.
D.
This amended license is effective as of the date of issuance and shall expire on
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ATTACHMENT 3 PEACH BOTTOM ATOMIC POWER STATION L.
UNIT NO. 1 Docket No. 50-171 License No. DPR-12 TECHNICAL SPECIFICATION CHANGES LIST OF ATTACHED PAGES 1-8
"