ML18026A540

Monthly Operating Repts for Feb 1998 for Susquehanna Steam Electric Station.W/980313 Ltr

ML18026A540
Person / Time
Site:	Susquehanna
Issue date:	02/28/1998
From:	Kuczynski G, Keith Young PENNSYLVANIA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-97-02, GL-97-2, PLA-0005063, PLA-4853, PLA-5063, NUDOCS 9803240272
Download: ML18026A540 (58)

Text

CATEGORY 1 .

REGUL ~RY INFORMATION DISTRIBUT SYSTEM (RIDS)

ACCESSION NBR:9803240272 DOC.DATE: 98/02/28 NOTARIZED: NO DOCKET FACXL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-,388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH.ill% AUTHOR AFFILIATION YOUNG,K.A. Pennsylvania Power & Light Co.

KUCZYNSKI,G.J. Pennsylvania Power E Light Co.

RECIP.NAME RECIPIENT AFFILIATION

SUBJECT:

Monthly operating repts for Feb 1998 for Susquehanna Steam Electric Station.W/980313 ltr.

DXSTRIBUTION CODE: IE24D COPIES RECEXVED:LTR ENCL SIZE:

TITLE: Monthly Operating Report (per Tech Specs)

NOTES: 05000387 Q

RECIPIENT COPXES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-2 PD 1 1 NERSES,V 1 1 INTERNAL: ACRS 1 1 AEOD/SPD/RRAB 1 1 CENT R 1 1 1 OC/DBA/PAD 1 1 1 1 EXTERNAL: LITCO BRYCE,J H 1 1 NOAC NRC PDR 1 1 NOTES: 1 1 U

E NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 11

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g I 0 tstsst 0 r George J. Kucsynstd Susquehanna Stcam Electric Station General Manager-Susquehanna P.O. Box 467, Benvick, PA 18603 Tel. 717.542.3120 Fax 717.542.1949 pp March 13, 1998 Submitted pursuant to Technical Specifications Section 6.9.1.6 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, D. C. 20555 SUSQUEHANNA STEAM ELECTRIC STATION MONTHLYOPERATING REPORTS Docket Nos. 50-387/NPF-14 and 50-388/NPF-22 PLA - 0004853 FILE: R41-2A The February 1998 monthly operating reports for Susquehanna SES Units 1 and 2 are attached. The format and contents of the report have been changed to comply with the guidance in G. L.97-02.

Very truly yours,

~- 2 C/~~

G. J. Kuczynski

/cmm Attachment cc: NRC Region 1 Mr. K. Jenison, NRC Sr. Resident Inspector Mr. C. Poslusny, Jr. NRC Sr. Project Manager 9803240272 'st80228 PDR ADQCK 05000387 R PDRg

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OPERATING DATA REPORT DOCKET NO. 50-387 UNIT One DATE 3/3/98

~~CC S<I OPERATING STATUS

1. Unit Name: Sus uehanna Steam Electric Station U1

2. Reporting Period: Februa 1998

3. Design Electrical Rating (Net MWe): 1100

4. Maximum Dependable Capacity (Net MWe): 1090 This Month Yr.-to-Date Cumulative

5. Hours in Reporting Period 672 1416 129 121

6. Number of Hours Reactor Was Critical 672 1416 103,793.8

7. Hours Generator On-Line 672 1416 102,009.1

8. Unit Reserve Shutdown Hours

9. Net Electrical Energy Generated (MWH) 744,755 1,572,644 102 813,459 NOTES:

Page 1 of 1

UNIT SHUTDOWNS DOCKET NO. 50-387 8< gag UNIT One DATE 3/3/98

~ere s<r REPORT MONTH Februa 1998 No. Date Duration Method of Cause & Corrective Action Type (Hours) Reason Shutting to Prevent Recurrence Down Reactor No report this month.

Summary:

The Unit operated at 100% power for most of the report period except for one short duration downpower. Qn February 6'" power was reduced to 73% for a scheduled control rod sequence exchange. Power returned to 100% at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> February 7

2. 3.

F. Forced Reason: Method:

S. Scheduled A - Equipment Failure (Explain) 1 - Manual B - Maintenance or Test 2- Manual Scram C - Refueling 3 - Automatic Scram D - Regulatory Restriction 4- Continuation from previous month E - Operator Training & Licensee 5- Other Exam F - Administrative G - Operational Error (Explain)

Page 1 of1

I SUSQUEHANNA STEAM ELECTRIC STATION I

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Docket Number: 50-387 Date: 3/3/98 5 51 1 257: . ~K.A.Y 7 1 22: ~717 542 2251 Challen es to Main Steam Safet Relief Valves None.

Chan es to the Offsite Dose Calculation Manual None.

Ma or Chan es to Radioactive Waste Treatment S stem Safety Evaluation NL-97-087, Current Licensing Bases Update for Liquid, Gaseous, and Solid'aste Management Systems. FSAR sections 11.2, 11.3 and 11.4 (Attached).

OPERATING DATA REPORT DOCKET NO. 50-388 UNIT Two DATE 3/3/98 TELEPHONE 17 542-3251 Wrc s~

OPERATING STATUS

1. Unit Name: Sus uehanna Steam Electric Station U2

2. Reporting Period: Februa 1998

3. Design Electrical Rating (Net MWe): 1100

4. Maximum Dependable Capacity (Net MWe): 1094 This Month Yr.-to-Date Cumulative

5. Hours in Reporting Period 672 1416 114 360

6. Number of Hours Reactor Was Critical 672 1416 97 052.3

7. Hours Generator On-Line 672 1416 95,458.4

8. Unit Reserve Shutdown Hours

9. Net Electrical Energy Generated (MWH) 746,341 1,555,164 98,000,228 NOTES:

Page1 of1

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UNIT SHUTDOWNS DOCKET NO. 50-388 gag UNIT Two

~e DATE 3/3/98

~ere s~"

COMPLETED BY ~K. A. Youn REPORT MONTH Februa 1998 No. Date Method of Cause & Corrective Action TYPe'uration Reason~ Shutting to Prevent Recurrence (Hours)

Down Reactor 3

No report this month.

The Unit operated at 100% power for the entire report period.

1. 2. 3.

F. Forced Reason: Method:

S. Scheduled A - Equipment Failure (Explain) 1 - Manual 8 - Maintenance or Test 2- Manual Scram C - Refueling 3 - Automatic Scram D - RegulatorY Restriction 4 - Continuation from previous month E - Operator Training 8 Licensee 5- Other Exam F - Administrative G - Operational Error (Explain)

Page 1 of 1

SUSQUEHANNA STEAM ELECTRIC STATION Docket Number: 50-388 Date: 3/3/98 6 pl 1667: ~K.41.7 7 1 pd  : L7717 642 2261 Challen es to Main Steam Safet Relief Valves None.

Chan es to the Offsite Dose Calculation Manual None.

Ma or Chan es to Radioactive Waste Treatment S stem (See Docket 50-387 and Attachment).

SAFETY'EVALUATIONCOVERSHEET Title: .Current Licensing Basis Update for Liquid, Gaseous and Solid Waste Management Systems-FSAR Sections 11.2, 11.3 and 11.4 No. NL-97-087 UNiT ¹ 1 and 2 DCP ¹ Not Applicable PROCEDURE ¹ Not Applicable OTHER IEcot, SPCP, By. Pass, RIE)

Not Applicable SUSQUEHANNA STEAM ELECTRIC STATION PENNSYLVANIAPOWER & LIGHT COMPANY

/ x~ 98-oZ-/~ F~/ 4 i%8 REv. PREPARED BY/ REVIEWED BY/ APP ROY BY'/ PORC MTG ¹/

DATE DATE DATE DATE This signature of the Responsible Supervisor indicates approval of the safety evaluation and confirms that interfaces with other disciplines, functional groups, etc. have been considered and have been incorporated into the evaluation as necessary. The Responsible Supervisor must be designated on Form NDAP-QA-0726-3.

A copy of the ACCEPTED Safety Evaluation must be forwarded to the Supervisor-Nuclear Licensing.

FORM NDAP-QA-0726-1, Rev. 2, Page 1 of 25

PCAF NO. 1-96-6258 Page 5 of 6 SAFETY EVALUATION0 1VL-97-087 Title: Current Licensing Basis Update for Liquid, Gaseous and Solid Waste Management Systems-FSAR Sections 11.2, 11.3, and 11.4 READ "INSTRUCTIONS FOR COMPLETING NDAP-QA-0726-1" BEFORE ANSWERING EACH QUESTION I. System/Procedure/Experiment Identification. (Name and Number)

Liquid Waste Management System / 069/169/269 Solid Waste Management System /068/168/268 Gaseous Waste Management System /072 Condensate Cleanup System /139/239 Solid Radioactive Waste Process Control Program, NDAP-QA-0646, R4 Offsite Dose Calculation Manual II. Description and Implications of Proposed Action.

A. Fully describe the action and its purpose.

The purpose of this safety evaluation is to support the revision of the Susquehanna Steam Electric Station - Final Safety Analysis Report (FSAR) Sections 11.2, 11.3 and 11.4 text, tables and figures; and interfacing FSAR subsections, Offsite Dose Calculation Manual (ODCM) (Section 10.6, Figures 1 and 4); and PPBL procedure NDAP-QA-0646, "Solid Radioactive Waste Process Control Program" (Section 6.2) to reflect:

(1) changes to the as-built design and operation of the liquid, gaseous, solid radwaste and condensate cleanup systems as described in Condition Report CR 097-0762 and CR 097-3393 for the Liquid Waste Management System (LWMS), CR 97-2219 for the Solid Waste Management System (SWMS) and CR 96C419 for the Condensate Cleanup System, (2) the results of studies and calculations performed to assess the impact of the identified system changes, (3) validation of the. liquid, gaseous, and solid waste management system design data supporting Current Licensin'g Basis (CLB) project requirements.

This Safety Evaluation supports Licensing Design Change Notice (LDCN)s for updating FSAR Sections 2.4.12.2, 2.4.12.3 2.4.13.3, 9.1.3, 10.4.6, 11.2, 11.3, 11.4, 12.2.2, and 15.7.3 to be consistent with Regulatory Guide 1.70 revision 2 requirements. This Safety Evaluation and the above referenced condition reports were prompted by the CLB effort in which a comparative review was performed of the as-built and as-operated plant systems versus the FSAR design description.

FORM NDAP-QA-0726-1, Rev. 2, Page 2 of 25

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~w This Safety Evaluation addresses the resolution of the 28 discrepancy items contained in CR 97-

~ 0762 for the LWMS and the 22 items identTiied in CR 97-2219 for the SWMS. CR 96-0419 is also addressed because problems described in this CR are identical to item 4 in CR 97-0762 and item 3 in CR 97-2219 which indicates that chemical regeneration of condensate demineralizers is not performed and that the radwaste evaporators are not utilized for processing chemical wastes as described in the FSAR. The disposition of CR 97-3393 (LRW Sample Tank Room curbing requirement) is also included as part of the current licensing update to FSAR Section 11.2.

As detailed in the referenced CRs, design and operational changes have been made to the liquid and solid waste processing systems and the condensate demineralizer system that have not been incorporated into the FSAR descriptions. Documentation of changes and modifications that have been made to the.radwaste systems and associated safety evaluations that are considered in this safety evaluation is as follows: A DCP 82-0155, RO, Radwaste Mobile Process Connection, PORC Mtg.82-117 PORC Mtg. 82-0234, Safety Evaluation for Hittman Nuclear Development Corporation, Mobile Radwaste Processing System DCP-82-0512A, B, Process Shield for Mobile Radwaste System DCP 82-0311 Ultrasonic Resin Cleaner

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OP-068-122, RO, PORC Mtg.86-103, Three Tank Demineralization Operation (Unpressurized)

OT-RKB-92-001: Liquid Isotope Offsite Dose Consequences for use of the Atmospheric Demineralizer System, PLI-70360 PLI - 70612 Atmospheric Demineralizer Results DCP 90-3025, R6, RWCU Pump Replacement, Unit 2 DCP 90-3031, R2, Turbine and Reactor Building Sample Station Interfaces DCP 90-3035C and D, R10/R6, RWCU Pump Replacement - Pump 1P221A/8 DCP 90-3036, R6, RWCU Pump Replacement Unit 2 DCP 91-9003, RO, LRW Laundry Drain Filter Replacement NL 92-004, RO, Bypass for Processing Chemical Radwaste to the River after Appropriate Treatment through the Atmospheric Demineralizer DCP 92-9056, RO, Cross Tie Piping Between LRW Tanks OT-321 and OT-322 DCP 93-9007, RO, Isolate Rad Screw Conveyors Cement Silo from Radwaste Mixing Pump NL-93-008, RO, Solid Radioactive Waste Processing Utilizing Pacific Nuclear Systems DCP 93-9054, RO, LRW Collection/Surge/Sample Tank Overflow Line DCP 95-9010, RO, Suppression Pool Transfer to LRW An Appendix to this section of the Safety Evaluation (Section II-A) has been prepared to tabulate items described in CR 97-0762 and CR 97-2219. The items in the Tables of the subject appendix are grouped into categories relative to the significance of the change or modification. The original item numbering as prepared in the original CR is preserved as an aid in describing the resolution of the identified items. Tables 1 and 2 of the Appendix summarize the 50.59 determinations and safety evaluations that have been performed to address the items specified in CR 97-0762 and 97-2219, respectively. Safety evaluations, 50.59 determinations, and FSAR updates have been prepared for all major changes and modifications that have been made to the radwaste systems. A Major change is defined as a change to a radwaste treatment system, procedure, operation, or design which has the potential to increase dose consequences or material releases from that previously predicted in the license application or amendments.

Although the safety evaluations identified in Tables 1 and 2 were performed, the impact of these modifications on radwaste system design basis and the assumptions and parameters used for estimating component inventories, effluent releases and doses, as documented in FSAR Sections 11.2 and 11.4, was not fully assessed. Further, Secondary changes, (the indirect result of a FORM NDAP-QA-0726-1, Rev. 2, Page 3 of 25

modification, and plant experience change items, that result from knowledge gained from plant

, operations) did not undergo 50.59 determinations, safety evaluations or FSAR updates.

The objective of this safety evaluation is to the assess both the individual and collective impact of these changes to applicable radwaste and interfacing system design bases to ensure that no unreviewed safety question exists and to support the update to applicable FSAR sections and analyses. Related current licensing basis and condition report findings are also included in this safety evaluation.

Verified engineering studies and calculations as prepared under PP8L procedure NDAP-QA-0221

'Preparation of Engineering Calculations and Studies'n support of this Safety Evaluation are:

EC-RADN-1044, Liquid Waste Management System Study EC-RADN-1041, Expected Liquid and Gaseous Effluent Releases and Doses EC-045-0537, Process Valve Stem Leakoff Collection System Design Basis EC-RADN-1047, LWMS Component Inventories EC-RADN-1059, Airborne Activity Estimates EC-RADN-1052, Solid Waste Management System Study EC-RADN-1048, Solid Radwaste Component Inventories EC-RADN-1054, Radioactive Waste Management System Design Data Validation Summary EC-RADN-1064, Postulated Radioactive Waste Management System Component Failure EC-RADN-1069, Liquid Radwaste Tank Failure Analysis (Groundwater Analysis-SRP 15.7.3)

EC-RADN-1071, SSES Design Liquid Releases-10CFR20, Appendix B, MPC Compliance EC-RADN-1072, SSES Gaseous Releases-10CFR20, Appendix B, MPC Compliance The following calculations originally prepared by the architect/engineer (Bechtel) have been superseded:

EC-RADN-0298, Liquid Releases EC-RADN-0300, Gaseous Releases EC-RADN-0297, FSAR 11.2 Component Inventories EC-RADN-0299, FSAR 11.2 Filter Loadings EC-RADN-0301, Solid Radwaste Component Inventories EC-069-0003, Concentrates Waste Tank Failure EC-HPHY-0007, Airborne Activity Estimates (FSAR 12.2.2)

The purpose of the following numbered paragraphs is to provide a discussion of the items as described in Tables 1 and 2 of the Appendix. The designations in brackets at the end of the paragraph refer to the CR items identified in the Appendix tables.

Major Liquidand Solid IVaste Management System Design Changes/Modifications The following paragraphs summarize the current licensing basis changes to be made to the liquid and solid waste management systems.

As a result of plant modifications, waste inputs to the Liquid Radwaste (LRW) subsystem have changed from that described in the FSAR:

a) suppression pool wastewater is transferred to LRW as per DCP 95-9010; b) RWCU pump seal leakage was eliminated by a replacement with sealless pumps as per DCP 90-3035C/D 8 90-3036; c) liquid radwaste input from the reactor and turbine building sampling system were chan ed as er P 90-3031 and 90-30 5'ORM NDAP-QA-0726-1, Rev. 2, Page 4 of 25

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DCP 93-9054 modified the batch size and setpoints associated with the LRW collection, surge and sample tanks; and e) the auxiliary boilers are not an input to the liquid radwaste system since the radwaste evaporators are not operated.

[CR 97-0762, items 7, 9, 10, 11, 21, 12]

Laundry is not processed onsite, (DCP 91-9003), therefore the Laundry Drain subsystem is used to process only decon wastewater, significantly altering the composition and quantity of the waste materials in this subsystem. [CR 97-0762, item 5]

The original SSES radioactive waste management system design incorporated (a) permanently installed evaporators for processing chemical wastes, (b) resin dewatering using the LRW filters and (c) cement solidification equipment for packaging wastes for storage and offsite shipment. Plant Modification Records82-155 and 82-243 were installed (tie-ins only) on the in-house liquid and chemical radwaste subsystems and the solid waste management system to provide an interface to use mobile vendor equipment for processing the chemical subsystem wastes, perform resin dewatering and solidification as a replacement for in-house equipment whose performance was found to be below expectations. [CR 97-0762, items 1, 4; CR 97-2219, items 1,2]

The Chemical Processing subsystem is not operated as described in the FSAR in that chemical regeneration of the. condensate demineralizer resins is not performed (OP-068-122, DCP 92-9056, 8 NL 92-004). Ultrasonic resin cleaning was added as a mechanical cleaning system that replaced the original Air Bump, Rinse Off (ABRO) function of the regeneration skid to remove particulates from the resins (DCP-82-311). FSAR Section 10.4.6 was updated to refer to URC as an alternate means of mechanically cleaning resins.

This section needs to be revised to reflect the fact that URC is the primary means of cleaning the condensate demineralizer resin and that the resin is discharged rather than chemically regenerated. Due to this change, the radwaste evaporators have not been used and have been replaced by a vendor supplied and operated mobile liquid processing system, with essentially 100% of the wastewater directed to this subsystem discharged to the environment (rather than the 5% previously assumed in assessing the impact of radioactive releases). Although this mobile system was originally installed (per DCP 82-155) as a demand and backup alternative to the in-plant subsystem, over the years with subsequent upgrades (NL-93-008), it has been used as the primary means of processing wastewater directed to the chemical processing subsystem. As a result of using filtration/demineralization, rather than evaporation, there is a significant reduction in the effective decontamination factor afforded by the chemical waste subsystem equipment.

[CR 97-0762, items 1, 4, 6, 13, 25 and 14; CR 97-2219 items 3, 4, 5; CR 96-419].

Liquid and Solid Waste Management System Plant &cperience'Changes Plant operating experience has demonstrated changes in operational expectations, parameters, and practices differing from those previously assumed in the original design analyses and presented in the FSAR Section 11.2 and 11.4 descriptions. Due to the implementation of the 24 month fuel cycle, the expected and design basis radionuclide activity inventories in components should be based on one refueling outage per year per station (in lieu of per unit). Some of the design and operating data for the liquid radwaste subsystem is not correctly described in the FSAR, specifically:

a) the liquid radwaste filters are not used for solids dewatering, rather both filters are o all inservicei se esfor rocessi

d astes.

FORM NDAP-QA-0726-1, Rev. 2, Page 5 of 25

l b) the filter cakes are not dried since operating experience with drying was found to cause problems in the removal of the cake from the filter screens; c) diatomaceous earth is not normally used on the LRW filters; d) the normal processing flowrate through the filters and demineralizer has changed from 200 gpm to 100 gpm (nominal); also the discharge flow rate from this subsystem to the plant discharge pipe (from the sample tanks) is 100 gpm, not 200 gpm as listed in Table 11.2-4, with approximately 2% of the wastewater directed to this subsystem discharged to the environment (rather than the 1% previously assumed in assessing the impact of radiological releases); discharge to the condensate storage tank (from the sample tanks) is at a nominal rate of 200 gpm.

e) backwash frequencies and volumes for the RWCU, fuel pool and LRW filters have changed as have the batched inputs to the LRW from the SWMS and consequently inputs directed to the waste sludge and RWCU phase separators has changed, f) there are three fuel pool filter demineralizers not two (as listed in Table 11.2-2),

g) based on operating experience, the RWCU phase separators are alternatively processed at yearly intervals rather than after 60 days. (This is incorrectly stated as 180 days in CR 97-0762);

h) the fuel pool filter demineralizer backwash is directed to the RWCU phase separator rather than the waste sludge phase separator.

[CR 97-0762, items 2, 3, 15, 16, 17, 18, 20, 22; CR 97-2219, items 2, 6, 7, 8, 9, 10, 19, 20, 21]

The cement solidification system is not used for processing solid waste for offsite shipment and has been replaced by a mobile processing system as per DCP 82-155,82-234, 82-512A, B and DCP 93-9007 and NL-93-008. In addition, this mobile system. is utilized to dewater waste solids in lieu of using the LRW filters. [CR 97-2219, items 1, 19]

The disposal data and methods of handling dry active waste (DAW) presented in Section 11.4.2.3 are not consistent with plant experience and current operating practices. Due to the conversion to a 24 month fuel cycle, control rod blades and power range monitor detector replacement frequency occurs at each refueling and not on an annual basis. The estimated disposal data presented in Table 11.4-2 is not representative of SSES operating experience. Although the hydraulic press and trash compactor is available for use, current practice is to utilize the services of a contracted vendor. The majority of DAW that is to be compacted is currently loaded into cargo containers and shipped offsite for incineration before burial by the contracted vendor. [CR 97-2219, items 11, 16, 22]

As a result of the changes described in 1 through 7 above, the data presented in the Section 11.2, 11.3, and 11.4 of the FSAR for inputs to the various tanks, usage factors, holdup times, decontamination factors, component activity content, liquid and gaseous radioactive release estimates and flow diagrams are not consistent with current plant design and operations nor with the assumptions previously utilized in conducting the NUREG-0016 analysis to demonstrate the ability of the liquid and gaseous waste management systems to comply with the applicable requirements contained in 10CFR20 and 10CFR50, Appendix I.

Other FSAR analyses affected by these changes include: fuel pool system, filter and deanup backwash receiving tank shielding source terms (FSAR Tables 12.2-12-14),

condensate demineralizer shielding source terms (FSAR Table 12.2-16) and the estimated airborne concentrations in the reactor, turbine, and radwaste buildings (FSAR Tables 12.2-35-37)., In addition, the accident analyses presented in FSAR Sections 2.4.12.2, 2.4.12.3, 2.4.13.3 and 15.7.3 are not correctly described or analyzed since these analyses utilize the evaporator concentrates tank which is no longer in service. [CR 97-0762, items 8, 19, 27, FORM NDAP-QA-0726-1, Rev. 2, Page 6 of 25

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~ 9. Although not described in the Appendix, CR 97-3393 indicates that contrary to statements in FSAR Section 11.2.2, the liquid radwaste sample tank room in the Radwaste building on elevation 646'oes not have a curb or elevated threshold. Since the FSAR provides general statements with regard to the use of curbs and elevated thresholds: (1) "Rooms of components containing significant amounts of liquid radwaste are provided with elevated door thresholds to minimize the potential spread of contamination from leaks." and (2)

"Indoor tanks have curbs or elevated thresholds with floor drains routed to the liquid radwaste treatment system", the proposed action is to update the FSAR statements to reflect the fact that "Except for tanks containing processed wastewater (i.e. sample tanks),

curbs and elevated thresholds, with drains routed to the appropriate liquid waste management subsystem, are provided to minimize the potential spread of contamination from leaks or spills."

8. Identify all the components that will be affected.

The following plant systems and associated components were evaluated for potential impacts resulting from the actions described:

Liquid Waste Management System / Mobile Liquid Waste Processing System Solid Waste Management System/Mobile Solidiflication/Dewatering Processing System Gaseous Waste Management System Equipment and Floor Drainage System Condensate Cleanup System / Ultrasonic Resin Cleaner Reactor Water Cleanup System Fuel Pool Cooling 8 Cleanup System Suppression Pool Cleanup System HVAC, Turbine, Radwaste, Reactor Buildings, Process Valve Stem Leakoff Collection System Process and Effluent Radiation Monitoring System Area Radiation Monitoring System Sampling System Plant Shielding 8 Radiation Zones Low Level Radwaste Holding Facility r

C. List Safety Functions of affected components.

The liquid, 'gaseous, and solid waste management systems are described in FSAR Sections 11.2, 11.3, and 11.4, respectively. These systems, including the vendors supplied and operated liquid and solid mobile processing equipment, do not have safety related functions as part of their design basis. However, portions of these systems are designed and constructed in accordance with the requirements for dass 'D'ugmented as described in FSAR Section 3.2 and NRC Branch Technical Position ETSB No. 11-1.

The liquid and gaseous waste management systems are designed to be capable of maintaining radioactive effluents ALARA based on expected waste inputs over the life of the plant consistent with 10CFR50, Appendix I; maintain releases below the limits of 10CFR20 during periods of fission product release and have the ability to meet processing demands during normal operation and during periods of anticipated operation'al occurrences.

A mobile pressurized liquid processing system is currently utilized as a replacement for the radwaste evaporators to process wastewater from the chemical waste subsystem. The FORM NDAP-QA-0726-1, Rev. 2, Page 7 of 25

replaces the high efficiency atmospheric demineralizer system (HEADS) previously utilized for this purpose. The pressurized liquid processing system is designed, fabricated, and inspected in accordan'ce with Regulatory Guide 1.143 with design details documented in Molten Metal Technology's PP8L/SSES Chem Waste Processing System Report dated 10/97 (PLI-84607). The potential use of a pressurized system, similar to the one currently in use, was previously evaluated in NL 93-008.

The mobile solidification / dewatering processing subsystems are utilized to treat and package wet waste to meet the requirements of ETSB 11-3, R2 per Standard Review Plan Section 11.4 and documented in Topical Report No. TP-02-P-A, R1(6/85). These vendor supplied and operated subsystems replace the in-house cement solidification equipment

'and the use of the liquid radwaste filters for dewatering wet waste materials. The use of these mobile solidiTication and dewatering processing systems was previously evaluated in NL 93-008 and is performed in accordance with the Process Control Program (NDAP-QA-0646).

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2. The equipment and floor drainage system, as described in FSAR Section 9.3.3, is provided throughout the plant to collect liquid wastes from their points of origin and transfer them to the liquid waste management system, the plant discharge water treatment facilities, or the storm drainage system. With the exception of the drywell equipment drains and the drywell floor drain sump discharge piping penetrations through the primary containment and the associated isolation valves, the failure of this system will have no impact on plant safety.

The condensate cleanup system, as described in FSAR Section 10.4.6, has no safety related functions. The system is designed to maintain the condensate at the required purity level by the removal of contaminants via the condensate demineralizers. An ultrasonic resin cleaner is used to remove insoluble iron oxides (and associated radionuclides) deposited on the condensate demineralizer resin beads and to remove resin fines.

The reactor water cleanup'system, as described in FSAR Section 5.4.8, continuously purifies the reactor water. The system is not an engineered safety feature. A small portion of the system is part of the. reactor coolant pressure boundary up to and including the outermost containment isolation valve. The processed water is returned to the reactor pressure vessel, the main condenser. or to radwaste.

The fuel pool cleanup system, as described in FSAR Section 9.1.3, is used to maintain water clarity and quality in the fuel pools to facilitate underwater handling of fuel assemblies and to minimize fission and corrosion product buildup that pose a radiological hazard to operating personnel. This portion of the fuel pool cooling and cleanup system has no safety function as part of its design basis.

The interfacing of the suppression pool cleanup system with the LRW systems only involves components that are non-safety related and located in the non-seismic portions of the suppression pool deanup and residual heat removal systems that serve no safety related functions and are not required for the safe shutdown of the plant.

The radwaste and turbine building HVAC systems, as described in FSAR Sections 9.4.3 and 9.4.4, are designed to provide a suitable environment for personnel and equipment during normal operations and anticipated operational occurrences. These systems have no FORM NDAP-QA-0726-1, Rev. 2, Page 8 of 25

safety functions as part of their design basis. The reactor building HVAC system is described in FSAR Section 9.4.2 and includes both safety and non-safety related functions as part of its design basis. The portion of the reactor building ventilation system that is associated with the recirculation system is safety related. The remaining portion of the ductwork within the secondary containment boundary is not safety related however, it is seismicly.designed.and analyzed to ensure that it will not damage the safety related equipment and systems.

The process valve stem leakoff collection system, as described in FSAR Section 1.2.2.8.15, was designed and installed to minimize radioactive releases to the turbine building atmosphere by equipping high pressure valve's 2-1/2 inch and larger in system containing potentially radioactive steam with two sets of packing and a leakoff tap located between the packing sets. The system has no safety function as part of its design basis.

The process and eNuent radiation monitoring system, as described in FSAR Section 11.5, is provided.to monitor releases of radioactive materials in the plant gaseous and liquid effluents. The monitoring of certain effluent streams provides initiating'circuits for the .

Engineered Safety Features (ESF) Systems. Radiation Monitoring Systems (RMS) which provide safety related functions include: standby gas treatment vent stack exhaust; refueling floor wall duct exhaust: refueling floor high exhaust duct; railroad access exhaust duct and outside air intake duct which are unaffected by the proposed actions., The monitoring of liquid and gaseous radwaste processing and eNuent release points, while described in Technical Specifications, is not safety related.

10. The area radiation monitoring system, as described in FSAR Section 12.3.4, supplements the personnel and area radiation survey provisions of the Health physics Program and has no function related to the. safe shutdown of the plant or to the quantitative monitoring of the release of radioactive materials to the environs. The system serves no active safety function during operation, is not safety related and is constructed to Quality Group D requirements.

The sampling system, as described in FSAR Section 9.3.2, is provided to monitor the operation of plant equipment and is designed to prevent hazards to operating personnel due to high pressure, temperature. or radiation levels of the process fluid during all modes of operation. The sampling system is designed to limit the discharge flows, under normal operations and during postulated malfunctions or failures, to preclude any fission product release leading to exposures that exceed the 10CFR20 site boundary limits. The sampling system is not required to function during an accident nor is it required to prevent or mitigate the consequences of an accident.

12. The plant shielding and radiation zones, as described in FSAR Section 12.3.2, have no active safety function except where shielding is used for environmental qualification of safety related equipment or for providing post accident access. The basic design objective is to reduce personnel exposures, in conjunction with a program of controlled personnel access to and occupancy of radiation areas, to levels that are ALARA and within the dose requirements of 10CFR20 and 10CFR50.

The low level radwaste holding facility, as documented in FSAR Section 11.6, has no safety related functions. The facility is designed to temporarily store dry active waste (DAW) and solidified waste generated at SSES. The facility may also be used to store FORM NDAP-QA-0726-1, Rev. 2, Page 9 of 25

pieces of contaminated equipment, however it is not used to store gaseous waste or waste containing free liquids.

D. Describe potential effects on Safety Functions.

The liquid, gaseous, and solid waste management and applicable portions of interfacing systems and components important to safety, discussed above, do not perform a safety function. As such, there are no effects on safety related functions or the safe shutdown of the plant.

I The following numbered paragraphs (numbering is provided to facilitate review) describe radwaste related changes which have the potential to impact:

(a) the design basis, assumptions, etc. for waste management and interfacing systems, (b) the release of radioactivity, (c) ALARAprogram requirements, (d) maintainability and accessibility functions, and (e) accident analyses described in FSAR Sections 2.4.12.2, 2.4.12.3, 2.4.13,3, 11.6, 15.7 The proposed actions alter the expected daily inputs and activities to each of the three liquid waste management subsystems (liquid radwaste, chemical and laundry) including usage factors for pumps and processing equipment, batch frequencies, and flow rates as well as routine releases from the gaseous waste management system. Study EC-RADN-1044, documents the design and operational changes resulting from the proposed actions, their bases and the resulting changes in FSAR Tables 11.2-1, 2, 3, 4, 8, 10, 11 and flow diagram Figure 11.2-8. In addition to demonstrating that the treatment systems provided are capable of satisfying the anticipated processing requirements of the Station, this information is used as input for estimating expected and design basis activities in radwaste system equipment and for estimating offsite liquid and gaseous radioactive releases and doses to demonstrate the ability for compliance with the requirements of 10CFR20 and 10CFR50, Appendix I.

Estimates of the revised radioactive releases and doses are evaluated in EC-RADN-1041.

This calculation documents the changes in the assumptions and parameters used for estimating the expected reactor coolant activity, liquid and gaseous radioactive releases, off-site doses and the resulting changes to FSAR Tables 11.2-8, 9, 12, 13, 14, and 15, 11.3-1, 2, 3, and 7. EC-RADN-1059 evatuates the changes in the parameters and estimated airborne activity in the various buildings as presented in FSAR Tables 12.2-30 through 37. 'The results of the these NUREG-0016 related analyses demonstrate continued compliance with the requirements of 10CFR20 and 10CFR50, Appendix I, as contained in 0776. 'UREG EC-RADN-1047 evaluates the impact on the expected and design basis activity inventories in liquid waste management system components and the resultant changes to FSAR Tables 11.2-5 and 6.

The processing and packaging of solid wastes is in accordance with NDAP-QA-0646 (Solid Waste Process Control Program) which ensures that the processing and shipping of solid waste is in accordance with applicable NRC and DOT regulations. EC-RADN-1052 documents the design and operational changes that have been made to the solid waste FORM NDAP-QA-0726-1, Rev. 2, Page 10 of 25

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management system and the resultant changes to FSAR Tables 11 4-1 through 4 and flow

'iagram Figure 114-3. The changes in the estimates of expected and'design basis radionuclide inventories in the SWMS components provided in FSAR Tables 11 4-5, 6, and 7 are evaluated in EC-RADN-1048.

The proposed actions do not create a new release pathway to the environment nor will they result in the contamination of a non-radioactive system or reduce the physical or administrative barriers between a radioactive and a non-radioactive system or release point.

Therefore, there is no change in the NRC IE Bulletin 80-10 System or Effluent Pathway classification in the ODCM. However, the liquid and solid waste management system flow diagrams and the definition of appropriate treatment in the ODCM require updating to be consistent with the proposed actions discussed above. (This statement satisfies .the requirements of Section 6.3.7 of PP&L Procedure NDAP-QA-0726)

In support of the current licensing basis update of the FSAR, EC-RADN-1054 piovides updates to and verification and validation for the waste management system component design data tabulated in FSAR Sections 11.2, 11.3, and 11.4.

Curbs and elevated threshold as described in FSAR Section 11.2.2 and discussed in CR 97-3393, are provided as an aid in containing and minimizing the spread of contamination from leaks or spills in rooms housing radioactive liquid containing components. The equipment and floor drainage system is considered the primary means of accomplishing this design objective. These features are not safety related, provide no safety function and were originally provided, where deemed necessary, as part of standard engineering/design practice.

The equipment and floor drainage system provides for the collection of various liquid wastes and routes liquids that are potentially radioactive back to the liquid radwaste, chemical radwaste or laundry/detergent processing subsystems, as appropriate. The drainage sources and expected inputs to this system from areas of potential radioactivity are given in FSAR Table 11.2-1. For the diywell and radwaste buildings, the maximum expected leakage from equipment is used as the design basis for this system. Other buildings utilize other influent (e.g. fire protection system operation etc.) as the design basis for this system. Since no change has been made in the estimated influent floor and equipment drain quantities for the drywell and radwaste building (refer to EC-RADN-1044),

there is no impact to the operation of the equipment and floor drainage system.

The condensate cleanup system utilizes ultrasonic resin cleaning for processing the condensate demineralizer resins. The equipment to perform chemical regeneration of resins has not been removed from the plant but is no longer used. CR 96-0419 documents that chemical regeneration of condensate demineralizer resins has not taken place since 1984 and the system description contained in the FSAR is outdated relative to plant operating practice. CR 97-0762 and 97-2219 document that the use of ultrasonic resin cleaning will significantly change the input volume to the turbine building outer area drains and the inputs from this source to the liquid waste management system as well as the input volumes from the regeneration waste surge tanks to the waste sludge phase separator in the solid waste management system. The impact of this revised interface on the operation of the radwaste system is quantified in EC-RADN-1041, 1044, 1047, 1048 and 1052. Also FSAR Table 11.2-7, which provides estimated expected and design basis activity concentrations in the condensate demineralizer regeneration chemical wastes, reflects historic information with the use of ultrasonic resin cleaning. Due to the increase in the time eriod for the buildu of activi between cleanin s to 30 da s for articulates/7 da s to 2 FORM NDAP-QA-0726-1, Rev. 2, Page 11 of 25

~~ )

years for fission and halogen isotopes), the design basis shielding source terms for the condensate demineralizers are increased. This increase affects previously predicted area dose rates and radiation zoning.

The changes in the reactor water cleanup system that impact the operation of the liquid and solid waste management system are described in EC-RADN-1044 and 1052. The installation of sealless pumps per DCP-90-3035 and 90-3036 has eliminated the input to the liquid radwaste system from this source. Also, improvements in the RWCU system performance have resulted in a decrease in the backwash frequency and volume associated with processing the RWCU filter demineralizers. Typically a RWCU filter is backwashed/precoated every 21 days per unit in lieu of the 7 days previously assumed.

'Also based on operating experience, only one batch of exhausted resins from the RWCU filter demineralizers is transferred to the backwash receiving tank instead of the two previously assumed. Changes in these parameters/assumptions impact the bases previously utilized in assessing demineralizer, RWCU backwash tank, and RWCU phase separator activity content and consequently localized estimates of dose rates and radiation zoning. The change in expected and design basis component activity content is addressed in EC-RADN-1048.

The changes in the operation of the fuel pool cleanup system relative to the liquid and solid waste management systems are detailed in EC-RADN-1044 and 1052. The changes

'n the operation of this system relative to that previously considered include such items as:

there are three fuel pool filters (unit 1, 2, and common) rather than two; only one batch of exhausted resin /precoat is collected in the backwash receiving tank rather than two; the fuel pool backwash receiving tank is processed to the RWCU phase separator rather than the waste sludge phase separator; the fuel pool F/D is seldom backwashed, current experience is a total of three backwashes and precoats before an outage per year. Similar to the RWCU, these changes impact the bases previously utilized in assessing the activity content of the fuel pool F/D, the backwash receiving tank and the RWCU and waste sludge phase separators and consequently localized estimates of dose rates and radiation zoning in areas where this equipment is located. The change in component activity content is addressed in EC-RADN-1048.

The interfacing of the suppression pool cleanup system with the liquid radwaste system is a result of DCP 95-9009 which installed piping to permit transfers of. excess suppression pool inventory to the liquid radwaste system for processing in lieu of directing this waste to the hotwell. This modification was made to eliminate the negative impact of the poor quality suppression pool water on the operation of the condensate demineralizers and reactor water quality. Based upon the assessments provided in EC-RADN-1044 and 1041, this modification will not degrade the function or performance objectives considered as part of the LWMS design basis.

The impact of the proposed actions on the effectiveness of the radwaste, turbine and reactor building HVAC systems to maintain a suitable environment for personnel during normal operations and anticipated operational occurrences is evaluated in EC-RADN-1059.

The effectiveness of these systems in maintaining gaseous radioactive releases and doses within the requirements of 10CFR20 and in compliance with the guidelines of 10CFR50 Appendix I is demonstrated in EC-RADN-1041.

8. The process valve stem leakoff collection system was originally designed and provided to minimize radioactive release from the turbine building. The NUREG 0016 analyses resented in EC-RADN-1041 reflect a factor of 5 reduction in the antici ated aseous l

FORM NDAP-QA-0726-1, Rev. 2, Page 12 of 25

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releases from the turbine building as a result of. this installation of this system. The impact of recent changes in the process valve stem leakoff collection system design basis is evaluated in EC-045-0537. The proposed actions do not impact this system The proposed actions do not affect those portions of the process and effluent radiation monitoring system that initiate ESF systems nor are there changes in the process lines or waste streams that would require new ESF initiations or different setpoints for ESF initiations. The control and monitoring of radioactive releases and doses are not affected by the proposed actions.

10. The proposed actions may have localized effects on the area radiation monitoring system due to changes in the radiation source terms associated with affected equipment and the concomitant impact on area radiation dose rates and radiation zoning. This, of course, is dependent upon the degree and extent of plant operations with failed or contaminated fuel.

The replacement of the reactor and turbine building sampling stations (DCP 90-3032 8 90-9025) has altered the interface between the liquid radwaste and the sampling system as previously considered in assessing routine releases and doses. The impacts of these changes are considered in EC-RADN-1044 and 1041.

12. The proposed actions will alter the design basis shielding source terms that were utilized in the design of plant shielding and for establishing radiation zones for radwaste related components. The existing shielding design in conjunction with the SSES ALARA Program will be utilized to ensure continued compliance with the dose regulations of 10CFR20 and 10CFR50.

13. The changes in the design and operation of the radwaste systems do alter the expected and design basis activity content for the offsite shipping containers described in FSAR Table 11.4-7 for the SWMS. The impact of these changes is addres'sed in EC-RADN-1048.

However, since this data was not utilized in the design and accident analyses presented in Section 11.6 for the low level radwaste holding facility, the effect of the proposed actions on the LLRWHF will be addressed in a separate safety evaluation being prepared for the CLB update to FSAR Section 11.6.

14. FSAR Sections 2.4.12.2, 2.4.12.3, and 2.4.13.3 document the analysis of the potential effects of a postulated radioactive liquid release to the groundwater due to single failures involving tanks and comporients containing radioactive materials located outside containment in accordance with SRP 15.7.3. The proposed actions will impact the analysis and results presented in these sections. The result of the analysis is to demonstrate compliance with 10CFR20 limits at the nearest potable water supplies in an unrestricted area. EC-RADN-1069 has been prepared to address the impact of the proposed actions on this analysis.

15. FSAR Section 15.7 evaluates the radioactive release from subsystems and components. Of the accidents considered, the proposed actions do have the potential to impact Sections 15.7.1, Gaseous Radwaste System Leak or Failure, 15.7.2 Liquid Radwaste System Failure, and 15.7.3 Postulated Radioactive Releases due to a Liquid Radwaste Tank Failure analyses and results. Other design basis accidents described in Chapter 15 are unaffected. EC-RADN-1064 has been prepared to address and document the offsite dose consequences for applicable accident scenarios..

FORM NDAP-QA-0726-1, Rev. 2, Page 13 of 25

0 I

. Does the proposed action increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety, as previously evaluated in the SAR? (Include specific reference to FSAR sections that are applicable.)

YES NO Provide a discussion of the basis and criteria used in arriving at the above conclusion.

The proposed actions do not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the SAR.

The following licensing design basis descriptions, associated safety evaluations, and analyses were considered in the evaluation of the proposed changes:

FSAR Section 2.4.12.2 Accidental Releases FSAR Section 2.4.12.3 ENuent Dilution FSAR Section 2.4.13, Groundwater FSAR Section 2.4.13.3, Accident Effects on Groundwater Quality FSAR Section 3.2, Classification of Structures, Systems, and Components FSAR Section 5.4.8, Reactor Water Cleanup System FSAR Section 6.2.4.3.3.8, Suppression Pool Cleanup and Drain FSAR Section 9.1.3, Fuel Pool Cooling and Cleanup System FSAR Section 9.2.10, Condensate Storage and Transfer System FSAR Section 9.3.2, Sampling System FSAR Section 9.3.3Equipment and Floor Drainage System FSAR Section 9.4.2, Reactor Building HVAC System FSAR Section 9.4.3, Radwaste Building HVAC System FSAR Section 9.4.4, Turbine Building HVAC System FSAR Section 10.4.6, Condensate Cleanup System FSAR Section 11.1, Source Terms FSAR Section 11.2, Liquid Waste Management System FSAR Section 11.3, Gaseous Waste Management System FSAR Section 11.4, Solid Waste Management System FSAR Section 11.5, Process and Radiological Monitoring and Sampling Systems FSAR Section 11.6, Low Level Radwaste Storage Facility FSAR Section 12.2, Radiation Sources FSAR Section 12.3, Radiation Protection Design Features FSAR Section 12.4, Dose Assessment FSAR Section 15.7, Radioactive Release From a Subsystems or Components NUREG 0776, SSES Safety Evaluation Report Offsite Dose Calculation Manual Based on a review of the above listed FSAR Sections, changes in the radwaste system design and operation which may have an impact on accidents'or malfunctions of equipment important to safety are discussed in paragraphs below. (Paragraphs are numbered to facilitate review FORM NDAP-QA-0726-1, Rev. 2, Page 14 of 25

II I

The probability of a failure of tanks and associated components which could contain

~

radioactive liquids outside containment as analyzed in FSAR Section 2.4.12.2, 2.4.13.3, 15.7.2 and 15.7.3 is not changed since all physical modifications which involved changes in system piping and components were performed. in accordance with codes and standards specified in FSAR Section 3.2, including the requirements for Class "D" Augmented.

The gaseous radwaste system leaks or failures analyzed in FSAR Section 15.7.1 address the following postulated accidents: main condenser offgas treatment system failure; malfunction of main turbine gland sealing system; and failure of air ejector lines. The proposed actions do not affect any of these components, therefore the probability of occurrence of any of these events is not changed.

2. The consequence of a gaseous radwaste system leak or failure described in FSAR Section 15.7.1 is not changed since the proposed actions do not alter the radiation source terms or-other assumptions and parameters utilized in assessing the consequences of these failures.

FSAR Sections 2.4.12.2, 2.4.12.3, and 2.4.13.3 evaluate the potential consequences of a postulated release of radioactive liquids to the groundwater due to single failures involving tanks and components containing radioactive materials located outside the reactor containment. The analysis presented in the FSAR and the SSES SER reflects a postulated rupture of the radwaste evaporator concentrates tank and the unimpeded release to the groundwater. The results of the analysis demonstrated compliance with 10CFR20 limits at the dosest potable water supplies in an unrestricted area.

Based upon the changes made in the'esign and operation of liquid and solid waste

~

management systems, where the evaporator concentrates tank is not used, the RWCU phase separator tank was found to contain the highest expected radioactive inventory.

Component activity inventories are documented in EC-RADN-1047 and 1048 for the liquid and solid waste management system components, respectively. EC-RADN-1069 evaluates the rupture of the RWCU phase separator, in accordance with SRP 15.7.3 guidance, and demonstrates continued compliance with 10CFR20 limits at the closest potable water supply in an unrestricted area. This analysis also updates the surface and groundwater hydrology relative to the installation and use of onsite production wells and the locations of off-site wells utilized as sources of potable water

4. Liquid Radwaste System Failure is analyzed in FSAR Section 15.7.2 which identifies the bounding scenarios as a feedwater pipe break outside containment or a main steam pipe break outside containment (FSAR Subsections 15.6.6 and 15.6.4 respectively). FSAR Section 15.7.2 also addresses other potential releases outside containment which include small spills and leaks of radioactive materials inside structures housing processing equipment. Conservative values for leakage have been assumed and included in the assessment of routine plant liquid and gaseous releases in EC-RADN-1041 which demonstrated compliance with the 10CFR50 Appendix I guidelines. The offsite dose that would result from any small spill which could occur outside containment, would be

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negligible in comparison to the dose resulting from these routine releases.

FSAR Section 15.7.3.5 evaluates the potential offsite radiological effects of a postulated radioactive release to the atmosphere due to the failure of a LWMS component with the greatest amount of iodine inventory. The analysis presented in the FSAR and considered in the SSES SER utilizes the design basis iodine inventory in the evaporator concentrates tank. The results of this analysis demonstrated compliance with the acce tance criteria contained in SRP 15.7.2.

FORM NDAP-QA-0726-1, Rev. 2, Page 15 of 25

~ ll Based upon the changes made in the design and operation'f the liquid and solid waste management systems, the RWCU phase separator (in lieu of the evaporator concentrates tank) was identified as the component with the highest iodine inventory for the radioactive liquid containing components located outside of containment (per EC-RADN-1047 and 1048). EC-RADN-1064 evaluates the radiological consequences of the'failure of the RWCU phase separator, based on the assumptions and guidance provided in SRP 15.7.2, and concludes that the resulting radiological doses remain at a small fraction of 10CFR100 limits and well within the SRP 15.7.2 guidelines of 0.5 rem whole body and 1.5 rem thyroid from gaseous releases at the site boundary.

FORM NDAP-QA-0726-1, Rev. 2, Page 16 of 25

IV Does the proposed action create a possibility for an accident or malfunction of a different type than any evaluated previously in the SAR? (Include reference to specific FSAR sections applicable.)

YES NO Provide a discussion of the basis and criteria used in arriving at the above conclusion.

The proposed actions do not create a possibility for an accident or malfunction of a different type than any previously considered in the SAR.

The systems that are directly or indirectly affected by the changes in the radwaste related changes do not perform any safety function nor do they interface with the safety related portion of those systems that are 'classified as safety related. A review of the FSAR and the SER was conducted to determine the impact on the accidents and malfunctions considered.

As discussed in Section III, the only accidents affected involve radioactive releases from subsystems and components and no credit for the active function of components important to safety is assumed for those accidents previously evaluated in the FSAR and SER.

Therefore, the modifications and radwaste related system changes do not create a possibility for an accident or malfunction of a different type than previously considered.

FORM NDAP-QA-0726-1, Rev. 2, Page 17 of 25

Lf lt I

V Does the proposed action reduce the margin of safety as defined in the basis for any Technical Specification? (Include reference to specific Technical Specification sections that are applicable.)

YES NO Provide a discussion of the basis and criteria used in arriving at the above conclusion.

There is no reduction in the margin of safety defined in the basis of any Technical Specification.

The following Technical Specifications and equivalent Improved Technical Specifications which would be contained in the Technical Requirements Manual'were reviewed in addressing the proposed changes in the design and operation of the radioactive waste management and interfacing systems:

3/4.3.7.10 Radioactive Liquid Effluent Monitoring Instrumentation 3/4.3.7.11 Radioactive Gaseous Effluent Monitoring Instrumentation 3/4.11 Radioactive Effluents, as follows:

3/4.11.1, Liquid Effluents 3/4.11.2, Gaseous Effluents 3/4.11.3, Solid Radwaste System 3/4.11.4, Total Dose Technical Specification 3/4.3.7.10 addresses the radioactive liquid effluent monitoring instrumentation requirements. The basis for this Tech Spec is to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases of liquid effluents. The alarm/trip setpoints of these instruments shall be calculated in accordance with the procedure described in the ODCM to ensure the alarm/trip will occur prior to exceeding the limits of 10CFR20.. The operability and use of this equipment are consistent with the requirements of GDC 60,'3 and 64 of App. A of 10CFR50. There is no reduction in the margin of safety defined in the basis of this Tech Spec since the proposed actions will not change or affect the procedure in the ODCM for determining alarm/trip setpoints.

The basis for Gaseous Radwaste Effluent Instrumentation in Technical Specification 3/4.3.7.11 is similar to the liquid effluent monitoring instrumentation described above.

In addition, the gaseous instrumentation provisions include monitoring (and controlling) the concentrations of potentially explosive gas mixtures in the waste gas holdup system. Since the proposed actions do not affect the gaseous radwaste system nor do they change the chemistry of gaseous radwaste, there are no impacts to the margin of safety defined in the basis of this specification.

Liquid Effluents Technical Specification 3/4.11.1 is provided to: 1) ensure that the concentration of radioactive materials released in liquid waste effluents to unrestricted areas will be less than the concentration levels specified in 10CFR20, 2) implement the dose requirements of 10CFR50, Appendix I, and 3) define the operability requirements of the liquid radwaste treatment system so that it will be available whenever liquid effluent requires treatment prior to release to the environment.

FORM NDAP-QA-0726-1, Rev. 2, Page 18 of 25

I EC-RADN-1041 and EC-RADN-1071 demonstrate that with the changes made in the radwaste system that the margin of safety defined in items 1 & 2 of the basis of this specification is maintained and is in compliance with the requirements of 10CFR20 and 10CFR50, Appendix I Based on the results presented in these calculations, there is no significant change in the estimated quantity or concentrations of radioactive materials released to unrestricted areas from the liquid pathway.

The original FSAR (& SER) analysis was performed using revision 0 to NUREG 0016.

Due to changes made in revision 1 to NUREG 0016, (i.e., calculational methodology, updated radiation source terms, etc.), a quantitative comparison with the previously calculated FSAR doses cannot provide meaningful conclusion regarding reductions in the margin of safety. However, these reanalyses, that reflect the proposed actions and are performed utilizing updated NUREG guidance, demonstrate continued compliance with the dose criteria of 10CFR50, Appendix I. This is shown in Table 3 of the Appendix to this safety evaluation The operability requirements of the liquid radwaste system are not changed by the cumulative effect of the proposed actions.

Gaseous Effluents Technical Specification 3/4.11.2 is provided to ensure that the doses at any time at and beyond the site boundary from gaseous effluents from all units on the site are within the annual dose rate and dose limits of 10CFR20. The margin of safety defined in the basis of this specification is compliance with 10CFR50, Appendix I guidance utilizing NUREG 0016. This compliance is documented in EC-RADN-1041 and EC-RADN-1072.

Due to changes made in the NUREG 0016 calculational methodology (use of Rev. 1 versus Rev. 0), NUREG 0016 source terms, and updated offsite critical locations (used in EC-RADN-1041), a quantitative comparison with previously calculated FSAR doses-cannot provide meaningful conclusions regarding a reduction in the margin of safety.

However, as shown in Table 3 of the Appendix to this safety evaluation compliance with the dose criteria of 10CFR50. Appendix I is maintained.

The operability of the solid radwaste system in Technical Specification 3/4.11.3 ensures that the system will be available for use whenever solid radioactive wastes require processing and packaging prior to being shipped off-site. This specification implements the requirements of 10CFR50.36a and GDC 60 of Appendix A to 10CFR50. The process parameters included in establishing the Process Control Program include, but are not limited to waste type, waste pH, waste/liquid/solidification agent/catalyst ratios, waste oil content, waste principal chemical constituents, mixing and curing times. The requirements specified in NDAP-QA-0646 are applicable with the implementation of the proposed actions and will continue to ensure that 10CFR50 and GDC 60 are satisfied.

There are no changes to solid radwaste system operability requirements by the proposed actions. Therefore, the margin of safety defined in the basis of this specification is maintained.

Total Dose Technical Specification 3/4.11,4 is provided to meet the dose limitations of 40CFR190 that have been incorporated into 10CFR20. EC-RADN-1041 demonstrates that the proposed actions do not adversely affect the ability of the plant's radwaste process systems to meet the dose limitations specified in 10CFR50, Appendix I.

Therefore, there is no reduction in the margin of safety defined in the basis of this specification.

FORM NDAP-QA-0726-1, Rev. 2, Page 19 of 25

VI Does the proposed action involve a change in a Technical Specification?

YES NO If "YES", NDAP-QA-0731 "Technical Specification Changes" applies. A 'YES" answer does not preclude activity up to a point just before it would physically affect the functioning of the plant.

Provide a discussion of the basis and criteria used in arriving at the above conclusion.

If appropriate, describe the extent of activity and why it should be allowed to proceed prior to the Technical Specification change.

The proposed actions do not require a change to the technical specifications; Major changes as identified in Section II (and associated Appendix) of this safety evaluation require reporting in the monthly and annual operating reports under Technical Specifications 6.9.1.6, 6.9.1.7, 6.9.1.8, 6.13, 6.14 and 6.15.

The Unit 1 and 2 Technical Specification were reviewed with particular attention directed toward radiological effluent and dose requirements per TS 3/4.11: for Liquid Effluent, (3/4.11.1), Gaseous Effluent (3/4.11.2), Solid Radwaste System (3/4.11.3),

and 3/4.11.4 Total Dose to determine if any of the proposed changes would involve a change to these existing or their equivalent improved technical specifications (or technical requirements manual). These specifications are provided to ensure that the off-site dose at any time, from radioactive liquid and gaseous effluents, and direct radiation where applicable, will be within the dose limits of 10CFR20. The specification limits provide reasonable assurance that the radioactive materials discharged from the plant will be as low as reasonably achievable and consistent with the guidance provided in 10CFR50, Appendix I. The proposed actions will not impact'the ability of the radwaste systems and equipment to perform their design function and will not affect existing or improved technical specifications requirements or their bases.

Although the proposed actions do not require a change to the technical specifications, the major changes to the radioactive waste treatment system require reporting in the monthly and annual operating reports under Technical Specifications 6.9.1.6, 6.9.1.7, 6.9.1.8, 6.13, 6.14 and 6.15.

FORM NDAP-QA-0726-1, Rev. 2, Page 20'of 25

Vll Does the proposed action create the need to make an application for amendment to the license other than to Appendix A?

YES No H Provide a discussion of the basis and criteria used in arriving at the above conclusion.

The proposed action does not create the need to make an application for amendment to the facility license.

A review of the Unit 1 and Unit 2 Licenses has been performed. Based upon the discussions provided in the above sections; the proposed actions do not create an unreviewed safety question and do not change any licensing commitments. The changes in the design, 'operation, and analyses for the radwaste and interfacing systems will be addressed via FSAR, ODCM and PCP Change Notices. No amendment to either Unit License is required.

FORM NDAP-QA-0726-1, Rev. 2, Page 21 of 25

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APPENDIX CONDITION REPORTS 97-0762 8 97-2219 ITEM

SUMMARY

TABLES FORM NDAP-QA-0726-1, Rev. 2, Page 22 of 25

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'I A ill.l'. I

( I< 97-II7r '/SAI( ('IIAI'Iill( I I 2 I.lf)(ill)iiVAS'I'I:MANAGEMEN1'YSTEM SAFETY SAFETY SAFETY FSAR FSAR 5059 DET EVALUATION EVALUATION EVALUATION CHANGE CHANGE ITEM NO DESCRIPTION PERFORMED REQUIRED PFRFORMED REFERENCES REQUIRED PERFORMED REMARKS Mobile Liquid Processing used for chemical waste Yes Yes Yes DCP 82-155. NL Yes Yes Major Change 93-008 OP.68-122 Modification Chemical Processing is w/o regeneration & w/o evaporahon Yes Yes Yes DC P 92-9056, NL Yes Yes Majot Change 92.004,OP-68-122 Modification

13. 14 URC changed input volume lo turbine bldg outer area and Yes Yes Yes DCP 82-311, Yes Yes Major Cha Waste Stud e Phase Se arator WSPS 201742 8echtel 112 No Modifica 23 Tabulated activit data chan ed These items are secondary changes due to Major Changes Yes 8 Tbl 11 2-1 in ut volumes have chan ed For this reason. none of these changes have specific 50.59 Yes No 12 Aux boilers not used w/o eva ration Delerminalion or Safety Evaluation Yes No 19 Tbl 11 2 3usa e factors have chan ed Yes No 24 Tbl I I 2.8 Cond demin data has chan ed Yes 26 Tb!112.1 100aclion of PCA has chan ed Yes No 27 Tbl 11 2.11 holdu bmes have cha ed Yes 28 Tbl 11.2.10DF Ior chem ioc have chan ed Yes No

6. 25 100% of processed chem ical waste is discharged not 5 ir Yes Yes Yes DC P 92-9056. NL Yes No Major Change 92-004 Modification Laundry sent offsite. subsystem waste stream is decon Yes Yes Yes DCP 91-9003 Yes Yes Modification & plan!

solutions. ex erience Su resslon I excess tranfer to radwaste Yes Yes Yes DCP/NL 95-9010 Yes No Modification RWCU pump seal leakage has been eliminaled Yes Yes Yes DCP90-3035C &D, Yes Yes Modification 90-3036 11.2 No 10, 11 LRW input from RB&TB Sampling has changed Yes Yes Yes DCP 90-3031. 90- Yes Yes Modification 3025 21 Batch size for LRW coll surge & sample lanks has changed Yes Yes Yes DCP 93-9054 Yes Yes Modificallon set int ch Activit based on one refuel outa e /unit No Yes Yes No Plant Ex erie LRW filters:diatomaceous earth is not used and fillers are both No Yes No Yes No Plant Experience in series 3.20 LRW Cilter cake is not dried & processing rate is 40 lo160 gpm Yes Yes No Yes Plant Experience nol 200 m 15 RWCU. LRW filter. fuel pool backwash frequency & volume No Yes No Yes No Plant Experience has chan ed Tbl11.2-2& 4 16 There are 3 fuel I filters not 2 in Table 11.2.2 No Yes No Yes No Plant Ex erience 17 RWCU hasese arators rocessed er rnot60da No Yes No Yes No Plant Ex erience 18 Fuel I backwash sent to RWCU rather than WSPS Yes Yes No Yes No Plant Ex erience Flow rate to lant dischar eis 100 not 200 m Tbl 11.2-4 Yes No Plant Ex enence Major Changes are defined as a change lo a radwasle treatment system, procedure. operation, or design which has the potential lo increase dose consequences or mate/lai releases from that previously predicted in Ihe license application or amendments, Plant Modifications are those system changes that have been made In accordance with the design change program (DCP). Plant Experience represents changes in operating expectations. parameters. and practices which differ from the original design description presented ln the FSAR.

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('I( 'I -'219 I"SAlt ('ll ill'I'I'.I( I I 4 S()l.ll) KA!II'I'.MANAGI:h1ENTSYSTEM SAFETY SAFETY SAFETY FSAR FSAR 50 59 DET E VALUA7 ION EVALUATION EVALUATION CHANGE CHANGE ITEM NO DESCRIPTION PERFORMED REQUIRED PERFORMED REFERENCES REQUIRED PERFORMED REMARKS Mobile Processing sokd waste Peimenant cement SOrificatn Yes Yes Yes DCPs82-155. Yes Yes Major Change system nol used 82.243. 82.512A. Modification 82.512 B, PORC 82-234, NL 93-008 LRW filters not used lo dewater wastes Yes Yes Yes Yes No Major Modificali 17 Figure 11 4.3 Flow diagram is not accurate These items are secondary changes due lo Major Changes. For this Yes Major Change and reason. none ol these changes have specific 50 59 Determination or Plant Experience Safely Evaluation 19 Tbl 11 4 8 Dewatered cake slurries is not a kcable Yes Ma or Chan e Radwate evaporatois nol iun Yes Yes Yes OP-068.122 Yes No Major Change;(item 4 CR 97%762 Resin is dischar ed rathei Inan r eneiared Yes Yes Yes Ma or Chan e URC is operated Yes Yes Yes DCP 82-311. Yes Major Change 201742 Bechtel Modificatloij 12 Tbl 11 4-1 does nol include mobile liquid deposal vorumes These items are secondary changes due lo Major Changes. For this Yes Major Change reason. none of these changes have specilic 50,59 Determination or Safety F valuahon 13 Tbl 11 4.1 fre uenc and volumes are not accurate Yes Ma or Chan e 14 Tbl.11.4-4 fre uenc volume and Itow rate data is not accurate Yes No Maor Chan e 15 Tbl.11.4-3 ui ment usa efactorshavechan ed Yes No Ma or Chan e 18 Activit informatio in tables is not accurate Yes No Ma or Chan e 16 Dis osaldatain Table 11.4-2 DAW haschan ed No Yes Yes No Ma or Chan e Control rod blade re lacement lre uenc is slated as annual Yes Yes Plant Ex rl 21 LRW filters not a sotids in ut to WSPS in Tbl 11.4-4 Yes No Plant Ex rler 22 H raulic Press/Trash Com actor is nol used for DAW No Yes No Yes No Plant E erience Fuel pool backwash lo RWCU phase separator rather than Duplicate: (Same as item 18 in CR 97-0762)

WSPS 10 RWCU hase se arators switched annuall not 60da interval Duplicate: (Same as item 17 in CR 97-0762)

LRW filter cakes are not dried Du licate: Sameasitem3!nCR97%762 One RWCU backwash in RWCU backwash tank Du licate: Same as item 15 ln CR 97%762 One fuel I backwash er fuel I backwash tank Du Iicate: Same as item 15 ln CR 97-0762 20 Diatom earth and bod feed is nol used on filters Du kcate: Sameasitem3rnCR97-0762 Major Changes are defined as a change to a radwaste treatment system, procedure, operation, or design which has the potential to increase dose consequences or material releases from that previously predicted in the license application or amendments. Plant Modifications are those system changes that have been made in accordance with the design change program (DCP). Plant Experience represents changes in operating expectations, parameters, and practices which differ from the original design description presented in the FSAR.

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TABLE 3 CALCULATED DOSE COMMITMENTS TO A MAXIMUMINDIVIDUAL FROM THE OPERATION OF THE SUSQUEHANNA SES COMPLIANCE WITH 10CFR50 APPENDIX I 10CFR50 Appendix. I Calculated Liquid Effluents Design Objective Annual Dose /Unit Per Unit (mrem/yr)

(mrem/ r)

Total Body Dose from all pathways 3 0.05 Adult Dose to any organ from all pathways 10 0.14 Child. Bone Noble Gas Effluents 10CFR50 Appendix. I Calculated At The Site Boundary Design Objective Annual Dose /Unit Per Unit (mrem/yr)

(mrem/yr))

Gamma Dose in Air 10 5.0 Beta Dose in Air 20 6.7 Total Bod of an Individual 5.0 3.3 Skin of an Individual 15.0 9.2 Radioiodines and Particulates 10CFR50 Appendix. I Calculated at Nearest Critical Locations Design Objective Annual Dose /Unit Per Unit (mrem/yr)

(mrem/ r)

Dose to any Organ 15.0 3.4 Infant Th roid Dai Dose to any Organ 15.0 8.0 Child Bone (Garden Note: 7.9 mrem of the total of 8.0 mrem is from assumed C-14 ingestion based on NUREG 0016, R1

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SAFETY EVALUATION

SUMMARY

Title: Current Licensing 8asis Update for Liquid, Gaseous, and Solid Waste Mana ement S stems - FSAR Sections 11.2, 11.3, and 11.4 NL-97%87 Descri tion of Chan e:

Update the design basis, system descnptions and evaluations pmvided in the FSAR for the Liquid, Gaseous and Solid Waste Management Systems to reflect the as built design conditions, operating practices and current interfaces.

This evaluation also addresses items contained in CRs 97~93, 97%762, 97-2219 and 964419:

SUMMARY

A.

The licensing design basis, descnptions and safety evaluations contained in FSAR Section 2, 3, 5, 6, 9, 10, 11, 12, 15, NUREG 0776, and the ODCM were considered in conduding that the proposed actions do not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety, as previously evaluated in the SAR. The accidents or malfunction of equipment important to safety that were previously evaluated and could be affected by the proposed actions involve the failure of tanks and components, located outside containment. containing radioactive liquid. gases. and solids. These failures are evaluated in FSAR Section 2.4 and 15.7.

The probability of a failure of tanks and associated components which could contain radioactive liquids outside containment as analyzed and described in FSAR Sections 2.4.12.2. 2.4.12.3, 2.4.13.3, 15.7.2 and 15.7.3 is not changed by the proposed actions since all physical modifications which involved changes in system piping and components were performed in accordance with codes and standards specified in FSAR Section 3.2, induding the requirements for Class "D Augmented Witn the implementation of the proposed actions, the consequences of an unexpected and uncontrolled release of radioactivity that is stored or transferred in a waste system. as described in FSAR Sections 2.4.12.2.

2 4 12.3. 2 4 13.3. 15.7.2 and 15.7.3. is less than the radionudide concentrations of 10CFR20, Appendix B, Table IIColumn 2 from liquid releases at the nearest potable water supply in an unrestricted area and is a small fraction of 10CFR100 guidelines. i e 0 5 rem whole body. 1.5 rem thyroid, from gaseous releases at the site boundary The gaseous radwaste system leaks or failures analyzed in FSAR Section 15.7.1 consider the following postulated accidents: main condenser offgas treatment system failure: malfunction of main turbine gland sealing system: and failure of air elector lines The proposed actions do not affect any of these components.

therefore the probability of occurrence and consequences of any of these events is not changed.

The proposed actions do not involve a postulated initiating event which would create the possibility of an accident of a different type and will not adversely affect any structures. systems . or components in performing its safety function.

Therefore. the proposed actions do not create the possibility for an accident or malfunction of a different type than any previously evaluated in the SAR.

FORM NDAP-QA-072&4. Rev. 0. Page 1 of i

C.

The following Technical Specifications and equivalent Improved Technical Specifications/Technical Requirements Manual were reviewed in addressing the proposed changes in the design and operation of the radioactive waste management and interfacing systems:

3/4.3.7.10 Liquid Radwaste ENuent Monitoring Instrumentation 3/4.3.7.11 Gaseous Radwaste ENuent Monitoring Instrumentation 3/4.3.11 Radioactive ENuents, as follows:

3/4.3.11.1, Liquid Effluents 3/4.3.11.2, Gaseous Effluents 3/4.3.11.3, Solid Radwaste System 3/4.3.11.4, Total Dose The results of this review demonstrate.that, as a result of the implementation of the pioposed actions, there will be no reduction in the margin of safety defined in the basis of these technical specifications.

In addition, an 80-10 system or eNuent pathway dassification (per ODCM) review was performed. The results of this review determined that the proposed changes will not:

1. create a new release pathway to the enviionment,

2. result in the contamination of a no~dioactive system,

3. reduce the physical or administrative bamers between a radioactive and non-radioactive system or release point.

FORM NDAP-QA<726-4. Rev 0. Page 2 of ~

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ADDITIONALSPECIFIC EVALUATIONCRI'IZRIAFOR MODIFICATIONS CONCERNIIVG RADIOACTIVEVfASTE SYSTEMS NOTE: For radioactive waste systems, the appropriate portions of 10CFR20, 30, 50, 71 and 200, tire Technical Specifications and 40CFR190 'are a pp licable.

NL-97-087 DATE 12/4/97 Does the modification conflict with the following guidelines:

a. NDAP-QA-0153, "Quality Assurance Requirements for Radwaste Management

[Group D Augmented] Systems" Yes No X N/A Because:

The proposed actions performs no modifications to portions of Radwaste Systems that are designated as Group D Augmented as defined in NDAP-QA-0153. FSAR Section 3.2 and Branch Technical Position ETSB No. 11-1 Rev. 1

("Design Guidance for Radioactive Waste Management Systems Installed in Light Water-Cooled Nuclear Power Reactor Plants" ). The proposed actions involve updating the FSAR for current licensing basis to reflect plant modifications and other changes as presented in Section II of this SE. Previous plant modifications. as referenced in the SE, were performed in a manner consistent with the guidelines presented in NDAP-QA-0153.

b. FSAR Chapters 11.2 Liquid Waste Management Systems," 11.3 "Gaseous Waste Management Systems and I I.4 "Solid Waste Management Systems" Yes X No N/A Because:

lb. Refer to Section II of the SE for specific conflicts with FSAR Sections 11.2, 11.3 8 11.4 descnptions.

c. FSAR Chapter 11.5 "Process and Effluent Radiological Monitoring and Sampling Systems" Yes No X N/A Because:

lc. Refer to Section II D of the SE. The proposed actions do not impact the process and effluent radiation monitoring system.

FORM NDAP-QA-0726-2, Rev. 0. Page I of 2 Page I of 2

Are the radiological consequences of- unexpected and uncontrolled releases of radioactivity that is stored or transferred in a waste system a large fraction of the 10CFR100 guidelines, i.e., 0.5 rem whole, body, 1.5 rem thyroid from gaseous releases. and greater than the radionuclide concentrations of 10CFR20, Appendix B, Table II. Column 2 from liquid releases at the nearest water supplies (See FSAR section 15.7.3 for more details)?

Yes No X NIA Because:

2a.'s discussed in Section III of the SE. the radiological consequences of unexpected and uncontrolled releases of radioactivity that is stored or transferred in waste systems outside containment were determined to be a small fraction 10CFR100 guidelines, i.e. less than 0.5 rem whole body and 1.5 rem thyroid from gaseous releases at the site boundary, (see FSAR section 15.7.3) and less than the radionuclide concentrations of 10CFR20, Appendix B, Table II Column 2 from liquid releases at the nearest potable water supplies ( see FSAR

~

sections 2.4.12 and 2.4.13).

t PREPARED BY:- MICHAELJ. CANIBRIA DAi'ID A. MATCHICK 'enior Engineer '214!97 skalne I lile Date FORM NDAP-QA-0726-2. Rev. 0. Page 2 of 2 Page 2 of 2

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