ML17320B100
| ML17320B100 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Watts Bar, Limerick, Diablo Canyon, Vogtle, Waterford |
| Issue date: | 11/16/2017 |
| From: | Miranda S - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation |
| James, Lois, 301-415-3306 | |
| References | |
| 2.206, LTR-17-0341-1 | |
| Download: ML17320B100 (14) | |
Text
10 CFR §2.206 Petition re: License Renewals 16 November 2017 Samuel Miranda, PE
2
Commercial Nuclear Power Reactor Operating Licenses Expiration by Year, 2013-2055 2013 Indian Point 2 (entered renewal on September 29, 2013) 2015 Indian Point 3 (entered renewal on December 12, 2015) 2024 Diablo Canyon 1 and Waterford 3 2035 Watts Bar 1 (licensed 1996) 2049 Limerick 2, and Vogtle 2 2055 Watts Bar 2 (licensed 2015) 3
The Conowingo Dam, opened in 1928, is one of the largest non-federal hydroelectric dams in the U.S.
Conowingos hydroelectric turbines are capable of generating up to 574.5 MW of electricity.
The water behind the dam is used to cool Exelons Peach Bottom Atomic Power Station.
Exelon operates the Conowingo Dam with a license from the Federal Energy Regulatory Comm (FERC).
Exelons current license for the Conowingo was issued on August 14, 1980 and expired in September 2014.
FERC licenses last from 30-50 years. Could Conowingo Dam operate until 2067?
4
The nuclear safety criteria have been established on the premise that:
- a. Those situations in the plant that are assessed as having a high frequency of occurrence shall have a small consequence to the public, and
- b. Those extreme situations having the potential for the greatest consequence to the public shall be those having a very low frequency of occurrence.
Four categories, each of which is defined according to its expected frequency of occurrence.
Condition I, or Normal Operation: Operations that are expected frequently or regularly in the course of power operation, refueling, maintenance, or maneuvering of the plant 1/reactor-year Condition II, or Incidents of Moderate Frequency: Incidents, any one of which may occur during a calendar year for a particular plant 0/reactor-year Condition III, or Infrequent Incidents: Incidents, any one of which may occur during the lifetime of a particular plant 0/plant-lifetime Condition IV, Limiting Faults: Faults that are not expected to occur but are postulated because their consequences would include the potential for the release of significant amounts of radioactive material
= 0/plant-lifetime
7 In determining which systems are necessary to mitigate the effects of these postulated events, the classification system of ANSI-N18.2-1973 is utilized.
- Pg 15.0-13, Byron & Braidwood UFSAR, Rev 11 - Dec 2006 Thus, consistent with the philosophy and format of ANSI N18.2, the event is classified as a Condition III event. By definition "Condition III occurrences include incidents, any one of which may occur during the lifetime of a particular plant," and "shall not cause more than a small fraction of fuel elements in the reactor to be damaged...
- Pg 15.4-13, Byron & Braidwood UFSAR, Rev 9 - Dec 2002
- 2. ANS-51.1/Nl8.2-1973, "Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants.
References:
Pg 15.5-8, Byron & Braidwood UFSAR, Rev 15 - Dec 2014
Frequency of Occurrence :
Condition I:
1/reactor-year normal operation Condition II:
0/reactor-year remedied by a shutdown Condition III:
0/plant-lifetime 1/(40 yrs) > 1/(60 yrs)
Condition IV:
= 0/plant-lifetime or NEVER 8
9 Current licensing basis (CLB) is the set of NRC requirements applicable to a specific plant and a licensees written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect.
The CLB includes the NRC regulations contained in 10 CFR parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 54, 55, 70, 72, 73, 100 and appendices thereto; orders; license conditions; exemptions; and technical specifications. (General Design Criteria are in 10 CFR §50, Appendix A)
- 10 CFR §54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants
1 40 0.025/
10
10 CFR §50.92, Issuance of amendment.
(a) in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses
(c) The Commission may make a final determination that 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.
11
12 Licensees must show that ---
There is no significant increase in the probability of a Condition III event over the extended plant lifetime.
There is no significant reduction in a margin of safety, due to a Condition III event occurring over the extended plant lifetime.
Since the frequency of occurrence of a Condition III event is defined in terms of plant lifetime, the lengthening of the lifetime increases the events probability and reduces the safety margin.
Management Directive 8.11, "Review Process for 10 CFR 2.206 Petitions Criteria for Rejecting Petitions Under 10 CFR 2.206 The petitioner raises issues that have already been the subject of NRC staff review and evaluation either on that facility, other similar facilities, or on a generic basis, for which a resolution has been achieved, the issues have been resolved, and the resolution is applicable to the facility in question.. These requests will not be treated as a 2.206 petition unless they present significant new information.
13
Significant Information The CLB for currently operating plants is largely based on deterministic engineering criteria. Consequently, there is considerable logic in establishing license renewal scoping criteria that recognize the deterministic nature of a plants licensing basis..
PRA will not be used to justify poor performance in aging management or to reduce regulatory or programmatic requirements Page 22468, Federal Register, Vol. 60, No. 88, May 8, 1995 New Information Resolutions that have been achieved will be recorded in ADAMS (before any licenses are renewed 1993). These citations are necessary to close petitions that the NRC maintains have no new information.
14