ML23265A150

License Amendment Request – Revise a License Condition and Certain Technical Specifications to Remove Restrictions in Support of Decommissioning Activities

ML23265A150
Person / Time
Site:	Peach Bottom  (DPR-012)
Issue date:	09/22/2023
From:	David Helker Constellation Energy Nuclear Group
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML23265A150 (1)

Text

200ExelonWay KennettSquare,PA19348 www.constellationenergy.com 10 CFR 50.90 September 22, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 1 Facility Operating [Possession Only] License No. DPR-12 NRC Docket No. 50-171

Subject:

License Amendment Request - Revise a License Condition and Certain Technical Specifications to Remove Restrictions in Support of Decommissioning Activities In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Facility Operating [Possession Only] License No. DPR-12 for Peach Bottom Atomic Power Station (PBAPS), Unit 1, to modify a License Condition and certain Technical Specifications (TS) to remove restrictions that currently limit decommissioning activities/efforts.

The proposed amendment would modify License Condition 2.C(1) and TS Sections 1.0, 2.1(b)1, 2.1(b)6, 2.3(b)1, and 2.3(b)2 to remove restrictions that currently preclude decommissioning activities/efforts without prior NRC approval. The proposed changes would amend the noted License Condition and TS to follow the Post-Shutdown Decommissioning Activities Report (PSDAR) process as governed by 10 CFR 50.82, "Termination of license,"

and the guidance stipulated in Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report."

The purpose of the PSDAR is to provide the U.S. Nuclear Regulatory Commission (NRC) and the public with a general overview of the licensees proposed decommissioning activities and to inform the NRC staff of the licensees expected activities and schedule so that the staff can plan for inspections and make decisions about its oversight activities. The PSDAR is also a mechanism that informs the public of the proposed decommissioning activities before the conduct of those activities.

Constellation

U.S. Nuclear Regulatory Commission License Amendment Request Revise a License Condition and Certain Technical Specifications in Support of Decommissioning Activities Docket No. 50-171 September 22, 2023 Page 2 CEG has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92.

The proposed changes have been reviewed by the PBAPS Plant Operations Review Committee in accordance with the requirements of the CEG Quality Assurance Program.

This amendment request contains no regulatory commitments. provides the evaluation of the proposed changes. Attachment 2 provides a copy of the mark-ups to the License Condition. Attachment 3 provides a copy of the mark-ups to the TS pages.

CEG requests approval of the proposed amendment by September 22, 2024, in order to further facilitate the decommissioning strategy for PBAPS, Unit 1. Upon NRC approval, the amendment shall be implemented within 60 days of issuance.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), CEG is notifying the Commonwealth of Pennsylvania and State of Maryland of this request by transmitting a copy of this letter along with the Attachments to the designated State Officials.

Should you have any questions concerning this submittal, please contact Richard Gropp at 1-267-533-5642.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22nd day of September 2023.

Respectfully, David P. Helker Sr. Manager, Licensing Constellation Energy Generation, LLC Attachments:

1.

Evaluation of Proposed Changes 2.

Mark-up of Proposed License Condition Page 3.

Mark-up of Proposed Technical Specifications Pages cc:

w/ Attachments Regional Administrator - NRC Region I NRC Senior Resident Inspector - PBAPS NRC Project Manager, NMSS - PBAPS Unit 1 NRC Project Manager, NRR - PBAPS W. DeHaas, Pennsylvania Bureau of Radiation Protection S. Seaman, State of Maryland

ATTACHMENT 1 License Amendment Request Peach Bottom Atomic Power Station, Unit 1 Docket No. 50-171 EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request - Revise a License Condition and Certain Technical Specifications to Remove Restrictions in Support of Decommissioning Activities 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 1 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Facility Operating [Possession Only] License No. DPR-12 for Peach Bottom Atomic Power Station (PBAPS), Unit 1 to modify a License Condition and certain Technical Specifications (TS) to remove restrictions that currently limit decommissioning activities/efforts.

PBAPS, Unit 1 permanently ceased operations on October 31, 1974, and is presently in SAFSTOR. Decommissioning activities which resulted in the present facility status were completed in February 1978. The previous decommissioning activities entailed removal of all plant-generated radioactive material outside of an Exclusion Area. The Exclusion Area includes the Unit 1 containment building, fuel storage pool, and liquid waste system basement. All PBAPS, Unit 1 spent fuel was removed from the site and shipped to a DOE facility in Idaho.

PBAPS, Unit 1 has been monitored and controlled in SAFSTOR in accordance with the Facility Operating License, Technical Specifications as amended, and Decommissioning Plan (reference letter dated May 15, 1975). For licensees that submitted a Decommissioning Plan prior to August 28, 1996, as is the case for PBAPS, Unit 1, the U.S. Nuclear Regulatory (NRC) considers the Decommissioning Plan and the associated environmental review to be the Post-Shutdown Decommissioning Activities Report (PSDAR).

The proposed changes would amend the applicable License Condition and TS to eliminate legacy restrictions and adopt requirements that more closely align with the current standards and guidance that govern decommissioning activities/efforts as specified in 10 CFR 50.82.

of this submittal provides the proposed mark-ups for the License Condition page that highlight the proposed changes. Attachment 3 provides the proposed mark-up pages for the affected TS pages that highlight the proposed changes.

2.0 DETAILED DESCRIPTION The proposed amendment modifies License Condition 2.C(1) and TS Sections 1.0, 2.1(b)1, 2.1(b)6, 2.3(b)1, and 2.3(b)2 to remove restrictions that currently preclude decommissioning activities/efforts without prior NRC approval. The proposed changes would amend the noted License Condition and TS to follow the PSDAR process as governed by 10 CFR 50.82, "Termination of license," and the guidance stipulated in Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report." These proposed changes facilitate CEGs ability to move forward with the PBAPS, Unit 1, decommissioning strategy.

Currently, License Condition 2.C(1) stipulates the following:

Current License Condition 2.C(1)

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 2 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change CEG proposes to modify the License Condition as described below to remove the restrictions that currently exist limiting the ability to further conduct decommissioning-related activities/efforts at PBAPS, Unit 1.

Proposed License Condition 2.C(1)

In addition, CEG proposes to modify TS Sections 1.0, 2.1(b)1, 2.1(b)6, 2.3(b)1, and 2.3(b)2 to remove the TS restrictions that currently preclude decommissioning activities/efforts without first obtaining prior NRC approval. The proposed changes to the affected TS sections are listed below depicting the highlighted proposed changes.

C.

This license shall be deemed to contain and be subject to the conditions specified in Part 20, Section 30.34 of Part 30, Section 50.59 of Part 50, 10 CFR Chapter I, and to all applicable provisions of the Act and to the rules, regulations, and orders of the NRC now or hereafter in effect and is subject to the additional conditions specified below:

(1)

Constellation Energy Generation, LLC shall not dismantle or dispose of the facility without prior approval of the NRC.

(2)

Technical Specifications The Technical Specifications contained in Appendix A as revised through Amendment No. 17 are hereby incorporated in this license. The licensee shall maintain the facility in accordance with the Technical Specifications.

C.

This license shall be deemed to contain and be subject to the conditions specified in Part 20, Section 30.34 of Part 30, Section 50.59 of Part 50, 10 CFR Chapter I, and to all applicable provisions of the Act and to the rules, regulations, and orders of the NRC now or hereafter in effect and is subject to the additional conditions specified below:

(1)

(2)

Constellation Energy Generation, LLC shall Rel disFRaAtle er disJ'lese ef Technical Specifications The Technical Specifications contained in Appen A as revised through Amendment No. 17 are hereby incorporated in this *cense. The licensee shall maintain the facility in accordance with the Tee ical Specifications.

maintain and control the facility in accordance with the Defueled Safety Analysis Report (DSAR) and Post-Shutdown Decommissioning ActIvitIes Report (PSDAR). The licensee may: 1) make changes to the facility or procedures as described in the DSAR or the PSDAR and, 2) conduct tests, or experiments not described in the DSAR or PSDAR, without prior NRC approval, provided the requirements of 10 CFR 50.59 and 10 CFR 50.82(a)(6) and (7) are satisfied.

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 3 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change TS Section 1.0 TS Section 2.1(b)1 TS Section 2.1(b)6 1.0 LOCATION AND SITE The Peach Bottom Atomic Power Station (PBAPS) Unit No. 1 is located in Peach Bottom Township, Pennsylvania, in the western shore of the Conowingo Pond at the mouth of Rock Run Creek on a site owned by Constellation Energy Generation, LLC. These Technical Specifications apply to PBAPS Unit No.1. The PBAPS Unit No. 1 Containment Building, Spent Fuel Pool Building, and Radwaste Building shall be secured in accordance with the PBAPS Security Plan and controlled in accordance with the PBAPS Radiological Protection Program. These Teehnieal Speeifieations apply to the PB1\PS Unit No. 1 E>Eelusion Area.

T-he E>Eclusion Area shall coA£.i.st of an area within lhe PE!APS 111hich is enclosed within locked barriers, and contains the Containment Vessel, Spent Fuel Pool Building and Radwaste Building. The only aclivity carried on within the Exch,1sion Area shall be ro1.1line

.ind emergency im;pecliom;.ind niainlen.ince.i:;;:;;oci.ited with the po:;;:;;e:;;:;;ion of the deco111111issioned PDAPS Unit No. 1. Peach Bottom Atomic Power Station, Units 2 and 3 are also located on the site.

2.0 ADMINISTRATIVE AND PROCEDURAL SAFEGUARDS 2.1 Administrative Organizations and Controls (a)

Plant Manager The Peach Bottom Plant Manager shall have the responsibility for administration of all Unit No. 1 functions.

The approved Post-Shutdown DecommiSS10ning Activibes Report (PSOAR) supplements the Defueled Safety Analysis Report (DSAR) and the licensee may 0) make changes in the faality or procedures as descnbed in the DSAR or the PSDAR and (ii) conduct tests, or experiments not descnbed in the OSAR or PSDAR. without poor NRC approval, provided the requirements of 10 CFR 50.59 and 10 CFR 50.82(a)(6) and (7) are satisfied ~

¥ 1h9R opened lo prGvide egress fGr inspecUons, sun*eys and repairs, the fGllo>Ning exclu&ion area baRier& &hall be maintained locked:

i - viii. Deleted The-gale in the Exclusion Area f~e..loca~e the containment personrienle lock al.E,levalion 116' -0*.

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 4 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change TS Section 2.3(b)1 and 2.3(b)2 Further justification associated with the proposed changes is provided in Section 3.0, "Technical Evaluation," below.

3.0 TECHNICAL EVALUATION

The proposed changes modify License Condition 2.C(1) and TS 1.0, 2.1(b)1, 2.1(b)6, 2.3(b)1, and 2.3(b)2 to revise legacy restrictions in the noted License Condition and TS and establish provisions consistent with the Post-Shutdown Decommissioning Activities Report (PSDAR) process as governed by 10 CFR 50.82, Termination of license, and the guidance stipulated in Regulatory Guide (RG) 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report," to support the PBAPS, Unit 1 decommissioning strategy.

The purpose of the PSDAR is to provide the U.S. Nuclear Regulatory Commission (NRC) and the public with a general overview of the licensees proposed decommissioning activities and to

3.

4.

5.

6.

7.

2.3 Deleted Security of the facillty shall be included as a part of the Peach Bottom Atomic Power Station security plan.

In the event of a Probable Maximum Flood, the personnel access door at elevation 116'--0" shall be opened in accordance with the Peach Bottom Atomic Power station Umts 2 and 3 flood procedures.

Deleted If &RIP/ amUgr \\\\1Qr1( iR 11:!e ooRtrnlled area gf 11:!e cgRtainFRORI sJ:igyld be necessary, radiation level and airbome activity surveys sball be perfolJlled prior lg beginAiAg \If-Ork aAd all work &Rall be performed llAder CQAIF9IS, as apprgpriale, lg FRiAimize 11:!e i:adiati9A 8Xp&Sllr& gf per:5gnAOI aAd lg pre>r&AI 11:!e release gf radjgacli¥ity jg 11:19 9R>JiFOOFR9At All radiation surveys, tests, counting work and radioactive effluent controls, and radiation exposure control measures shall be performed in accordance with written instructions and procedures that conform with the requirements of the Peach Bottom Atomic Power Station Unrts 2 and 3 radiatiOn control procedures.

Periodic Inspections The following inspections of the Unit No. 1 facility shall be performed by personnel knowledgeable in nuclear radiation monitoring and with the radiological hazards associated with Unit No. 1. Records of these inspections shall be maintained on file.

(a)

Deleted (b)

Semi-Annual Inspection

1.

2.

Deleted Cer,dttet s,r, ir,speetior, of e,celttsior, srea bsffief'S lo er,sttre lhsl IJ:te iAlegFity of IJ:te eaffier, am! IJ:teIr loekiAg a~1mral!:ls are iAtael.

Conduct a radiological survey of the accessible areas of the conta nment bu Id ng, spent fuel pool building and radwaste buIldIngexclusiOD area.

The survey shall indude radiation levels and surface contamination as well as air particulate activity.

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 5 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change inform the NRC staff of the licensees expected activities and schedule so that the NRC can plan for inspections and make decisions about its oversight activities. The PSDAR is also a mechanism that informs the public of the proposed decommissioning activities before the conduct of those activities.

As defined in 10 CFR 50.2, "decommission" means to remove a facility or site safely from service and reduce residual radioactivity to a level that permits either:

(1) Release of the property for unrestricted use and termination of the license; or (2) Release of the property under restricted conditions and termination of the license.

For licensees that submitted a decommissioning plan prior to August 28, 1996, as is the case for PBAPS, Unit 1, the NRC considers the Decommissioning Plan and the associated environmental review to be the PSDAR submittal (i.e., as noted under 10 CFR 50.82, "Termination of License").

Decommissioning plans normally contain sufficient information to satisfy the requirements of the PSDAR. Licensees that have an approved Decommissioning Plan must submit an update for activities not contemplated in the Decommissioning Plan to comply with 10 CFR 50.82(a)(7).

The NRC has encouraged licensees to replace legacy Decommissioning Plans, which was updated for PBAPS, Unit 1 (reference letter dated May 15, 1975), with a PSDAR update that uses the format and content as specified in RG 1.185. As such, the updated PSDAR must contain a description of the planned decommissioning activities along with a schedule for their accomplishment, a discussion that provides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmental impact statements, and a site-specific Decommissioning Cost Estimate (DCE), including the projected cost of managing irradiated fuel.

Since PBAPS, Unit 1, currently has a Decommissioning Plan/PSDAR, an updated PSDAR will be submitted after approval of this licensing action and utilized as the process to describe and control the associated decommissioning strategy. During this interim period, PBAPS, Unit 1, will continue to be maintained in the current SAFSTOR condition. Any changes that may be necessary to support decommissioning will continue to be evaluated in accordance with the requirements of 10 CFR 50.82.

The Exclusion Area described in the Decommissioning Plan for PBAPS, Unit 1, was established to ensure specific plant areas are physically controlled via locked barriers to limit unauthorized access into the areas. The proposed changes to the TS replace the TS specified locked barriers with programmatic controls of the radiological buildings, Containment Building, Spent Fuel Pool Building, and Radwaste Building, in accordance with the governing Physical Security Plan and Radiological Protection Program to ensure access is limited to authorized personnel only.

Any changes to the Defueled Safety Analysis Report (DSAR) that may be necessary to support this licensing action will continue to be evaluated in accordance with the requirements of 10 CFR 50.59 and reflected in the DSAR as updated in accordance with the requirements of 10 CFR 50.71(e). The proposed changes to the noted License Condition and TS require prior NRC approval and are considered necessary since they restrict the ability to transition to an updated PSDAR as described in RG 1.185 to support future decommissioning activities.

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 6 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.82, "Termination of license" For power reactor licensees who, before the effective date of this rule, either submitted a decommissioning plan for approval or possess an approved decommissioning plan, the plan is considered to be the PSDAR submittal required under paragraph (a)(4) of this section and the provisions of this section apply accordingly.

Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors" This regulatory guide, in conjunction with others, describes methods and procedures that are acceptable to the NRC for implementing the requirements of the 1996 rulemaking clarifying the regulations for decommissioning nuclear power facilities relating to the initial activities and the major phases of the decommissioning process.

Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report" This regulatory guide identifies the type of information that the post-shutdown decommissioning activities report (PSDAR) must contain and establishes a standard format for the PSDAR that the U.S. Nuclear Regulatory Commission (NRC) staff considers acceptable. The purpose of the PSDAR is to provide the NRC and the public with a general overview of the licensees proposed decommissioning activities and to inform the NRC staff of the licensees expected activities and schedule so that the staff can plan for inspections and make decisions about its oversight activities.

The PSDAR is also a mechanism that informs the public of the proposed decommissioning activities before the conduct of those activities.

4.2 Precedent There was no specific precedent identified related to the proposed changes for PBAPS, Unit 1; however, other licensees facilities that have permanently ceased operations and are in the process of decommissioning established provisions to comply with 10 CFR 50.82 requirements.

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG), proposes changes to a License Condition and certain Technical Specifications (TS) of the Facility Operating [Possession Only] License No. DPR-12 for Peach Bottom Atomic Power Station (PBAPS), Unit 1.

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 7 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change The proposed amendment would modify License Condition 2.C(1) and TS Sections 1.0, 2.1(b)1, 2.1(b)6, 2.3(b)1, and 2.3(b)2 to remove restrictions that currently preclude decommissioning activities/efforts without prior NRC approval. The proposed changes would amend the noted License Condition and TS to follow the Post-Shutdown Decommissioning Activities Report (PSDAR) process as governed by 10 CFR 50.82, "Termination of license," and the guidance stipulated in Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report."

PBAPS, Unit 1 permanently ceased operations on October 31, 1974, and is presently in SAFSTOR. Decommissioning activities which resulted in the present facility status were completed in February 1978. The previous decommissioning activities entailed removal of all plant-generated radioactive material outside of an Exclusion Area. The Exclusion Area includes the Unit 1 containment building, fuel storage pool, and liquid waste system basement. All PBAPS, Unit 1 spent fuel was removed from the site and shipped to a U.S.

Department of Energy (DOE) facility in Idaho. PBAPS, Unit 1 has been monitored and controlled in SAFSTOR in accordance with the Facility [Possession Only] Operating License, Technical Specifications as amended, and Decommissioning Plan.

CEG has evaluated the proposed changes, using the criteria in 10 CFR 50.92, "Issuance of amendment," and has determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed changes would modify License Condition 2.C(1) and TS Sections 1.0, 2.1(b)1, 2.1(b)6, 2.3(b)1, and 2.3(b)2 to remove current restrictions that preclude decommissioning activities/efforts without prior NRC approval. The proposed changes would eliminate legacy restrictions that currently exist in the noted License Condition and TS and revise the documents to more closely align with the current requirements and standards that govern decommissioning under 10 CFR 50.82.

PBAPS, Unit 1 is permanently shut down and in a SAFSTOR condition and all fuel was removed from the facility and shipped to an offsite U.S. Department of Energy (DOE) location in Idaho. Since PBAPS, Unit 1 is in SAFSTOR with all fuel removed, those accidents (i.e., Design Basis Accidents) and other accident transients that would need to be considered for operating plants no longer apply.

The proposed changes do not make any physical changes to facility Structures, Systems, or Components (SSC); therefore, the proposed changes have no adverse effect on maintaining the facility. The facility remains as described and analyzed in the Defueled Safety Analysis Report (DSAR).

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 8 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes would modify License Condition 2.C(1) and TS Sections 1.0, 2.1(b)1, 2.1(b)6, 2.3(b)1, and 2.3(b)2 to remove current restrictions that preclude decommissioning activities/efforts without prior NRC approval. The proposed changes would eliminate legacy restrictions that currently exist in the noted License Condition and TS and revise the description to more closely align with the current requirements and standards that govern decommissioning under 10 CFR 50.82.

PBAPS, Unit 1 is permanently shut down and in a SAFSTOR condition and all fuel was removed from the facility and shipped to an offsite DOE location in Idaho.

The facility will remain as described and analyzed in the DSAR. Those accidents (i.e., Design Basis Accidents and other transients) evaluated for operating plants no longer apply for PBAPS, Unit 1. The proposed changes do not alter the plant configuration (i.e., no new or different type of equipment is being installed) or require any changes in how the facility is currently being maintained. The proposed changes do not make any physical changes to facility Structures, Systems, and Components (SSCs). The proposed changes will continue to assure that the facility is maintained to control the potential release of any radioactive material.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No The proposed changes would modify License Condition 2.C(1) and TS Sections 1.0, 2.1(b)1, 2.1(b)6, 2.3(b)1, and 2.3(b)2 to remove current restrictions that preclude decommissioning activities/efforts without prior NRC approval. The proposed changes would eliminate legacy restrictions that currently exist in the noted License Condition and TS and revise the description to more closely align with the current requirements and standards that govern decommissioning under 10 CFR 50.82.

PBAPS, Unit 1 is permanently shut down and in a SAFSTOR condition and all fuel was removed from the facility and shipped to an offsite DOE location in Idaho.

The facility will remain as described and analyzed in the DSAR. Since PBAPS,

License Amendment Request Revise a License Condition and Certain Technical Specifications Page 9 of 9 in Support of Decommissioning Activities Docket No. 50-171 Evaluation of Proposed Change Unit 1 is in SAFSTOR with all fuel removed, those accidents (i.e., Design Basis Accidents) and other accident transients that would require evaluation for operating plants no longer apply.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above evaluation, CEG concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above: 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 2) such activities will be conducted in compliance with the Commission's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

PBAPS, Unit 1 is currently in SAFSTOR and all fuel has been removed from the site.

CEG has determined that the proposed amendment would not change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation." Therefore, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," paragraph (c)(9).

Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

10 CFR 50.82, "Termination of license" Regulatory Guide 1.185, "Standard Format and Content for Post-Shutdown Decommissioning Activities Report" Regulatory Guide 1.184, "Decommissioning of Nuclear Power Reactors" Philadelphia Electric Company letter to the U.S. Nuclear Regulatory Commission -

"Revisions to Decommissioning Plan and Safety Analysis Report," dated May 15, 1975

ATTACHMENT 2 License Amendment Request Peach Bottom Atomic Power Station, Unit 1 Docket No. 50-171 License Amendment Request - Revise a License Condition and Certain Technical Specifications to Remove Restrictions in Support of Decommissioning Activities Mark-up of Proposed License Condition Page Unit 1 - License Page



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maintain and control the facility in accordance with the Defueled Safety Analysis Report (DSAR) and Post-Shutdown Decommissioning Activities Report (PSDAR). The licensee may: 1) make changes to the facility or procedures as described in the DSAR or the PSDAR and, 2) conduct tests, or experiments not described in the DSAR or PSDAR, without prior NRC approval, provided the requirements of 10 CFR 50.59 and 10 CFR 50.82(a)(6) and (7) are satisfied.

ATTACHMENT 3 License Amendment Request Peach Bottom Atomic Power Station, Unit 1 Docket No. 50-171 License Amendment Request - Revise a License Condition and Certain Technical Specifications to Remove Restrictions in Support of Decommissioning Activities Mark-up of Proposed Technical Specifications Pages Unit 1 Page 1 Page 2 Page 3 Page 4

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