NRC-98-0128, Rev to 980128 Application for Amend to License DPR-9, Revising TS to Implement Provisions of 1996 Decommissioning Rule,Including Requirements for Control of Effluents,Dose Limits & Annual Reporting of 10CFR50.36a

Rev to 980128 Application for Amend to License DPR-9, Revising TS to Implement Provisions of 1996 Decommissioning Rule,Including Requirements for Control of Effluents,Dose Limits & Annual Reporting of 10CFR50.36a

ML20237E894
Person / Time
Site:	Fermi
Issue date:	08/26/1998
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20237E896	List: ML20237E898 NRC-98-0128, Rev to 980128 Application for Amend to License DPR-9, Revising TS to Implement Provisions of 1996 Decommissioning Rule,Including Requirements for Control of Effluents,Dose Limits & Annual Reporting of 10CFR50.36a
References
CON-NRC-98-0128, CON-NRC-98-128 NUDOCS 9809010273
Download: ML20237E894 (9)

Text

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Ikniglas R. Gipson Senior Vice President. Nuclear Generation Ferrni 2 l

6400 North Dixie llay, Newport, Michigan 48166 j

l Tel:313M6.6201 Fax:3135m.4172 l

Detroit Edison August 26,1998 l

NRC-98-0128 l

U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D. C. 20555

References:

1) Enrico Fermi Atomic Power Plant, Unit No.1 NRC Docket No. 50-16 NRC License Number DPR-9 j

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2) Detroit Edison Letter, NRC-98-0027, dated January 28,1998

3) Detroit Edison Letter, NRC-96-0132, dated November 26,1996 l

4) NRC Letter," Applicability of Specific 10 CFR l

Requirements to Enrico Fermi Atomic Power Plant, Unit 1 Due to the Decommissioning Rule", dated l

June 25,1997

5) Detroit Edison Letter, NRC-98-0025, dated January 28,1998 l/

Subject:

Revised Application for a Technical Specification Change (License Amendment)- Effluent Technical Specifications The 1996 Decommissioning Rule revised 10 CFR 50.36a to apply to permanently shutdown reactor facilities. Detroit Edison submitted proposed effluent Technical l

Specifications in Reference 2 to implement provisions in the rule. The proposed i

license amendment included requirements for control of effluents, dose limits, and annual reporting per 10 CFR 50.36a. Sections F and I of the Fermi 1 Technical Specifications were to be modified. The proposed amendment was discussed with the NRC staffin a public meeting on July 28,1998. Detroit Edison asked that the

bd NRC put their review on hold while a revised request was submitted. The main l

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PDR j

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USNRC-NRC-98-0128 Page 2 reason for this change is the detection of tritium in residual sodium at Fermi 1 and a determination that tritium should be specifically identified in the effluent Technical Specifications to clarify the need for appropriate tritium monitonng.

This submittal replaces the Reference 2 submittal. The description and evaluation of the proposed Technical Specification changes are included in Enclosure 1. Enclosure 2 contains the proposed revised Technical Specification pages.

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

i 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.

j' Detroit Edison has evaluated the proposed change against the criteria of 10 CFR l'

50.92 and determined that No Significant Hazards Consideration is involved. This evaluation is included in Enclosure 1.

The Fermi 1 Review Committee has reviewed and approved this proposed license amendment. In accordance with 10 CFR 50.91. Detroit Edison is providing a copy of this letter to the State of Michigan.

4 If there are any questions, please contact Lynne Goodman, Director Fermi 1 at 734-586-1205.

l Sincerely, Enclosures L

cc: NRC Regional Administrator, Region III S.W. Brown G.A. Harris P. Lee, NRC Region III D.R. Hahn (State of Michigan) i

USNRC NRC-98-0128 Page 3 I, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

l DOUGLAS %. GIPSON Senior Vice President On this Ob'Oday of W1R 4A

.1998 before me personally appeared Douglas R. Gipson,lieing[/irst duly swom and says that he executed the foregoing as his free act and deed.

$ LL/L, IdM WL Notary Public ROSALE A.

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USNRC NRC-98-0128 Page 4 bec: G. Cerullo P. Fessler l

D.R. Gipson L.S. Goodman L.K. Layton P. Marquardt J.E. Moyers J.E. Conen L. Craine J. Couillard R.R. Eberhardt, Jr.

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

R. McLenon J

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

E.M. Page.

l K. Sessions l

E.M. Wilds D.R. Williams Information Management (116 NOC) - Fermi 1 Records NRR Chron File (Licensing)

NRC Notebook (Fermi 1) l l

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NRC-98-0128 Page 1 l

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ENCLOSUPPd Enrico Fermi Atomic Power Plant, Unit 1 NRC Docket No. 50-16 NRC License No. DPR-9 REVISED DESCRIPTION OF PROPOSED TECIINICAL SPECIFICATION CIIANGE j

and NO SIGNIFICANT IIAZARDS CONSIDERATION REVIEW EFFLUENT TECIINICAL SPECIFICATIONS d___________--.___

.NRC-98-0128 Page 2 INTRODUCTION The 1996 Decommissioning Rule revised 10 CFR 50.36a to make it applicable to permanently shutdown reactors. In Reference 3, Detroit Edison submitted its position as to why no changes would be needed to implement provisions of 10 CFR 50.36a. In Reference 4, the NRC stated that 50.36a is applicable to Fermi 1 and that Detroit Edison is required to have effluent Technical Specifications and should request an amendment to its Fermi 1 license. The NRC letter also discussed that since the 1996 rule made Appendix 1 numerical guides applicable to plants in decommissioning, if Detroit Edison proposes to use l

numerical guidelines different from those set forth in Appendix I, it should propose Fermi i 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 functional installed system to make such releases. It would be difficult to write a Technical Specification 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 grocedure will be developed at the time releases are planned. A NRC representative agreed it was not the NRC intent to require installation of a dir, charge system at this time. Also, at ;he meeting, the Detroit Edison representative discussed that 10 CFR 50, Appendix I, 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 I contains established criteria, Detroit Edison must propose some effluent criteria and the NRC will review what is proposed.

Detroit Edison proposed effluent Technical Specifications in Reference 2. Earlier this year, tritium was detected in the residual secondary sodium at Fermi 1. The proposed Technical Specifications were referenced, as well as the existing Technical Specifications, during planning for sodium work. Due to the presence of the tritium, Detroit Edison determined different effluent Technical Specification wording which specifically mentions provisions for tritium would be beneficial. The proposed Technier.1 Specification was discussed with the NRC representatives in a working level public meeting on July 28, 1998. Feedback from that meeting was used to modify this proposal. The NRC reviewer was asked to delay review of Reference 2 until this modified request was submitted.

This amendment reque.st proposes effluent Technical Specifications to meet 10 CFR 50.36a and the NRC position stated in Reference 4. Section F of the Technical Specifications, currently entitled " Waste Disposal Surveillance," will be renamed " Waste Disposal and Radioactive Effluents." The modified section will include requirements to have 1) a functional waste disposal system. with monitoring or sampling and analysis, and procedures, prior to commencing planned radioactive liquid or gaseous effluei.. Jischarges; 2) an effluent dose limit matchmg the numerical limit in 10 CFR 20.1301; and

3) gt.idelines using criteria from 10 CFR 50, Appendix 1. Also included will be the requirement 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 current requirements specified in Section F on surveillance of the radiation monitor used for liquid discharges, instantaneous limits for liquid and gaseous effluents, and monitoring liquid effluents, except for liquid effluents which have been processed to remove particulate.

'Ile proposed amendment implements the additional requirements of 10 CFR 50.36a applicable to

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.NRC-98-0128 Page 3 Fermi 1. Also, a requirement to sample and analyze liquid radioactive effluents prior to release is addeJ

' He proposed wording will require that controls and procedures for waste disposal be provided before any planned discharges. This is appropriate for the current status of the facility, since the waste discharge systems have not been used for 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 I does not apply to liquid metal reactors, the numerical guidelines are previously ac :pted guidelines and so Detroit Edison decided to use them in this proposed amendment.

Asy Solving operational flexibility from 10 CFR 50.36a or Appendix 1 are not proposed, since l

l Fermi 1 is permanently shutdown. The proposed wording is more concise than Appendix I wording, but the numerical criteria match. The format used fits into the Fermi i Technical Specifications.

For liquid radioactive effluents, a sample is required to be analyzed by gamma spectral analysis and 11-3 l

analysis prior to release. Additionally, if the liquid has not been processed to remove particulate, it will be required to be monitored by a radiation monitor during discharges. The monitor will serve to alert personnel to unexpected radioactive effluents, in the event some concentrated material was not present in the sample analyzed. In the case where the liquid has been processed to remove particulate prior to discharge, the sample taken will be fully representative of the effluents and so the monitor is not needed.

The existing Technical Specification requires the monitor, but not sample analysis. Sample analysis is more accurate and better utilized for performing the dose calculations required.

The proposed wording for radioactive gaseous effluents specifically addresses the 11-3 which has been detected in the secondary sodium and in a sample of Fermi i primary sodium previously shipped offsite.

During cutting of piping containing sodium and during sodium processing, the radioactive gaseous effluents will be monitored or sampled and analyzed for tritium. Additionally, airborne radioactive particulate will be required to be monitored or sampled and analyzed when cutting pipe containing primary sodium or processing primary sodium. While other evolutions that will generate gaseous radioactive effluents are not envisioned, the proposed specification will require monitoring or sampling

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and analyzing such effluents for 11-3 and particulate. This will ensure such evolutions are covered by the Technical Specifications if they arise, while the specifics for cutting piping containing sodium and processing sodium, which are planned activities, are covered.

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 effluent pathway.

Calculations will be required for years during which discharges of radioactive effluents occur. If effluents are not being released, no calculations will be necessary. This philosophy matches that in the approved Fermi 1 environmental surveillance. Environmental surveillance are not required until discharge ofliquid radiological effluents is commenced.

Lastly, the proposed amendment adds a requirement for an annual effluent report to Section I.8. This report must be submitted such that the time between reports does not exceed 12 months. The i

specification does not name the report, so that this effluent report could be combined with the already

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required annual report or be a separate report.

I A typographical error in section numbering is being corrected by this submittal on page 6 of the Technical Specifications.

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.NRC-98-0128 Page 4 SIGNIFICANT ll A7,ARDS 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 i

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. In the case ofliquid radioactive effluents which have been processed to remove particulate, the proposed submittal does not require monitoring during the discharge, but does add the requirement for sample and analysis. The sample and analysis will provide more accurate information than the current monitoring requirements. The monitoring requirement for normal discharges has no effect on the probability or consequences of an accident. No other existing requirements are deleted. For these reasons, this proposed change will not significantly increase the l

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 eccident previously analyzed?

No, the addition of requirements for radioactive effluent releases will not cause a new kind of accident. The additional requirements involve having a functional waste system with procedures, submitting an annual repod, and restricting the potential dose to the 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 effluents will not decrease the margin of safety. Since the only existing requirement being eliminated e that of monitoring processed liquid radioactive releases and the requirement for sampling and analyzing the liquid is being added, which will provide more accurate information, this change will not reduce the margin of safety of the facility.

ENVIRON 3f ENTAL 151 PACT Detroit Edison has reviewed the proposed Technical Specification changes against the criteria of l

10 CFR 51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor significantly change the types or increase the amounts of effluents that may be released off site, nor increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed Technical Specifications meet the criteria given in 10 CFR 51.22 (c)('9) fbr a categorical exclusion from the requirements for an Environmental Impact Statement.

NRC-93-0128 Page5 CONCLIISION Based on the evaluations above: (1) there is a reasonable assurance that the health and safety of the public will not be endangered by conduct of activities in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the proposed amendment will not be inimical to the common defense and security or the health and safety of the public.

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