ML12128A173
| ML12128A173 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/16/2012 |
| From: | Sawatzke B Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| G02-12-059 | |
| Download: ML12128A173 (5) | |
Text
ENERG'Y Bradley J. Sawatzke Columbia Generating Station P.O. Box 968, PE08 Richland, WA 99352-0968 qý F. *uEWwES Ph. 509.377.4300 1F. 509.377.4150 bjsawatzke@energy-northwest.com April 16, 2012 G02-12-059 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 ONE-TIME EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50.36a(a)(2) SUBMITTAL DATE FOR THE RADIOACTIVE EFFLUENT RELEASE REPORT
References:
- 1) Regulatory Guide 1.21, Revision 2, "Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste," June 2009 (ADAMS Accession No. ML091170109)
- 2) NRC Letter to Indiana Michigan Power Company, "Donald C. Cook Nuclear Power Plant, Units 1 and 2 - One-Time Exemption from the Requirements of 10 CFR 50 Section 36a(a)(2), Submittal Date for the 2008 Radioactive Effluent Release Report (TAC NOS. ME00002 and ME0003)," March 30, 2009 (ADAMS Accession No. ML090410275)
- 3) NRC Letter to Arkansas Nuclear One, "Exemption from the Requirements of 10 CFR 50.36a(a)(2) Submittal Date for the 2010 Radioactive Effluent Release Report (TAC Nos. ME 3548 and ME 3549)," dated September 28, 2010 (ADAMS Accession No. ML100920571)
Dear Sir or Madam:
Pursuant to 10 CFR 50.12, Energy Northwest requests an exemption from the requirements of 10 CFR 50.36a(a)(2) with regards to the submittal date for the Radioactive Effluent Release Report for Columbia Generating Station (CGS). The proposed exemption is administrative in nature and requests a change to the submittal date of the report to "prior to May 1," of each year.
CGS TS 5.6.2 requires the Radioactive Effluent Release Report (RERR) to be submitted in accordance with 10 CFR 50.36a. The CGS Offsite Dose Calculation Manual (ODCM) translates this requirement for submittal of the annual RERR as being within 60 days after January 1 of each year.
ONE-TIME EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50.36a(a)(2)
SUBMITTAL DATE FOR THE RADIOACTIVE EFFLUENT RELEASE REPORT Page 2 Sixty days to prepare and submit the RERR presents an undue administrative burden on CGS personnel due to the compressed schedule for data collection, report preparation, and internal review following the closure of the reporting period. Energy Northwest is proposing a change of the ODCM specified requirement of "within 60 days after January 1" to an approach that is consistent with the Reference 1 allowance of "prior to May 1" to relieve the administrative burden.
The proposed change above does not address the 10 CFR50.36a(a)(2) requirement that the interval between submittals of the RERR must not exceed 12 months. Energy Northwest is requesting a one-time exemption to the reporting interval for the next required CGS RERR submittal to include an additional 2 months (i.e. 14 month interval between last report and next).
The proposed exemption alters the required submission date for the RERR. It does not change the information in the report and does not change the physical plant or affect plant operation.
This letter contains no new commitments.
This request is essentially the same as that made and approved for DC Cook and Arkansas Nuclear One, References 2 and 3 respectively.
If NRC approval for this one-time exemption request is received prior to February 1, 2013, Energy Northwest will submit the 2012 RERR prior to May 1, 2013. If NRC approval is received after that date, then the exemption will be applied to the 2013 RERR, i.e. submittal prior to May 1, 2014.
Should you have any questions or require additional information regarding this matter, please contact Mr. ZK Dunham, Licensing Supervisor, at (509) 377-4735.
Respectfully, BJ Sawatzke Vice President, Nuclear Generation & Chief Nuclear Officer
Enclosure:
Request for Exemption from the Requirements of 10 CFR 50.36a(a)(2)
Submittal Date for the Radioactive Effluent Release Report cc: NRC Region RIV Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C R.N. Sherman - BPA/1 399 WA Horin -Winston & Strawn RR Cowley - WDOH JO Luce - EFSEC
Request for Exemption from the Requirements of 10 CFR 50.36a(a)(2) Submittal Date for the Radioactive Effluent Release Report Enclosure Page 1 of 3 Request for Exemption from the Requirements of 10 CFR 50. 36a(a)(2) Submittal Date for the Radioactive Effluent Release Report 10 CFR 50.36a(a)(2) requires each licensee to submit a report to the NRC annually that specifies the quantity of each of the principal radionuclides released to unrestricted areas in liquid and in gaseous effluents during the previous 12 months, including any other information as may be required by the NRC to estimate maximum potential annual radiation doses to the public resulting from effluent releases. The report must be submitted as specified in 10 CFR 50.4, and the time between report submittals must be no longer than 12 months.
Columbia Generating Station (CGS) Technical Specifications (TS) 5.6.2 requires the Radioactive Effluent Release Report (RERR) covering the operation of each unit in the previous year to be submitted in accordance with 10 CFR 50.36a. Originally, CGS TS required this report be submitted within 60 days after January 1 of each year, which was consistent with the 10 CFR 50.36a regulations in existence during initial plant licensing and Regulatory Guide 1.21 Revision 1 (Reference 1). Subsequently, the Radioactive Effluents Technical Specifications were relocated to the Offsite Dose Calculation Manual (ODCM) as allowed by Generic Letter 89-01, retaining the "60 days after January 1" language for the annual submittal of the RERR.
Energy Northwest has identified that the 60 day time period presents an undue administrative burden on CGS personnel due to the compressed schedule for data collection, report preparation, and internal review following the closure of the reporting period. Energy Northwest is seeking to mitigate this undue burden by adopting the language supported by Regulatory Guide 1.21 Revision 2 (Reference 2) for submitting the annual RERR "prior to May 1," into the ODCM.
In order to support a change to a later reporting date, Energy Northwest is requesting a one-time relief from the 10 CFR50.36a(a)(2) requirement "that the interval between submittals of the Radioactive Effluent Release Report must not exceed 12 months."
The proposed exemption allows an additional two months for the data collection, report preparation, and internal review activities. Future submittals will then be made "prior to May 1." Approving the exemption will relieve CGS of unnecessary burden while continuing to ensure the subject report is submitted on an annual basis.
It should be noted that this exemption request does not affect the information to be submitted or the time period the report covers, only the date the report is submitted.
10 CFR 50.12 DISCUSSIONS Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 50 when (1) the exemptions are authorized by law, will not present an undue risk to public health or safety, and are consistent with the common defense and security, and (2) when special circumstances are present. These circumstances include the special
Request for Exemption from the Requirements of 10 CFR 50.36a(a)(2) Submittal Date for the Radioactive Effluent Release Report Enclosure Page 2 of 3 circumstances that would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation.
Authorized by Law This exemption would allow the licensee to-submit the RERR for subsequent calendar years prior to May 1 of each year, in accordance with TS/ODCM requirements. As stated above, 10 CFR 50.12 allows the NRC to grant, exemptions from the requirements of 10 CFR Part 50. The NRC staff in the past has determined that granting a similar request for another licensee does not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulation. The exemption will continue to ensure the subject annual report is submitted to the NRC in a timely manner each year.
Based on the above, the exemption is authorized by law.
No Undue Risk to Public Health and Safety The underlying purpose of the reporting requirements specified in 10 CFR 50.36a(a)(2) is to report to the Commission annually the quantity of each of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents during the previous 12 months, including any other information as may be required by the Commission to estimate maximum potential annual radiation doses to the public resulting from effluent releases. This exemption request does not affect the information required to be submitted or the time period the report covers or the frequency of the report, but only the date by which the report must be submitted. Based on the above, no new accident precursors are created by extending the submittal date for the RERR to "prior to May 1." The probability of postulated accidents is not increased. Also, based on the above, the consequences of postulated accidents are not increased.
Therefore, there is no undue risk to public health and safety.
Consistent with Common Defense and Security The proposed exemption has no relation to security issues. The common defense and security are, therefore, not impacted by this exemption.
Special Circumstances Special circumstances, in accordance with 10 CFR 50.12(a)(2)(v), are present whenever application of the exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation. As noted above, the purpose of this reporting requirement is to submit a report to the Commission annually that specifies the quantity of each of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents, including any other information as may be required by the Commission to estimate maximum potential annual radiation doses to the public resulting from effluent releases.
The proposed exemption does not affect the information required to be submitted or the time period the report covers, but only the date by which the report must be submitted.
A, Request for Exemption from the Requirements of 10 CFR 50.36a(a)(2) Submittal Date for the Radioactive Effluent Release Report Enclosure Page 3 of 3 The requested exemption provides relief from the regulation in that it affords slightly more time for report preparation and establishes a consistent report due date in compliance with the CGS TS/ODCM requirements. The current TS require future reports be submitted on an annual basis as required by 10 CFR 50.36a(a)(2).
Therefore, since the underlying purpose of 10 CFR 50.36a(a)(2) is achieved, the special circumstances of 10 CFR 50.12(a)(2)(v) for the granting of an exemption from 10 CFR 50.36a(a)(2) exists.
As demonstrated above, the requested exemption is authorized by law, does not present an undue risk to the public health and safety, and is consistent with the common defense and security. Also, special circumstances are present. Based on this, Energy Northwest believes the requested exemption should be granted for CGS.
ENVIRONMENTAL IMPACT The proposed action does not significantly increase the probability or consequences of accidents. No changes are being made in the types of effluents that may be released offsite. There is no significant increase in the amount of any effluent released offsite.
There is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action.
With regard to potential non-radiological impacts, the proposed action does not have a potential to affect any historic sites. It does not affect non-radiological plant effluents and has no other environmental impact. Therefore, there are no significant non-radiological environmental impacts associated with the proposed action.
Based on the above, there are no significant environmental impacts associated with the proposed exemption.
REFERENCES
- 1. Regulatory Guide 1.21, Revision 1, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," June 1974 (ADAMS Accession No. ML003739960)
- 2. Regulatory Guide 1.21, Revision 2, "Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste," June 2009 (ADAMS Accession No. ML091170109)