U-604034, Request for Partial Site Release

Request for Partial Site Release

ML11340A077
Person / Time
Site:	Clinton
Issue date:	11/18/2011
From:	Noll W Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
U-604034
Download: ML11340A077 (13)

Text

Exelon.

Nuclear Clinton Power Station 8401 Power Road Clinton, IL 61727 U-604034 100CFR 050.83 November 18, 2011 Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001 Clinton Power Station Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Clinton Power Station Request for Partial Site Release Exelon Generating Company, LLC (Exelon), Clinton Power Station, is requesting approval for the transfer of real estate from the Clinton Power Station site to the Creek Township for the purpose of expanding the Lisenby Cemetary. Exelon requests NRC approval by March 30, 2012.

The attachments provide the supporting information for this request in accordance with 1 0CFR50.83(b) for release of a non-impacted area. This includes a description of the property and evaluations of the effect of releasing this property. Exelon's evaluation of the effect of releasing this property indicate that all applicable regulatory requirements will continue to be met and no change is needed to Clinton's Operating License or Technical Specifications.

There are no regulatory commitments contained in this letter.

Should you have any questions regarding this information, please contact Mr. Brian Davis at (217) 937-2800.

Respectf y,l*

William G. Noll Site Vice President Clinton Power Station EET/blf Attachments cc:

Regional Administrator, Region III I

NRC Senior Resident Inspector - Clinton Power Station Office of Nuclear Facility Safety - Illinois Emergency Management Agency A,. 2.-f

U.S. Nuclear Regulatory Commission Clinton Power Station U-604034 Page 1 of 7 Supporting Information for Clinton Power Station Request for Partial Site Release BACKGROUND Late in 2010, representatives of Creek Township approached Exelon officials with a request that Clinton Power Station (CPS) transfer to Creek Township approximately three (3) acres of land CPS currently owns that is adjacent to the Lisenby Cemetery.

The land at issue is on the outer edge of CPS property, and would be used to expand the Lisenby Cemetery. Abraham Lisenby was the first pioneer to settle in Creek Township in 1830.

The property has not been impacted by CPS operations and was evaluated for environmental concerns. No environmental concerns have been identified. This property has not been used for any activities that could have radioactively contaminated the property.

Exelon requests NRC approval per 1 OCFR50.83 for the release of this non-impacted property from the jurisdiction of NRC operating license NPF-62 for CPS.

DESCRIPTION OF THE PROPERTY The request consists of a square shaped piece of land of approximately 3 acres immediately adjacent to its current property line on the South, for expanding the cemetery. Additionally, all of the land from the Township Road to the current Cemetery property boundary and Township Road to the edge of the proposed addition to the Cemetery property line would be transferred, for a total of approximately 4 acres.

Reference Attachment 2, Site Characteristics, and Attachment 3, Detail of cemetery location.

The property is located approximately 2977 meters/1.85 miles from the plant site which is outside of the Exclusion Zone (975 meters/0.6 miles) and just within the Low Population Zone (LPZ) (4018 meters/2.5 miles) in the South Southeast (SSE) sector.

Reference Attachment 4, Site Development.

The property is not located within the approximately 150 acres that comprise the Protected Area and Owner Controlled Area of the plant, nor is it located on the lake shoreline and it has no effect on the cooling function of the lake, which is designed to provide cooling water to the station and to remove the design heat load from the plant.

The LPZ was selected to provide reasonable probability that appropriate protective measures could be taken to assure compliance with the guidelines of 10CFR100, or, for accidents analyzed using Alternative Source Term, the limits of 10CFR50.67. The number and density of residents in the LPZ are low and this enables effective evacuation procedures to be followed in the event of a serious accident. There are no plans for permanent housing on the released site, only expansion and access of the cemetery.

U.S. Nuclear Regulatory Commission Clinton Power Station U-604034 Page 2 of 7 Supporting Information for Clinton Power Station Request for Partial Site Release SCHEDULE FOR PROPERTY RELEASE This property is planned to be transferred to Creek Township in early 2012.

RESULTS OF 10 CFR 50.59 EVALUATION 10 CFR 50.83(b) requires for non-impacted areas that the licensee submit the results of the evaluation performed in accordance with 10 CFR 50.59. The assessment of the free release of this property is as follows:

The property transfer involves approximately 4 acres of the approximately 14,000 acres the site owns. This transfer does not involve property that is actively used by the plant for normal operations or that is needed for the site's emergency plan. The Updated Safety Analysis Report (USAR) describes the current land in a table of total acreage within outer site boundary, and has no other mention of the property.

The 10CFR50.59 review assessed the impact of the change in the site boundary on offsite dose calculations and effluent releases and concluded that the change:

does not adversely affect any design function as described in the USAR.

does not adversely affect how a design function as described in the USAR is performed or controlled does not revise or replace an evaluation method used to establish design basis or safety analysis, and does not involve a test or experiment not described in the USAR.

Therefore, this change in property ownership does not require prior NRC approval under the requirements of 10CFR50.59.

HISTORICAL SITE ASSESSMENT 1 OCFR50.83 process includes a historical site assessment to identify potential or known sources of radioactive material or radioactive contamination that may have affected the property.

Technical Specification (TS) 5.6.2, Annual Radiological Environmental Operating Report includes summaries, interpretations, and analyses of trends of the results of the Radiological Environmental Monitoring Program. It also includes environmental radiation measurements taken pursuant to the locations specified in the table and figures in the Offsite Dose Calculation Manual (ODCM), as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979.

U.S. Nuclear Regulatory Commission Clinton Power Station U-604034 Page 3 of 7 Supporting Information for Clinton Power Station Request for Partial Site Release This information is used to calculate the offsite dose to the public. The radiation dose to the public in the vicinity of CPS is calculated by using the concentration of radioactive nuclides from each gaseous effluent release coupled with historical weather conditions.

The dose from CPS gaseous radioactive effluents has been a small fraction of the limit for the maximum exposed member of the public.

CPS releases airborne effluents via two (2) gaseous effluent release points to the environment. The first is the Common Station Heating, Ventilating, and Air Conditioning (HVAC) Vent and the second is the Standby Gas Treatment System (SGTS) Vent. Each gaseous effluent release point is continuously monitored consisting of a surveillance program of periodic sampling and analysis as specified in the ODCM.

CPS strictly controls effluents to ensure radioactivity released to the environment is maintained As Low As Reasonably Achievable (ALARA) and does not exceed federal release limit criteria. Effluent controls include the operation of radiation monitoring systems within the plant as well as an offsite environmental analysis program.

TS 5.6.3 Radioactive Effluent Release Report includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be consistent with the objectives outlined in the ODCM and process control program and in conformance with 10 CFR 50.36a and 10 CFR 50, Appendix I.

In addition to the TS requirements, a review of corrective action documents was completed for events that could have had a potential for releasing radioactive material to this property. There are no recorded events of any spills, leaks, or uncontrolled release of radioactive material on this land.

Radiological Technical Evaluations (RTE) have been reviewed for impact to this property. These evaluations are developed for accidental release of dry radioactive material stored on-site. The dose to the public and this property are well within 10CFR100 and 10CFR50.67 doses. There is no impact to this property from any RTEs.

The annual Radioactive Effluent Release Reports are a detailed description of gaseous and liquid radioactive effluents released from CPS. These reports show that CPS continues to be operated well within federally required limits for offsite dose to the public.

In addition, the Radiological Environmental Monitoring Program (REMP) is conducted continuously for the CPS in accordance with the ODCM. As reported in the annual Radiological Environmental Operating Reports, during each yearly reporting period, thousands of analyses are performed on thousands of samples. Assessments of all the data gathered for the yearly reports and comparing the results with preoperational data shows there has been no adverse radiological impact on this property.

U.S. Nuclear Regulatory Commission Clinton Power Station U-604034 Page 4 of 7 Supporting Information for Clinton Power Station Request for Partial Site Release Station release pathways are monitored and summarized as follows:

Surface, drinking, and well water samples were analyzed for concentrations of tritium and gamma emitting nuclides. Drinking water samples were also analyzed for concentrations of gross beta and 1-131. No fission or activation products have been detected. Gross beta activities detected are consistent with those detected in pre-operation years. No tritium activity has been detected and the required lower limit of detection (LLD) has been met.

Fish and shoreline sediment samples were analyzed for concentrations of gamma emitting nuclides. No fission or activation products were detected in fish or shoreline sediment samples.

Air particulate samples were analyzed for concentrations of gross beta and gamma emitting nuclides. Cosmogenic Be-7 was detected at levels consistent with those detected in previous years. No fission or activation products were detected. High sensitivity 1-131 analyses were performed on weekly air samples. All required LLDs were met.

Cow milk samples were analyzed for concentrations of 1-131 and gamma emitting nuclides. All 1-131 results were below the required LLDs.

Concentrations of naturally occurring K-40 were consistent with those detected in previous years. No fission or activation products were found.

Food product samples were analyzed for concentrations of gross beta and gamma emitting nuclides. Gross beta activities detected were consistent with those detected in previous years. Concentrations of Cosmogenic Be-7 and naturally occurring K-40 were consistent with those detected in previous years. No fission or activation products were detected.

Grass samples were analyzed for concentrations of gamma emitting nuclides.

Concentrations of Cosmogenic Be-7 and naturally occurring K-40 were consistent with those detected in previous years. No fission or activation products were detected.

Environmental gamma radiation measurements have been performed quarterly using thermoluminescent dosimeters. Levels detected are consistent with those observed pre-operation. Environmental sample location CL-44 monitors near this property, 2.3 miles SSE.

Releases of gaseous radioactive materials were accurately measured in plant effluents. There was no gaseous effluent releases that approached the limits specified in the CPS ODCM.

U.S. Nuclear Regulatory Commission Clinton Power Station U-604034 Page 5 of 7 Supporting Information for Clinton Power Station Request for Partial Site Release The findings of this review show the following:

1. The land has not been used for plant operations.

2. The land has not been used for storage of any radioactive material or waste.

3. There are no event records that any spills, leaks, or uncontrolled release of radioactive material have ever occurred on the land, reportable or non-reportable.

4. The last liquid radioactive release from the plant was in 1992 in the circulating water discharge canal which is on the north side of Salt Fork. This property is located on the south side of Salt Fork and not in the groundwater gradient of the discharge canal.

5. No state or local agency has required additional groundwater monitoring or remedial actions on the property.

6. Three separate hydrogeologic studies have been conducted at CPS, in accordance with NEI 07-07, Review of Hydrogeologic Investigation Report (HIR),

between 2006 and 2010. This property does not impact these studies.

7. The Radioactive Groundwater Protection Program (RGPP) conducts periodic monitoring of shallow groundwater. This program shows that shallow groundwater continues to flow predominantly towards the lake. This property is located on the south side of Salt Fork, whereas the plant is on the north side of Salt Fork, therefore, no contamination of this property through normal groundwater gradient flow can occur from plant discharges.

8. In assessing all the data gathered for the REMP annual report and comparing each year's results with preoperational baseline data, it is concluded that the operation of CPS has had no adverse radiological impact on this property.

CPS continues to implement a radiation protection program commensurate with 10 CFR Part 20 and CPS Technical Specifications 5.6.2 and 5.6.3. This property has no reasonable potential for residual radioactivity in excess of natural background or fallout levels, ttherefore, this property qualifies as a "non-impacted area" as per 10 CFR 50.2.

A historical cultural review was performed during the initial stages of planning and construction of the lake. The archaeological sites uncovered within CPS property boundaries are similar to other sites in Illinois and are not of major significance. There are no identified cultural sites in the area of the Lisenby Cemetery.

U.S. Nuclear Regulatory Commission Clinton Power Station U-604034 Page 6 of 7 Supporting Information for Clinton Power Station Request for Partial Site Release EVALUATION OF THE EFFECT OF PROPOSED PROPERTY TRANSFER Exelon has evaluated the effect of transferring the property in accordance with the criteria in 10 CFR 50.83(a) (1) in order to ensure that CPS will continue to comply with all applicable statutory and regulatory requirements that may be affected by the release of the property.

Listed below are details of each of the criteria:

(i)

The dose to individual members of the public does not exceed the limits and standards of 10 CFR Part 20, Subpart D. CPS strictly controls effluents to ensure radioactivity released to the environment is maintained ALARA and does not exceed federal release limit criteria. Effluent controls include the operation of radiation monitoring systems within the plant as well as an offsite environmental analysis program. The release of this property does not change any controls used to comply with dose limits for individual members of the public. CPS has determined that this property was never used for any radiological purposes.

(ii)

Impact on the effectiveness of emergency planning or physical security has been evaluated in accordance with 10 CFR 50.54(q) and (p). No credit is taken for this land in either the Emergency Plan or the Security Plan.

Therefore, the transfer of this property has no adverse effect on either plan.

(iii)

Effluent releases remain within license conditions and, because the property is distant from the plant site and is not down-gradient of discharge structures, it does not have the potential to be affected by effluent releases. The plant programs to maintain effluent releases within license conditions remain in effect and the transfer of this property does not impact those programs.

Therefore, the effluent releases from CPS will remain within license conditions.

(iv)

The transfer of this land does not have any effect on the environmental monitoring program and offsite dose calculation manual revisions, and neither requires revision as a result of this property transfer.

(v)

The siting criteria of 10 CFR 100 continues to be met. The transfer of this property has been reviewed with respect to the siting criteria in 10 CFR 100 and it has no effect on meeting these criteria. In addition, the limits of 10 CFR 50.67, Alternative Source Term, have been reviewed and the transfer has no effect on meeting these criteria.

Initially, two identical units were planned at the CPS Facility. The CPS Preliminary Safety Analysis Report, which was docketed on October 30, 1973, described both reactor facilities. Construction permits were issued for both units on February 24, 1976. Construction on the second unit was canceled in 1983. In 2002, Exelon conducted an Early Site Permit (ESP) study on an area that is contained entirely within the CPS exclusion area.

U.S. Nuclear Regulatory Commission Clinton Power Station U-604034 Page 7 of 7 Supporting Information for Clinton Power Station Request for Partial Site Release Reference Attachment 5, Aerial View of Site, and Attachment 6, Plant Location and Clinton Lake Impoundment. This co-location strategy proves beneficial because the existing nuclear site is already developed and dedicated to nuclear use. Clinton Lake will be used as the source of make-up water for the ESP facility cooling towers through a new intake structure located adjacent to the existing intake structure. Cooling tower blowdown and other plant discharges will use the existing discharge flume. The transfer of this land does not have any effect on the ESP.

(vi)

Other statutory and regulatory requirements continue to be met. There are no changes to CPS' policies and procedures to ensure that statutory and regulatory requirements continue to be met as a result of this property transfer.

In summary, based on the considerations discussed above, this property transfer has no impact on CPS' continued compliance with applicable NRC regulatory standards.