NRC-98-0027, Application for Amend to License DPR-6,modifying Sections F & I of Plant TS to Include Requirements for Control of Effluents,Dose Limits & Annual Reporting Per 10CFR50.36a

Application for Amend to License DPR-6,modifying Sections F & I of Plant TS to Include Requirements for Control of Effluents,Dose Limits & Annual Reporting Per 10CFR50.36a

ML20199G505
Person / Time
Site:	Fermi
Issue date:	01/28/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20199G510	List: ML20199H256 NRC-98-0027, Application for Amend to License DPR-6,modifying Sections F & I of Plant TS to Include Requirements for Control of Effluents,Dose Limits & Annual Reporting Per 10CFR50.36a
References
CON-NRC-98-0027, CON-NRC-98-27 NUDOCS 9802040290
Download: ML20199G505 (8)

Text

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, - Inouglas IL Glpwn sene.n n e ercanoon .a cene,aa.n Ielini C bl M Sif t h liiUP llW) , \t'Bln!!, \IK IWdll hlbh 1el. ;!l3 % f&l Iar 3lJ f.g 11U Detroit Edison January 28,1998 NRC 98-0027 U. S Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D. C. 20555

Reference:

1) Enrico Fermi Atomic Power Plant, Unit No.1 NRC Docket No. 5016 NRC License Number DPR 9

2) Detroit Edison Letter, NRC 96 0132, dated November 26,1996

3) NRC Letter," Applicability of Specific 10 CFR Requirements to Enrico Fermi Atomic Power Plant, Unit i Due to the Decommissioning Rule", dated June 25,1997

4) Detroit Edison Letter, NRC-98 0025, dated January 28,1998

Subject:

Application for a Technical Specification Change i

(License Amendment)-

Effluent Technical Snecifications The 1996 Decommissioning Rule revised 10 CFR 50.36a to apply to permanently shutdown reactor facilities. Detroit Edison cominunicated to the

[\ f NRC in meetings and correspondence (Reference 2) about the new rule's provisions, in Reference 3, the NRC stated that Detroit Edison should request an amendment to the Fermi 1 license to propose effluent Technical Specifications.

Pursuant to 10 CFR 50.90, Detroit Edison hereby proposes to amend Possession Only License DPR-9 by modifying Sections F and I of the Fermi 1 Technical Specifications to include requirements for control of effluents, dose limits and 9002040290 980'12F, PDR P

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USNRC NRC 98 0027 Page 2 annual reporting per 10 CFR 50.36a. Though 10 CFR 50, Appendix 1 applies only to light water reactors and so does not apply to Fenni 1, which was a liquid

, mual breeder reactor, the numerical guidelines proposed for inclusion in the Technical Specifications are based on Appendix 1.

The description and evaluation of the change are included in Enclosure 1.

Enclosure 2 contains the proposed revised Technical Specification pages.

Please note that Reference 4 is also a proposed Technical Specification change that affects page 5 of the Technical Specifications.

Detroit Edison requests the NRC approve the amendment with an implementation period of"within 60 days" to allow final approval of procedure changes required to implement the change.

Detroit Edison has evaluated the proposed change against the criteria of 10 CFR 50.92 and detennined that No Significant 11azards Consideration is involved. This evaluation is included in Enclosure 1.

The Fermi 1 Review Committee has reviewed and approved this Technical Specification change request. In accordance with 10 CFR 50.91, Detroit Edison is providing a copy of this letter to the State of Michigan, if there are any questions, please contact Lynne Goodman, Director Fermi 1 at 734 586-1205.

Sincerely, l

Enclosures ec: A.B. Beach S.W. Brown G.A. liarris J.E, llouse, NRC Region III D.R. Ilahn (State of Michigan)

, -USNRC-NRC 98 0027 i Page 3 1, DOUGLAS R. GIPSON, do hereby afYimi that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

DOtJGLAS'R. GIPSON Senior Vice President On this MI - day of _ ff /////A * ,1998 before me personally-appeared Douglas R Gipson, $ing f1 i dul// worn and says that he executed the foregoing as his free act and deed.

A? wild-Abt//Ku Eotary Public

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, - USNRC NRC 98 0027

- Page 4 bec: P.J. Borer P. Fessler D.R. Gipson L.S. Goodman L.K. Layton J.E. Moyers R.J. Beaudry J.E. Conen J. Couillard R.R. Eberhardt, Jr.

W.D. Gilbert R.A. Janssens E.F. Kokosky R. Laubenstein E.F. Madsen -

R.L. Matthews R. McLenon J.E. Meyers R.A. Newkirk W.T. O'Connor, Jr.

E.M. Page E.M. Wilds D.R. Williams Information Management (116 NOC) . Fermi 1 Records

- NRR Chron File (Licensing)

NRC Notebook (Fermi 1) 6

4 Enclosure 1

. NRC 98'0027 Page1 ENCL,OSURE 1 DESCRIPTION OF PROPOSED TECilNICAL SPECIFICATION C:!ANGE and NO SIGNIFICANT HAZARDS CONSIDERATION REVIEW Enrico Fermi Atomic Power Plant, Unit 1 NRC Docket No. 5016

, NRC License NO. DPR 9 i

Enctoriure i

. NRC 9810027 Page 2 INTRODUCTIOE ne 1996 Decornmissioning Rule revised 10 CFR 50.36a to make it applicable to permanently shutdown reactors. In Reference 2, Detroit Edison submitted its position as to w hy no changes would be needed to implement provisions of 10 CFR 50.36a. In Reference 3, the NRC stated that 50.36a is applicable to Fermi 1 and that Detroit Edison is required to have ef11uent Technical Specifications and should request an amendment to its Fermi 1 license. The NRC letter also discussed that since the 1996 rule made Appendix I numerical guides applicable to plants in decommissioning, if Detroit Edison proposes to use numerical guidelines different from thase set forth in Appendix 1,it should propose Fermi l specific guidance for NRC consideration. In a follow up public meeting on July 15,1997, the Detroit Edison representative discussed that currently no radioactive effluents are being released from Fermi 1 and there is not a ftmetional installed system to make such releases. It would be difficult to write a Technical Speci0 cation or procedure for a system that does not currently exist, so the plan would be to prepare a Technical Specification requiring that the release capability and procedure will be developed at the time releases are planned. A NRC representative agreed it was not the NRC intent to require installation of a discharge system at this time. Also, at the meeting, the Detroit Edison representative discussed that 10 CFR 50, Appendix 1, specifically applies to light water reactors and so does not apply to Fermi 1, which was a liquid metal cooled reactor. The NRC representatives discussed that Appendix 1 contains established criteria, Detroit Edison must propose some effluent criteria and the NRC will review what is proposed.

This amendment request proposes effluent Technical Specifications to meet 10 CFR 50.36a and the NRC position stated in Reference 3. Section F, currently entitled " Waste Disposal Surveillances," will be renamed " Waste Disposal and Radioactive Effluents." The modified section will include requirements to have a functional waste disposal system, with monitoring and procedures, prior to commencing planned radioactive liquid or gaseous effluent discharges; an efiluent dose limit matching the numerical limit in 10 CFR 20.1301; guidelines using criteris from 10 CFR 50, Appendix 1; that the calculational method for performing dose calculations be developed prior to commencing planned discharges; and that calculations be performed for any year in which discharges of radioactive effluents occur. Section 1.8 will be revised to include the annual reporting of effluents among the reporting requirements.

DISCUSSION The proposed amendment maintains all curreat requirements in Section F on monitoring liquid effluents, surveillances of the radiation monitor used foi any discharges, and instantaneous limits for liquid and gaseous eftluents. The additional requirementi implement the requirements of 10 CFR 50.36a applicable to Fermi 1. The proposed wording will require ' hat controls and procedures for waste disposal be pmvided before any planned discharges. This is appropriate for the current status of the facility, since the waste discharge systems have not been used br many years and are not functional or intact. The establishment of the numerical guidelines will insure that modifications installed to perform discharges will have to ensure that the established criteria are met when any discharges commence. The numerical limit in 10 CFR 20.1301 for dose due to a facility is added to Section F, as are criteria based on 10 CFR 50, Appendix 1. Though Appendix 1 does not apply to liquid metal reactors, the numerical guidelines are previously accepted guidelines and so Detroit Edison decided to use them in this proposed amendment.

Aspects involving operational ficxibility from 10 CFR 50.36a or Appendix 1 are not proposed, since Fermi 1 is permanently shutdown. The proposed word lng is more concise than Appendix 1 wording, but the numerical criteria matches, ne format used fits inta the Fermi 1 Technical Specifications.

Enclogure i

. NRC 98'0027 Page 3 The proposed amendment requires the dose calculation method used to show adherence to effluent criteria be developed prior to commencing planned discharges. This will ensure the method is in place before it is needed, but also allow it to be developed based on the provided emuent pathway.

Calculations will be required in years that discharges of radioactive emuents occur. If emuents are not being released, then there would be nothing to calculate. This philosophy matches that in the approved Fermi ! Environmental Surveillances, Environmental Surveillances are not required until discharge of

1. quid radiological emuents is commenced.

Lastly, the proposed amendment adds a requirement for an annual effluent report to Section 1.8. This report must be submitted such that the time between reports does not exceed 12 months. The specification does not name the re;. ort, so that this effluent report could be combined with the aircady required annual repai or be a separate report.

A typographical erTor in section numbering is being co Tected by this submittal on prge 6 of the Technical Specifications.

filGNIFICANT II AZARDS CONSIDERATION in accordance with 10 CFR 50.92. Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that conduct of activities in accordance with the proposed amendment would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.

To determine whether a significant hazards is posed by the proposed amendment, three questions are answered.

1) Does the proposed change significantly increase the probability or consequences of an accident previously evaluated?

No, the proposed submittal establishes additional requirements and limits on radioactive effluent releases. No existing requirements are deleted. For these reasons, this proposed change will not significantly increase the probability or consequences of an accident at Fermi 1.

2) Will the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?

No, the addition of requirements for radioactive emuent releases will not cause a new kind of accident. The additional requirements involve having a functional waste system with procedures, submitting an annual report, and restricting the potential dose to thw public from effluents. These changes, in themselves, do not require a different type of operation of systems. Any new system installed to enable future discharges will be evaluated at the time of design.

3) Will the proposed change significantly reduce the margin of safety at the facility?

No, adding new requirements for radioactive emuents will not decrease the margin of safety. Since no existing requirements are being climinated, this change will not reduce the margin of safety of the facility.

7 Enclopure i

. NRC 98:0027

.Page 4 I

ENVIRONMENTALIMPAct Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of 10 CFR $1.22 for environmental considerations. 'Ihe proposed changes do not involve a significant

-' hazards consideration, nor significantly change the types or increar,e the amounts of eilluents that may be released off site, nor bercase individual or cumulative occupational radiation exposures. Based on the foregoing. Detroit Editon concludes that the proposed Technical Specifications meet the crite:ia given in 10 CFR $1.22 (c)(9) for a ettesorical exclusion from the requirements for an Environmental Impact Statement.

CONCLUSION Based on the evaluations above: (1) there is e reasonable assurance that the health and safety of the public will not be endangered by conduct of activities in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the proposed amendment will not be inimical to the common defense and security c.r the health and safety of the public, 4

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