ML100200010
| ML100200010 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/06/2010 |
| From: | Benyak D M Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, NRC/FSME, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML100200009 | List:
|
| References | |
| RS-10-006 | |
| Download: ML100200010 (24) | |
Text
Exelon Generation 4300 Winfield Road Warrenville, IL 60555 RS-10-006 January 6, 2010 www.exeloncorp.com Nuclear 10 CFR 50.90 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 1,2, and 3 Facility Operating License No.DPR-12 Renewed Facility Operating License Nos.DPR-44 and DPR-56 NRC Docket Nos.50-171, 50-277, and 50-278
Subject:
Request for License Amendment to Allow Receipt and Storage of Low-Level Radioactive Waste at Peach Bottom Atomic Power Station, Units 1,2, and 3 In accordance with 10 CFR 50.90,"Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC)requests an amendment to Facility Operating License (FOL)No.DPR-12, and Renewed FOLs DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 1, 2, and 3.The proposed change revises license paragraph 2.B.(2)of DPR-12 and license paragraph 2.B.(5)of DPR-44 and DPR-56.The proposed change will enable PBAPS to possess byproduct material from Limerick Generating Station (LGS), Units 1 and 2.Specifically, the revised license paragraph would enable EGC to store low-level radioactive waste (LLRW)from LGS in the PBAPS Low Level Radioactive Waste Storage Facility (LLRWSF).The PBAPS LLRWSF already provides storage for LLRW generated at PBAPS.On July 1,2008, the EnergySolutions, LLC LLRW Disposal Facility in Barnwell, South Carolina (EnergySolutions
-Barnwell), as a LLRW disposal facility in the Atlantic Interstate Low-Level Radioactive Waste Management Compact Commission, ceased accepting LLRW shipments from out-of-compact generators.
This action, which was promulgated by the state of South Carolina, precluded the shipment of Class B and Class C (Class B/C)LLRW from EGC nuclear stations in Illinois and Pennsylvania to an outside disposal facility, since there are no other facilities that currently accept Class BIC LLRW from facilities in Illinois and Pennsylvania.
EGC will continue to dispose of Class A LLRW that is generated by these EGC nuclear stations at the EnergySolutions, LLC LLRW Disposal Complex inClive,Utah.
Due to the closure of EnergySolutions
-Barnwell to non-compact members, as well as the cost to construct alternate storage facilities, EGC has evaluated and verified the technical, regulatory, and legal acceptability of storage of Class BIC LLRW from LGS in the existing PBAPS LLRWSF.However, this evaluation also determined that a license amendment was required to implement the proposed storage strategy.
January 6, 2010 U.S.Nuclear Regulatory Commission Page 2 This license amendment request is subdivided as follows: Attachment 1 provides a description and evaluation of the proposed change Attachment 2 provides a mark-up of the PBAPS Units 1, 2, and 3 FOL pages Attachment 3 provides a technical report justifying the proposed amendment Attachment 4 provides a container drop accident analysis that is referenced in Attachment 3 The proposed change has been reviewed by the PBAPS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.EGC requests approval of the proposed amendment by December 29, 2010.Once approved, the amendment will be implemented within 30 days.In accordance with 10 CFR 50.91,"Notice for public comment;State consultation," EGC is notifying the State of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designatedStateOfficial.
There are no regulatory commitments contained in this letter.If you have any questions concerning this letter, please contact Mr.John L.Schrage at (630)657-2821.I declare under penalty of perjury that the foregoing is true and correct.Executed on the 6 th day of January 2010.
L Darin M.BenyakDirector-Licensing Attachments:
1.Evaluation of Proposed Change 2.Proposed Mark-up of FOL DPR-12, and Renewed FOLs DPR-44 and DPR-56 3.Peach Bottom LLRWSF LAR Support Technical Report Supporting Engineering Change Request (ECR)No.09-00301, December 3, 2009 4.Analysis No.PM-750, Container Drop Accident Analysis, August 13, 2009 ATTACHMENT 1 Evaluation of Proposed Change
1.0 DESCRIPTION
AND BACKGROUND
2.0 PROPOSED CHANGE
3.0 REGULATORY
FRAMEWORK AND LEGAL AUTHORITY
4.0 TECHNICAL ANALYSIS
5.0 REGULATORY
ANALYSIS 5.1 No Significant Hazards Consideration
5.2 Applicable
Regulatory Requirements/Criteria
6.0 ENVIRONMENTAL
CONSIDERATION Page 1 of 18 ATTACHMENT 1 Evaluation of Proposed Change
1.0 BACKGROUND
AND DESCRIPTION
1.1 Background
During the mid-1980s, Philadelphia Electric Company (Le., the original licensee for Peach Bottom Atomic Power Station (PBAPS)), designed and constructed an interim low-level radwaste storage facility (LLRWSF)at PBAPS.The LLRWSF was designed to store low-level radioactive waste (LLRW)on an interim basis in order to offset the postulated lack of disposal capability in the event that existing disposal facilities such as the EnergySolutions, LLC LLRW disposal facility in Barnwell, South Carolina, (Energy Solutions-Barnwell), ceased accepting LLRW from licensees that were not members of the Atlantic Interstate Low-Level Radioactive Waste Management Compact Commission (Atlantic Compact).The LLRW Policy Amendments Act of 1985 allowed compacts with operating LLRW disposalsitesto deny access to generators in states and compacts that had not developed their own disposal capacity.Prior to July 1, 2008, Exelon Generation Company, LLC (EGC)(Le., the current PBAPS licensee), transported, for permanent disposal, Class B and Class C (Class B/C)LLRW from PBAPS to EnergySolutions
-Barnwell and Class A LLRW to the EnergySolutions, LLC LLRW Disposal Complex in Clive, Utah (EnergySolutions
-Clive).On July 1, 2008, EnergySolutions
-Barnwell ceased accepting LLRW shipments fromcompact generators.
This action, which was promulgated by the state of South Carolina, precluded the shipment of Class BIC LLRW from EGC nuclear stations in Illinois and Pennsylvania to an outside disposal facility, since there are no other facilities that currently accept Class BIC LLRW from facilities in Illinois and Pennsylvania.
EGC nuclear stations in these two states will continue to transport Class A LLRW generated at those facilities to Clive for disposal.Due to the inability to ship Class BIC LLRW to an external disposal facility, the PBAPS LLRWSF will be used to store primarily Class BIC LLRW, as well as Class A LLRW, if needed.Additionally, Limerick Generating Station (LGS), Units 1 and 2 (Le., an EGC nuclear station located in Pennsylvania which did not build an LLRWSF)will need access to the Class BIC LLRW storage capacity within the PBAPS LLRWSF.Based on the cost to construct an additional Class BIC LLRW storage facility at LGS, and the excess storage capacity at the PBAPS LLRWSF, EGC has evaluated and verified the legal, technical, and regulatory acceptability of the storage of Class BIC LLRW that is generated at LGS in the existing PBAPS LLRWSF.This evaluation concluded that the proposed storage option complies with all technical and regulatory requirements.
However, the EGC evaluation determined that a license amendment is necessary to implement this proposed LLRW storage option.1.2 Description In accordance with 10 CFR 50.90,"Application for amendment of license, construction permit, or early site permit," EGC requests an amendment to Facility Operating License (FOL)No.DPR-12, and Renewed FOLs DPR-44 and DPR-56, for PBAPS, Units 1, 2, and 3.The proposed change revises license paragraph 2.B.(2)of DPR-12 and license paragraph 2.8.(5)of DPR-44 and56.The proposed change will enable PBAPS topossessbyproduct material from LGS.Page 2 of 18 ATTACHMENT 1 Evaluation of Proposed Change Specifically, the revised license paragraph would enable EGC to store LLRW generated at LGS in the PBAPS LLRWSF.The PBAPS LLRWSF already provides storage for LLRW generated at PBAPS.
2.0 PROPOSED CHANGE
The proposed license amendment revises license paragraph 2.B.(2)of FOL DPR-12 and license paragraph 2.B.(5)of Renewed FOLs DPR-44 and DPR-56, as described below.Changes to the existing license paragraphs are highlighted with italics and underlining.
DPR-12 (2)Pursuant to the Act and 10 CFR Part 30,"Rules of General Applicability to Domestic Licensing of Byproduct Material" to possess, but not to separate, such byproduct material as may have been produced by operation of the facility, and such byproduct materials as may be produced bv the operation of Limerick Generating Station.Units 1 and 2.DPR-44 and DPR-56 (5)Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30,40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of Peach Bottom Atomic Power Station, Units 2 and 3.and such byProduct materials as may be produced bv the operation of Limerick Generating Station.Units 1 and 2.3.0 REGULATORY FRAMEWORK AND LEGAL AUTHORITY Since 1981, the NRC has issued a number of generic communications providing information to licensees regarding the storage of LLRW on licensees' sites.These generic communications are summarized in Regulatory Issue Summary (RIS)2008-32,"Interim Low Level Radioactive Waste Storage at Reactor Sites." The purpose of RIS 2008-32 was to clarify the current NRC position regarding the long-term, interim storage of LLRW at facilities licensed under 10 CFR Part 50 (Part 50),"Domestic Licensing of Production and Utilization Facilities." A Part 50 licensee's legal authority to possess byproduct material that is generated at the licensee's facility (e.g., LLRW)is established by a specific paragraph in the FOL.This paragraph invokes and references 10 CFR Part 30 (Part 30),"Rules of General Applicability to Domestic Licensing of Byproduct Material," as well as 10 CFR Part 40,"Domestic Licensing of Source Material," and 10 CFR Part 70,"Domestic Licensing of Special Nuclear MateriaL" In the case of PBAPS, license paragraph 1.H in DPR-12 and license paragraph 1.1 in DPR-44 and DPR-56 authorizes the receipt, possession, and use of byproduct material in accordance with NRC regulations in Part 30.This authorization is then implemented by license paragraphs 2.B.(2)for DPR-12 and 2.B.(5)for DPR-44 and DPR-56.However, these applicable FOL paragraphs, as well as RIS 2008-32, address the legal and technical aspects of on-site LLRW storage generated by a Part 50 licensee, and are silent on the storage of LLRW generated by a different Part 50 licensee.Page 3 of 18 ATIACHMENT 1 Evaluation of Proposed Change The following discussion establishes the regulatory framework and legal authority for NRC review and approval of a Part 50 license application to possess byproduct material, source material, and special nuclear material.The discussion then extends this regulatory framework to the establishment of the NRC's legal authority to review and approve an application for a 10 CFR 50.90 license amendment request (lAR)to possess byproduct material, source material, and special nuclear material that is generated at a different facility licensed under Part 50.Multiple examples are provided where the NRC has applied this regulatory framework to exercise its legal authority to approve such an LAR.In addition, the discussion below summarizes the technical and regulatory criteria, including the regulatory source documents that would be referenced by the NRC to review and approve this type of lAR.3.1 license to Possess Byproduct Material The Atomic Energy Act of 1954, (the Act)as amended (P.L.83-703), establishes the authority of the NRC to establish by rule, regulation, or order, such standards and instructions to govern the possession and use of special nuclear material, source material, and byproduct material as the NRC may deem necessary or desirable to promote the common defense and security or to protect health or to minimize danger to life or property.1 Furthermore, the Act authorizes the NRC to issue general or specific licenses to applicants seeking to use byproduct material for research or development purposes, for medical therapy, industrial uses, agricultural uses, or such other useful applications as may be developed.
Such licenses shall be issued in accordance with the provisions of the Act and subject to such conditions as the NRC may by rule or regulation establish to effectuate the purposes and provisions of the Act.2 10 CFR 1.43,"Office of Nuclear Reactor Regulation" (NRR)establishes the responsibility and authority of NRR to develop, promulgate, and implement regulations, policies, programs, and procedures for all aspects of licensing the receipt, possession, and ownership of source, byproduct, and special nuclear material used or produced at facilities licensed under 10 CFR 50,"Licensing of Production and Utilization Facilities." In accordance with Part 50, NRR issued, by letters dated January 24, 1966, October 25, 1973, and July 2,1974, FOls DPR-12, DPR-44, and DPR-56 for PBAPS, Unit 1, 2, and 3, respectively.
In these FOls, the NRC found that the receipt, possession, and use of byproduct material, subject to the conditions and requirements of the FOLs, would be in accordance with the NRC's regulations in 10 CFR Part 30.Therefore, in accordance with the Act and Part 30, the NRC granted to PBAPS, by paragraph 2.B.(2)of DPR-12 and paragraph 2.B.(5)of DPR-44 and DPR-56, the authorization to possess, but not separate byproduct material generated by the operation of PBAPS.1 42 USC 2201,"Chapter 14-General Authority, Sec.161, General Provisions" 2 42 USC 2111,"Chapter8-Byproduct Material, Sec.81, Domestic Distribution" Page 4 of 18 ATTACHMENT 1 Evaluation of Proposed Change In addition, paragraph C of FOLs DPR-12, DPR-44, and DPR-56 establishes that the FOLs are subject to the conditions specified in the NRC's regulations, as set forth in 10 CFR Part 1, as well as all applicable provisions of the Act;the rules, regulations and orders of the NRC (Le., including Part 30);andspecificlicense conditions specified in the FOL.When taken as a whole, the regulatory progression from the Act, to the regulations, and then to the FOLs establishes the regulatory framework and legal authority that the NRC employed to issue"embedded" Part 30 licenses, within the PBAPS Units 1, 2, and 3 Part 50 FOLs.In addition, this regulatory progression establishes the regulatory framework and legal authority for the NRC to amend the embedded Part 30 licenses in the PBAPS FOLs by amending license paragraph 2.B.(2)of the PBAPS Unit 1 Part 50 FOL, and license paragraph 2.B.(5)of the PBAPS Units 2 and 3 Part 50 FOLs.The concept of embedded Part 30 licenses, within the Part 50 license, as well as the NRC's legal authority to amend the embedded license is also highlighted in SECY-94-198,"Review of Existing Guidance Concerning the Extended Storage of Low-Level Radioactive Waste," as well as RIS 2008-32.As stated in SECY-94-198, NRC regulations do not require a separate Part 30 license for storage of LLRW by a Part 50 licensee, since a Part 50 licensee is already authorized under Part 30 to possess byproduct materials.
3.2 Application
of Legal Authority NUREG-0386,"United States Nuclear Regulatory Commission Staff Practice and Procedure Digest," January 2009 update, provides a digest of significant decisions of the NRC, the Atomic Safety and Licensing Appeal Board Panel, and the Atomic Safety and Licensing Board Panel.These decisions collectively interpret 10 CFR Part 2,"Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders." Although the Appeal Board Panel was abolished in 1991, NUREG-0386 stipulates that Appeal Board precedent may still be cited, to the extent it is consistent with more recent case law and the current rules of practice.Giventhis guidance, the validity of the legal framework and authority for amending"embedded" 10 CFR Part 30, 40, and 70 licenses was endorsed by the Atomic Safety and Licensing Appeal Board in ALAB-651, 14 NRC 307,314 (1981),"Duke Power Co.(Amendment to Materials License SNM-1773-Transportation of Spent Fuel from Oconee Nuclear Station for Storage at McGuire Nuclear Station)." In the context of spent nuclear fuel storage, the Appeal Board recognized that"the waste disposal problem confronting nuclear powerplantoperators stems from the limited storage capacity of on-site reactor spent fuel pools (taken in conjunction with the unavailability of off-site storage repositories)." The Duke Power Appeal Board further noted that"when the exhaustion of that capacity approaches[,)
the plant operator likely will have no more than four choices: expansion of the spent fuel pool's storage capability by reracking or some other means;building of an independent spent fuel storage installation (ISFSI)either on-site or off-site;transportation of the spent fuel to another of its facilities; and shutdown of the plant." According to the Appeal Board,"where available, each of these alternatives ha[s]manifest independent utility." Ultimately, the Appeal Board authorized the Director of NRR to issue a license amendment allowing Duke Power Company to transport spent fuel from Oconee Nuclear Station to McGuire Nuclear Station for storage, explicitly endorsing the legal validity of transporting spent nuclear fuel for storage from one nuclear plant to another.Following the Page 5 of 18 ATTACHMENT 1 Evaluation of Proposed Change Appeal Board Order, the NRC, on October 27, 1981, granted McGuire Nuclear Station, Unit 1, a license amendment to receive, possess, and store irradiated fuel assemblies containing special nuclear material from Oconee Nuclear Station, Units 1, 2, and 3.The NRC has also authorized other Part 50 licensees, either through a license amendment or license condition, to receive, possess, and store source and other special nuclear material from different Part 50 licensees that are owned by the same company.1.On April 21, 1986, the NRC granted a license amendment to North Anna Power Station, Units 1 and 2, allowing it to receive, possess and store up to 500 spent fuel assemblies from theSurryPower Station, Units 1 and 2.North Anna andSurryare both owned by the same company and located in Virginia approximately 86 miles apart.In its Safety Evaluation (SE)issued on July 2, 1984, the NRC concluded that"(1)there is reasonable assurance that the health and safety of the public will not be endangered by operation and transport in the proposed manner, and (2)such activities will be conducted in compliance with the Commission's regulations and will not be inimical to the common defense and security or to the health and safety of the public.1I Furthermore, the NRC conducted an Environmental Assessment and concluded that the amendment involved"no significant changes in types or significant increase in the amounts of any effluents that may be released off-site and there is no significant increase in individual or cumulative occupational radiation exposure." As such, the NRC determined that an Environmental Impact Statement (EIS)was not required for the license amendment.
2.In a letter and SE dated January 17,1985, the NRC issued an FOL to Catawba Nuclear Station, Unit 1, that included a license paragraph allowing it to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of McGuire Nuclear Station, Units 1 and 2, and Oconee Nuclear Station, Units 1,2 and 3.On May 15, 1986, Catawba Nuclear Station, Unit 2 was granted an operating license with the same license condition.
3.In a letter and SE dated January 12, 1987, the NRC issued an FOL to Shearon Harris Nuclear Power Plant, Unit 1 that included a license paragraph allowing it to receive and possess, but not separate, byproduct and special nuclear materials produced at Brunswick Steam Electric Plant, Units 1 and 2, and Robinson Steam Electric Plant, Unit 2.The NRC has also allowed atleastone Part 50 licensee to receive, possess and use, but not separate, fuel assemblies and fuel channels from another Part 50 licensed facility not owned by the same company.Specifically, in a letter and SE dated June 23, 1993, the NRC granted a license amendment allowing LGS, Units 1 and 2, to receive, possess, and use, but not separate, such source, byproduct, and special nuclear materials as contained in the fuel assemblies and fuel channels from the Shoreham Nuclear Power Station.The intent of the LGS license amendment request was to enable LGS to purchase the fuel assemblies from the Shoreham Nuclear Power Station and use the fuel at LGS.The NRC SE concluded that there was reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, such activities will be conducted in compliance with the NRC's regulations, and the issuance of the amendments would not be inimical to the common defense and security or to the health and safety of the public.Furthermore, the NRC conducted an Environmental Assessment where it made a finding of no significant impact.Page 6 of 18 ATTACHMENT 1 Evaluation of Proposed Change The same reasoning provided by the Appeal Board in the 1981 Duke Power Co.decision also applies to the review and approval of a license amendment that would enable a company to transport LLRW from one nuclear power plant to another for storage.As with spent nuclear fuel in the 1981 Duke Power Co.case, there is a current LLRW disposal problem due to the July 2008 action by the state of South Carolina that prohibits the EnergySolutions
-Barnwell facility from accepting LLRW from licensees that are located in non-Atlantic Compact states, such as Illinois and Pennsylvania.
Therefore, based on limited on-site storage space for Class BIC LLRW and the unavailability of disposal facilities for Class BIC LLRW, nuclear power plant operators should have the same options regarding storage of Class BIC LLRW that they have for spent nuclear fuel (Le., the four choices described in the Duke Power Co.Appeal Board decision, one of which would be the shipment of LLRW to another plant for storage).In fact, as discussed below, there is direct precedent for allowing one Part 50 licensee to store LLRW that is generated at another Part 50 licensee's facility, using the same regulatory framework and legal authority.
In a letter and SE dated July 18, 2000, the NRC issued a license amendment that allowed the Tennessee Valley Authority (TVA)to possess, at Sequoyah Nuclear Plant (SNP), Units 1 and 2, source, byproduct, and special nuclear material produced at Watts Bar Nuclear Plant, Unit 1 (WBN).The TVA LAR requested an amendment of SNP FOL Paragraph 2.B.(5)to allow possession of source, byproduct, and special nuclear material produced at WBN, as well as that produced at SNP.The NRC Staff granted the request based on the determination that the increased radioactivity would have an insignificant effect on safe operation of the SNP units, and that increases in radiation dose to workers and the general public would be very minor.Furthermore, the NRC concluded that the amendment involved no significant increase in the amounts, and no significant change in the types, of any effluents that may be released off-site, and that there was no significant increase in individual or cumulative occupational exposure.As demonstrated above, the NRC has both the legal authority and a regulatory framework for the review and approval of a 10 CFR 50.90 license amendment request that would allow a Part 50licenseeto receive and possess byproduct material from another Part 50 licensee.Furthermore, the NRC has exercised this authority multiple times to approve requests from a Part 50 licensee to store either spent nuclear fuel or LLRW generated at another Part 50 licensed facility.
4.0 TECHNICAL EVALUATION
4.1 Description
of the PBAPS LlRWSF and LLRW The PBAPS LLRWSF was originally designed to comply with specific NRC regulatory guidance documents at the time, primarily Generic Letter (GL)81-38,"Storage of Low-Level Radioactive Wastes at Power Reactor Sites." In addition, the requirements of 10 CFR Part 20,"Standards for Protection Against Radiation," and 40 CFR Part 190,"Environmental Radiation Protection Standards for Nuclear Power Operations," formed the basis for the design of the LLRWSF with respect to exposure to radiation.
In that regard, the LLRWSF features 36-inch concrete shield walls on the peripheral wall for direct transmission protection.
For higher activity LLRW (e.g., Class BIC LLRW)the PBAPS LLRWSF is equipped with 35 storage cells, each with 14-inch concrete walls and a 24-inch concrete cap for skyshine protection.
This design ensures that the Page 7 of 18 ATTACHMENT 1 Evaluation of Proposed Change dose rate at the exterior wall of the LLRWSF, the nearest restricted area boundary, and the nearest residence, when the LLRWSF is filled to capacity would be less than the limits specified in 10 CFR Part 20and40 CFR Part 190.As part of a 1992 revision to the original 10 CFR 50.59 evaluation, an analysis was conducted to assess the potential radiological impact of a postulated container drop accident that spilled the entire contents of a worst case radionuclide mixture onto the floor of the LLRWSF, resulting in the airborne dispersion of a specified fraction of the contents.This original container drop analysis demonstrated that the maximum expected offsite dose rate was less than 10%of the 10 CFR Part 100,"Reactor Site Criteria," acceptance criteria.During that period (i.e., the mid-1980s), approximately 90%of the LLRW projected to be stored in the PBAPS LLRWSF was Class A LLRW, with the balance being Class B/C LLRW.Classes A, B, and C LLRW are generally acceptable for near-surface disposal and are defined in 10 CFR Part 61,"Licensing Requirements for Land Disposal of Radioactive Waste." Section 10 CFR 61.55 lists the radioactivity concentration limits of specific radioactive materials allowed in each LLRW class for near-surface disposal.Class A LLRW contains the lowest radioactive concentration and constitutes the majority of radioactive waste.Class BLLRWcontains the next higher radioactive concentration and Class C LLRW has the highest radioactive concentration allowed to be disposed of in a near-surface LLRW disposal facility.Most Class A LLRW can be classified as Low Specific ActiVity (LSA)waste, and includes spent condensate demineralizer ion exchange resins and slightly contaminated dry active waste (DAW).Class B/C LLRW is typically high specific activity ion exchange resins, with the typical radioactive constituent being Co-60.This type of LLRW results in relatively high container contact radiation levels (Le., typically greater than 15 R/hr).Class B/C LLRW is typically generated at PBAPS in the demineralizers of the Reactor Water Cleanup (RWCU)system.The high specific activity ion exchange resins from the RWCU system demineralizers are stored and transported in high density polyethylene (HOPE)High Integrity Containers (HICs)in a dewatered resin waste form.The dewatered resins comply with Generic Letter (GL)81-38 requirements for"Stabilized Waste." The LLRW containers (Le., HOPE HICs)comply with the requirements of 10 CFR Part 20, 10 CFR Part 61, Title 49 of the CFR,"Transportation," and current EnergySolutions
-Barnwell site waste acceptance criteria, for eventual shipment of the LLRW to a permanent disposal facility.The PBAPS LLRWSF is located outside the plant Protected Area, but within the Owner Controlled Area.The PBAPS LLRWSF is located in a fenced area, which is locked and periodically patrolled.
The LLRWSF bUilding is also locked.The fenced and locked area, including the LLRWSF building, is considered a restricted area for radiation protection purposes.Access to the LLRWSF is controlled in accordance with the PBAPS Radiation Protection Program.4.2 Evaluation of Proposed Class SIC LLRW Storage Option Based on the cost to construct an additional Class B/C LLRW storage facility at LGS, and the available space at the PBAPS LLRWSF, EGC has evaluated the technical and regulatory aspects of storage of Class BIC LLRW that is generated at LGS, in the existing PBAPS LLRWSF.This Page 8 of 18 ATTACHMENT 1 Evaluation of Proposed Change technical and regulatory evaluation was documented as a technical report supporting an EGC Engineering Change, in accordance with EGC procedures.
The technical report, which is provided as Attachment 3, evaluated the existing PBAPS LLRWSF design and operational requirements against the NRC guidance applicable to extended storage of LLRW, including the storage of a larger number of Class BIC LLRW containers than previously evaluated, and storage of Class BIC LLRW containers from LGS.After assessing both normal design requirements and potential design basis events, the technical report validated that storage of Class BIC LLRW in the existing PBAPS LLRWSF complies with current NRC regulatory requirements, and that the PBAPS LLRWSF performs acceptably in an extended storage operational mode (i.e., up to 80 years in duration)for Class BIC LLRW in HOPE HICs.This conclusion is equally valid for extended storage of Class BIC LLRW from LGS.The technical report includes a review of the original 10 CFR 50.59 evaluation that was conducted for the initial installation and operation of the PBAPS LLRWSF.This review of the original 10 CFR 50.59 evaluation is provided in Appendix A of Attachment 3.The Attachment 3 technical report is based on the regulatory requirements and guidance described in GL 81-38, NUREG-0800,"Standard Review Plan fortheReview of Safety Analysis Reports for Nuclear Power Plants," Appendix 11.4-A,"Design Guidance for Temporary Storage of Low-Level Radioactive Waste," and RIS 2008-32.The EGC review of these documents resulted in a tabulation of the design and operational requirements for the PBAPS LLRWSF that would ensure compliance with regulatory requirements and guidance, as well as the basis for compliance with each regulatory requirement.
This information is provided in Table 4.5-1 of Attachment 3.The EGC review of the original 10 CFR 50.59 evaluation and applicable regulatory documents identified that many of the design andoperationalrequirements associated with the proposed LLRW storage option are bounded by the previous 10 CFR 50.59 evaluation, including original supporting calculations and analyses.However, EGC also determined that a subset of the design and operational requirements would require new calculations andlor analyses to ensure compliance with regulatory requirements and guidance.To adequately document the bounding evaluations, and address the need for new calculations and analyses, the technical report that is provided in Attachment 3 addresses the topics listed below.These topics are based on the regulatory requirements, and the basis for verifying compliance with each requirement, that is provided in Table 4.5-1 of Attachment 3.Characterization of the expected Class BIC LLRW from LGS Assessment of the potential for flammable gas generation in the Class BIC LLRW containers Assessment of Class BIC LLRW container integrity for extended storage (i.e., up to 80 years)Definition of waste acceptance criteria for receipt of Class BIC LLRW containers at PBAPS Evaluation of PBAPS LLRWSF effluent release paths and monitoring requirements Page 9 of 18 ATTACHMENT 1 Evaluation of Proposed Change Evaluation of PBAPS LLRWSF design basis events, including an assessment of a Class B/C LLRW container drop event Documentation of PBAPS LLRWSF compliance with NRC security program requirements Completion of updated PBAPS LLRWSF radiation shielding assessments (Le., to account for a larger number of Class B/C LLRW containers)
Evaluation of Class B/C LLRW container decontamination and repackaging capability Consideration of PBAPS LLRWSF operation, as described in EGC procedure105,"Guidelines for Operating an Interim On Site Low Level Radioactive Waste Storage Facility," relative to EPRI Report,"Guidelines for Operating an Interim On Site Low Level Radioactive Waste Storage Facility" 4.3 PBAPS LLRWSF Operational Performance Requirements and Design Conditions The PBAPS LLRWSF operational performance requirements, design conditions, and analyses are listed below, and summarized in subsequent sections, including a cross-reference to the applicable section andlor appendix of the EGC technical report that is provided as Attachment 3.Class B/C LLRW characteristics and waste acceptance criteria Class B/C LLRW packaging requirements and storage criteria, including analyses ofterm container integrity and potential flammable gas generation Radioactive effluent monitoring requirements Updated radiation shielding and dose acceptability assessments Design basis event analyses for postulated fire, tornado, flood, seismic, and container drop events 4.3.1 Class B/C LLRW Characteristics and Waste Acceptance Criteria Class B/C LLRW that will be stored in the PBAPS LLRWSF for long-term storage will be similar to the types of LLRW currently licensed and stored in the PBAPS LLRWSF, as described in Section 5.0 of Attachment 3.Container contact radiation levels are expected to range from approximately 15 R/hr to 400 R/hr.The placement of containers within the PBAPS LLRWSF will be controlled in accordance with administrative procedures, and will ensure compliance with the dose and dose rate limits specified in 10 CFR Part 20 and 40 CFR Part 190.All containers received from off-site will comply with 49 CFR transportation requirements, as applicable, as well as the PBAPS Waste Acceptance Criteria (WAC).In order to ensure that the Class B/C LLRW radioactive waste form and packages are acceptable for extended (Le., greater than five years)storage and eventual shipment for disposal in a licensed facility, specific criteria identifying conditions of acceptance are required.The purpose of PBAPS LLRWSF WAC is to provide the authorized radioactive material, form, and packaging for emplacement in the facility for long-term storage and eventual shipment to a disposal facility.The PBAPS LLRWSF WAC is based on the EnergySolutions
-BarnwellFacility License, Amendment No.49.The PBAPS LLRWSF WAC is discussed in Section 7.3 and provided as Appendix D of Attachment 3.Page 10 of 18 ATTACHMENT 1 Evaluation of Proposed Change 4.3.2 Class SIC llRW Packaging Requirements and Storage Criteria Class B/C LLRW will be packaged in grapple-compatible containers.
EGC has conducted an evaluation of this container type to ensure that container integrity is maintained for the duration of an"extended storage period" and will not rupture when subjected to handling for transportation to a future disposal site.EGC has defined"extended storage period" as the life of the plant (Le., 40 years)plus 40 years for a total of 80 years.The container integrity evaluation is documented in Section 7.2 and Appendix C of Attachment 3.EGC has conducted an assessment to evaluate the potential flammable gas (e.g.,.hydrogen)generation in Class B/C LLRW packages containing dewatered ion exchange resin (Le., due to radiological decomposition of the resin).This assessment indicates that flammable gas generation in the PBAPS LLRWSF for Class B/C LLRW, even at maximum theoretical container quantities and dose rates, is not of concern as long as the containers are adequately vented.This conclusion is valid, even during extended periods of LLRWSF operation withoutforcedventilation.
The flammable gas generation assessment is documented in Section 7.1 and AppendiX B of Attachment 3.The PBAPS LLRWSF has the capacity to hold 520 containers of Class B/C LLRW in 35 separate cells.When the PBAPS LLRWSF was initially designed and constructed, apprOXimately 90%of theprojectedLLRW that would be stored was Class A LLRW, with the balance being Class B/C LLRW.As discussed in Section 1.1 above, Class A LLRW from PBAPS and LGS will continue to be shipped to EnergySolutions
-Clive.Since approximately 90%of the LLRW waste that was anticipated to be stored at the PBAPS LLRWSF (Le., Class A LLRW)will be shipped to Energy$olutions
-Clive, there will be sufficient excess storage capacity in the PBAPS LLRWSF for extended storage of the Class B/C LLRW generated at LGS, in addition to Class BIC LLRW that is generated at PBAPS.Although the Class BIC LLRW from LGS, combined with the Class BIC LLRW from PBAPS, is expected to have higher average radiation levels than originally assumed in the PBAPS LLRWSF design, EGC will implement loading and placement restrictions to ensure continued compliance with the as low as reasonably achievable (ALARA)requirements of 10 CFR Part 20 and the dose requirements of 40 CFR Part 190.4.3.3 Radioactive Effluent Monitoring EGC conducted an assessment to review radioactive effluent monitoring needs and capabilities for the PBAPS LLRWSF, relative to regulatory requirements and gUidance, including 10 CFR Part 50, AppendiX A,"General Design Criteria for Nuclear Power Plants," General Design Criterion (GDC)61,"Fuel Storage and Handling and Radioactivity Control," GDC 63,"Monitoring Fuel and Waste Storage," and GDC 64,"Monitoring Radioactivity Releases." This assessment concluded that for long-term storage of solidified or dewatered ion-exchange resin in the PBAPS LLRWSF, with no processing or repackaging, there was no potential pathway for liquid, gaseous, or solid releases, and as such, continuous radioactive effluent monitoring is not required in the PBAPS LLRWSF.This assessment is documented in Section 7.4 of Attachment 3.Page 11 of 18 ATTACHMENT 1 Evaluation of Proposed Change 4.3.4 Updated Radiation Shielding and Dose Acceptability Assessments The design function of the PBAPS LLRWSF is to store LLRW, either for staging of LLRW prior to shipment to a LLRW disposal site, or for storage on a more extended basis if a disposal site is not available.
For radiation protection purposes, these functions must be implemented with shielding, container placement, and LLRW handling processes that are sufficient to ensure compliance with regulatory radiation dose and dose rate limits.Shieldingdesign for the PBAPS'LLRWSF, and the use of specific Class B/C LLRW handling procedures (Le., operational and administrative controls)ensure compliance with 10 CFR Part 20 and 40 CFR Part 190 requirements, including the maintenance of personnel doses ALARA.Section 8.2 of Attachment 3 describes the operational and administrative controls, and Section 8.5 of Attachment 3 describes an updated radiation shielding assessment for storage of Class B/C LLRW in the PBAPS LLRWSF.With respect to the extended storage of Class B/C LLRW in the PBAPS LLRWSF, 40 CFR Part 190 limits the annual dose to individual members of the public from direct radiation and effluent releases to 25 mrem, as implemented under 10 CFR 20.1301 (e).Onsite doses that are associated with temporarystorageare limited and controlled in accordance with 10 CFR Part 20, including the ALARA principle of 10 CFR 20.1101.The updated radiation shielding assessments for the PBAPS LLRWSF indicates that the calculated dose rates to offsite receptors due to extended storage of Class B/C LLRW in the PBAPS LLRWSF, including Class B/C LLRW from LGS are limited to 1 mrem per year.This is a small fraction of the 40 CFR Part 190 limit of 25 mrem per year.Similarly, dose rates in areas outside of, but in the immediate vicinity of the PBAPS LLRWSF, will be limited to less than 1 mrem per hour, thus ensuring compliance with 10 CFR 20 limits, including the ALARA principle of 10 CFR 20.1101.This evaluation is conservative in that it does not take credit for isotopic decay effects, which would result in lower dose rate projections as the PBAPS LLRWSF is filled.The updated radiation shielding assessments have not been included in this LAR, due to the size of the document.However, this calculation is available for NRC review, and will be provided on the PBAPS dockets, if requested.
4.3.5 Design
Basis Event Analyses EGC validated that the original PBAPS LLRWSF 10 CFR 50.59 evaluation for a subset of design basis events (Le., fire, tornado, flood, and seismic)bound the proposed LLRW storage option.This validation is described in Sections 8.4.1 through 8.4.4 and Appendix E of Attachment 3.EGC has developed an updated evaluation for the design basis container drop accident for the LLRWSF to reflect new anticipated LLRW characteristics.
The updated evaluation, which is provided as Attachment 4, conservatively demonstrates that the consequences of the postulated accident are less than 10%of the 10 CFR Part 100 dose limit (Le., as required by GL 81-38 and NUREG-0800, Appendix 11.4-A).Page 12 of 18 ATTACHMENT 1 Evaluation of Proposed Change 4.4 Class SIC llRW Shipping and Handling Criteria The transportation of Class BIC LLRW from LGS to PBAPS will be conducted in accordance with NRC and Department of Transportation regulations (Le., 10 CFR Part 71,"Packaging and Transportation of Radioactive Material," and 49 CFR Parts 171-180,"SubpartC-Hazardous Materials Regulations").
Transportation of Class BIC LLRW from LGS to PBAPS requires significantly less on-road travel than previous shipments of Class B/C LLRW to Barnwell, (Le., prior to July 2008).LGS is approximately 80 miles from PBAPS.In comparison, LGS is approximately 710 miles from Barnwell, South Carolina.Transportation of Class B/C LLRW to PBAPS is significantly shorter and thus poses less of a risk to the public than transportation of Class BIC LLRW to Barnwell or other out-of-statedisposalfacilities.
The source of the Class B/C LLRW does not impact the handling of LLRW.From both an operational and radiological perspective, handling of Class B/C LLRW from LGS is equivalent to handling of Class BIC LLRW generated at PBAPS.Furthermore, the isotopic mixture used in the updated PBAPS LLRWSF radiation shielding assessments (Le., 100%Co-60)bounds the PBAPS and LGS isotopic mixtures.A description of the PBAPS LLRWSF and associated equipment is provided in Section 8.1 of Attachment 3.Operational procedures are provided as part of Table 4.5-1 of Attachment 3.No changes to the PBAPS LLRWSF loading/unloading processes or equipment will be necessary for acceptance and handling of Class B/C LLRW from LGS.4.5 Class SIC llRW Decontamination and Repackaging Capability GL 81-38,Section V,"Solidified Radioactive Waste Storage," discusses the development of contamination isolation and decontamination repackaging capabilities for LLRW containers when significant handling and personnel exposure is anticipated.
Class B/C LLRW containers stored at the PBAPS LLRWSF that are identified as requiring decontamination will be isolated in accordance with PBAPS procedures, and forwarded to the PBAPS Radwaste Building for decontamination or transferred to a licensed off-site facility for decontamination.
The PBAPS Radwaste Building and equipment are designed to ensure that the ALARA principle is incorporated, in accordance with the applicable regulatory requirements and guidance.This is discussed in Section 8.6 of Attachment 3.GL 81-38,Section V and NUREG-0800, Appendix 11.4-A discuss the need for, and development of, additional processing/repackaging capabilities in the event of Class B/C LLRW container failure andlor as required for final transport and burial in accordance with regulatory requirements and disposal site criteria.Class BIC LLRW containers stored in the PBAPS LLRWSF that are identified as requiring processing or repackaging to meet transportation and disposal requirements will be isolated according to PBAPS procedures, and forwarded to the PBAPS Radwaste Building for the necessary processing/repackaging, or transferred to a licensed off-site facility for that purpose.The PBAPS Radwaste Building and equipment are designed to ensure that the ALARA principle is incorporated, in accordance with the applicable regulatory requirements and guidance.This is discussed in Section 8.8 of Attachment 3.Page 13 of 18 ATTACHMENT 1 Evaluation of Proposed Change 4.6 Summary The EGC technical report provided in Attachment 3, and summarized above, validates that the PBAPS LLRWSF complies with NRC regulatory requirements and performs acceptably in an extended storage operational mode (i.e., up to 80 years in duration)for PBAPS-generated Class B/C LLRW in HOPE HICs.This conclusion is equally valid for extended storage of Class BIC LLRW from LGS in the PBAPS LLRWSF.This validation assessed both normal design requirements and potential design basis events.Key findings of the EGC technical report include: Proper container venting will eliminate flammable gas generation concerns for Class BIC LLRW (Le., dewatered ion exchange resins), even in the event the PBAPS LLRWSF ventilation system is secured for extended periods.HOPE HICs will retain the physical properties associated with long-term container integrity for extended storage periods (i.e., 100 years or more).Additional processing (i.e., dewatering) that may be required prior to eventual shipment to a disposal facility would be conducted in a separate facility.The use of stacking structural systems that are provided with HOPE HICs minimize stresses experienced by the HICs, thus minimizing container embrittlement, even with high radiation doses.The addition of anti-oxidant compounds to Class BIC LLRW container material (i.e., HOPE)substantially reduces HOPE HIC physical property degradation associated with extended storage and radiation.
In addition, the PBAPS LLRWSF provides a controlled temperature environment, with negligible UV exposure, thus enhancing longevity of HOPE HICs that contain Class B/C LLRW.Continuous radioactive effluent monitoring is not required based on the absence of a postulated release mechanism for volatile or liquid container contents.Seismic, flood, and tornado design basis events are bounded by the original PBAPS LLRWSF 10 CFR 50.59 evaluations.
An updated evaluation of the dropped container design basis event conservatively demonstrates that less than 10%of 10 CFR Part 100 dose limits would result (i.e., as required in GL 81-38).The updated design basis container drop evaluation is provided in Attachment 4.Updated fire hazard assessments demonstrate that no fire initiation scenario exists with the storage of Class BIC LLRW in HOPE HICs.The updated radiation shielding assessment for the PBAPS LLRWSF demonstrates compliance of the PBAPS LLRWSF with 10 CFR Part 20 and 40 CFR Part 190 requirements when completely filled.This compliance assumes container placement is controlled as specified in the updated radiation shielding assessments (e.g., placing lower dose rate containers in peripheral storage cells near the outside walls).The updated radiation shielding assessment has not been included in this LAR, due to the size of the document.However, this calculation is available for NRC review, and will be submitted to the NRC on the PBAPS dockets, if requested.
Page 14 of 18 ATTACHMENT 1 Evaluation of Proposed Change 5.0 REGULATORY ANALYSIS 5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.90,"Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGG)requests an amendment to Facility Operating License (FOL)No.DPR-12, and Renewed FOLs DPR-44 and DPR-56 for PBAPS Units 1,2, and 3.The proposed change revises license paragraph 2.B.(2)of DPR-12 and license paragraph 2.B.(5)of DPR-44 and DPR-56.The proposed change will enable PBAPS to possess, but not separate, byproduct material from Limerick Generating Station (LGS), Units 1 and 2.Specifically, the revised license paragraph would enable EGC to store low-level radioactive waste (LLRW)from LGS in the PBAPS Low Level Radioactive Waste Storage Facility (LLRWSF).The PBAPS LLRWSF already provides storage for LLRW generated at PBAPS.According to 10 CFR 50.92,"Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1)Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2)Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)Involve a significant reduction in a margin of safety.EGC has evaluated the proposed change, using the criteria in 10 CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration.
The following information is provided to support a finding of no significant hazards consideration.
1.Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change is an amendment to the PBAPS FOLs that will enable PBAPS to receive and store Class B/C LLRW from LGS in the PBAPS LLRWSF.This proposed change does not impact any initiators or precursors of previously analyzed accidents.
The storage of Class B/C LLRW from LGS does not impact the failure of any plant structures, systems, or components.
The proposed change does not have a detrimental impact on the integrity of any plant structure, system, or component that initiates an analyzed event.The proposed change does not affect any active or passive failure mechanisms that could lead to an accident.The PBAPS LLRWSF is not safety related, and is not used for plant shutdown resulting from accident or nonstandard operational conditions.
The proposed change does not significantly increase the consequences of postulated design basis events (i.e., seismic, flood, tornado, fire, and container drop events), in that the postulated impact of these events remains well below regulatory requirements (Le., less than 10%of 10 CFR Part 100,"Reactor Site Criteria" acceptance criteria).
Page 15 of 18 ATTACHMENT 1 Evaluation of Proposed Change Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change is an amendment to the PBAPS FOLs that will enable PBAPS to receive and store Class B/C LLRW from LGS in the PBAPS LLRWSF.The proposed amendment does not involve any change to plant equipment or system design functions.
EGC has verified that the storage of Class B/C LLRW from LGS in the PBAPS LLRWSF does not affect the ability of the PBAPS LLRWSF to perform its design function, including compliance with NRC regulatory requirements and guidance.No new accident initiators are introduced by this amendment.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.
3.Does the proposed change involve a significant reduction in a margin of safety?Response: No The proposed change is an amendment to the PBAPS FOLs that will enable PBAPS to receive and store Class BIC LLRW from LGS in the PBAPS LLRWSF.The proposed amendment does not involve any change to plant equipment or system design functions.
The margin of safety is established through the design of the plant structures, systems, and components, the parameters within which the plant is operated, and the setpoints for the actuation of equipment relied upon to respond to an event.The proposed amendment does not affect the PBAPS safety limits or setpoints at which protective actions are initiated.
The proposed amendment does not significantly increase the dose rate at the exterior wall of the LLRWSF, the nearest restricted area boundary, and the nearest residence when the LLRWSF is filled to capacity with Class BIC LLRW.Therefore, these dose rates will remain within limits specified in 10 CFR Part 20 and 40 CFR Part 190.Additionally, the potential radiological impact of a postulated design basis container drop accident is less than 10%of the 10 CFR Part 100 acceptance criteria.Therefore the margin of safety is not reduced by the proposed change.Based on the above evaluation, EGC concludes that the proposed amendment presents no significant hazards considerationunderthe standards set forth in 10 CFR 50.92, paragraph (c), and accordingly, a finding of no significant hazards consideration is justified.
Page 16 of 18 ATTACHMENT 1 Evaluation of Proposed Change 5.2 Applicable Regulatory Requirements/Criteria 5.2.1 10 CFR Part 20,"Standards for Protection Against Radiation" and 40 CFR Part 190,"Environmental Radiation Protection Standards for Nuclear Power Operations" With respect to the extended storage of Class B/C LLRW in the PBAPS LLRWSF, 40 CFR Part 190 limits the annual dose to individual members of the public from direct radiation and effluent releases to 25 mrem, as implemented by 10 CFR 20.1301(e).
Onsite doses that are associated with temporary LLRWstorageare limited and controlled in accordance with 10 CFR Part 20, including the ALARA principle of 10 CFR 20.1101.EGC has verified that the calculated dose rates to offsite receptors due to extended storage of Class B/C LLRW in the PBAPS LLRWSF, including Class B/C LLRW from LGS are limited to 1 mrem per year.This is a small fraction of the 40 CFR Part 190 limit of 25 mrem per year.Similarly, dose rates in areas outside of, but in the immediate vicinity of the LLRWSF, will be limited to less than 1 mrem per hour, thus ensuring compliance with 10 CFR 20 limits, including the ALARA principle of 10 CFR 20.1101.Therefore, the proposed change will not impact compliance with 40 CFR Part 190 or 10 CFR Part 20.5.2.2 10 CFR Part 50, Appendix A,"General Design Criteria for Nuclear Power Plants," General Design Criterion (GDC)61,"Fuel Storage and Handling and Radioactivity Control," GDC 63,"Monitoring Fuel and Waste Storage," and GDC 64,"Monitoring Radioactivity Releases" When evaluating long-term on-site LLRW storage, Part 50 licenseesmustalso consider the applicability of the general design criteria listed in 10 CFR Part 50, Appendix A, specifically GOC 61, 63 and 64: GOC 61 specifies that fuel storage and handling, radioactive waste, and other systems that may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions.
GOC 63 states that appropriate systems shall be provided in fuel storage, radioactive waste systems, and associated handling areas to (1)detect conditions that may result in loss of residual heat removal capability and excessive radiation levels and (2)to initiate appropriate safety actions.GOC 64 requires a method for monitoring the level of radioactivity in effluent release pathways and to the plant environs.EGC has verified that the extended storage of Class B/C LLRW in the PBAPS LLRWSF, including Class B/C LLRW from LGS comply with the requirements of GOC 61, GOC 63, and GOC 64.Page 17 of 18 ATTACHMENT 1 Evaluation of Proposed Change 5.2.3 NUREG-0800,"Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Chapter 11.4,"Solid Waste Management System," and Appendix 11.4-A,"Design Guidance for Temporary Storage of Low-Level Radioactive Waste" NUREG-0800, Chapter 11.4 specifies the information that should be included in a Construction and Operating License Application concerning the solid waste management system.Appendix 11.4-A, provides generally applicable and waste-specific guidance to licensees for increasing and utilizing on-site LLRW storage capacity.EGC has verified that the extended storage of Class BIC LLRW in the PBAPS LLRWSF, including Class BIC LLRW from LGS, comply with the requirements and guidance in NUREG-0800, Appendix 11.4-A.6.0 ENVIRONMENTAL CONSIDERATION EGC has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20,"Standards for Protection Against Radiation." However, the proposed amendment does not involve: (i)a significant hazards consideration, (ii)a significant change in the types or significant increase in the amounts of any effluent that may be released off-site, or (iii)a significant increase in individual or cumulative occupational radiation exposure.Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22,"Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," paragraph (c)(9).Therefore, pursuant to 10 CFR 51.22(b)and (c)(9), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.
Page 18 of 18 ATTACHMENT 2 Proposed Mark-up of PBAPS Facility Operating License DPR-12 and Renewed Facility Operating Licenses DPR-44 and DPR-56 A.This amended license applies to the Peach Bottom Atomic Power Station, Unit 1, a permanently shutdown, high temperature, gas cooled, demonstration power reactor, and associated equipment (the facility)owned by Exelon Generation Company.The facility is located at the licensee's site in York County, Pennsylvania, and is described in the application dated May 21, 2002, B.Subject to the conditions and the requirements incorporated herein, the NRC hereby licenses the Exelon Generation Company:{1)Pursuant to Section 104(b)of the Act and 10 CFR Part 50,"Domestic Licensing of Production and Utilization Facilities" to possess but not operate the facility.(2)Pursuant to the Act and 10 CFR Part 30,"Rules of General Applicability to Domestic Licensing of Byproduct Material" to possess, but not to separate, such byproduct material as may have been produced by..oPeration oUhe fadli.............C, This license shall be emed to contain and be subject to the conditions specified in Part ,Section 30.34 of Part 30, Section 50,59 of Part 50, 10 CFR Chapter 1, to all applicable provisions of the Act and to the rules, reguJati.,and orders of the NRC now or hereafter in effect and is subject to the.Oitional conditions specified below: , and such byproduct materials as may be produced by the operation of Limerick Generating Station, Units 1 and 2.(1)(2)Exelon Generation Company shall not dismantle or dispose of the facility without prior approval of the NRC.Technical Spedfications The Technical Specifications contained in Appendix A as revised through Amendment No, 11 are hereby incorporated in this license.The licensee shall maintain the facility in accordance with the Technical Specifications.
(3)Exelon Generation Company shall provide to the Director of the Office of Nuclear Material Safety and Safeguards, a copy of any application, at the time it is filed, to transfer (excluding grants of security interests or liens)from Exelon Generation Company to its direct or indirect parent, or to any other affiliated company.facilities for the production, transmission, or distribution of electriC energy having a depreciated book value exceeding ten percent (10%)of Exelon Generation Company's consolidated net utility plant, as recorded on Exelon Generation Company's books of account (4)Deleted Amendment No 11 AUG 27 2003 (5)Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facilit.C.This renewed license shall be deemed to contain and is sub'to the conditions specified in the following Commission regulations in 10 Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40 ction 50.54 of Part 50, and Section 70.32 of Part 70;all applicable proviso s of the Act and the rules, regulations, and orders of the Commissi now or hereafter in effect;and is subject to the additional conditions ecified below: (1)Maximum Power el , and such byproduct materials as may be produced by the operation of Limerick Generating Station, Units 1 and 2.(2)Exelon neration Company is authorized to operate the Peach Bottom A IC Power Station, Unit 2, at steady state reactor core power levels not in excess of 3514 megawatts thermal.Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No.273, are hereby incorporated in the license.Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.
(3)Physical Protection Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822)and the authority of 10 CFR 50.90 and 10 CFR 50.54(p).The combined set of plans 1, submitted by letter dated May 17, 2006, is entitled: "Peach Bottom Atomic Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 3." The set contains Safeguards Information protected under 10 CFR 73.21.(4)Fire Protection The Exelon Generation Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility, and as approved in the NRC Safety Evaluation Report (SER)dated May 23, 1979, and Supplements dated August 14, September 15, October 10 and November 24,1980, and in the NRC SERs dated September 16,1993, and August 24, 1994, subject to the following provision:
The Exelon Generation Company may make changes to the approved The Training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.Renewed License No.DPR-44 Revised by letter dated October 28, 2004 Revised by letter dated May 29, 2007 Amendment No.273 Page 3 (5)Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facili.C.This renewed license shall be deemed to contain and is su.ct to the conditions specified in the following Commission re Ions in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70;all icable provisions of the Act and the rules, regulations, and orders 0 e Commission now or hereafter in effect;and is subject to the addition onditions specified below: (1)Maximum er Level , and such byproduct materials as may be produced by the operation of Limerick Generating Station, Units 1 and 2.(2)xelon Generation Company is authorized to operate the Peach Bottom Atomic Power Station, Unit No.3, at steady state reactor core power levels not in excess of 3514 megawatts thermal.Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No.277, are hereby incorporated in the license.Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.
1 (3)Physical Protection Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans, including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822)and the authority of 10 CFR 50.90 and 10 CFR 50.54(p).The combined set of plans 2 , submitted by letter dated May 17, 2006, is entitled: "Peach Bottom Atomic Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 3." The set contains Safeguards Information protected under 10 CFR 73.21.(4)Fire Protection The Exelon Generation Company shall implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Final Safety Analysis Report for the facility, and as approved in 1Licensed power level was revised by Amendment No.250, dated November 22,2002, and will be implemented following the 14 th refueling outage currently scheduled for Fall 2003.2The training and Qualification Plan and Safeguards Contingency Plan are Appendices to the Security Plan.Renewed License No.DPR-56 Revised by letter dated October 28, 2004 Revised by letter dated November 5, 2004 Revised by letter dated May 29, 2007 Amendment No.277 Page 3