ML20056A200

Safety Evaluation Supporting Amend 6 to License NPF-82

ML20056A200
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/31/1990
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20056A198	List: ML20056A197 ML20056A199 ML20056A200 ML20056A201 ML20056A202
References
NUDOCS 9008060126
Download: ML20056A200 (15)

Text

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! i SAFETY EVALUATION.BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING PROPOSED EXEMPTION AND AMENDMENT NO. 6 TO FACILITY OPERATING l LICENSE NO. NPF-82 '

LONG ISLAND LIGHTING COMPANY i SHOREHAM NUCLEAR POWER STATION. UNIT 1

, DOCKET NO. 50 322

1.0 INTRODUCTION

By letter dated December 15, 1989, Long Island Lighting Company (LILCO or l the licensee) submitted an amendment to Facility Operating License No. '

, NPF-82 for the Shoreham Nuclear Power Station, Unit 1, which requested authority (1) to cease all offsite emergency planning and preparedness activities,and(2)toimplementaproposed"DefueledEmergencyPrepared.

ness Plan" (DEPP) to replace the current onsite plan the "Shoreham

! Nuclear Power Station Emergency Preparedness Plan." ,LILCO stated that in its present defueled state, there is no credible accident which can occur at Shoreham that would require offsite emergency preparedness.

LILCO's submittal included requests for (1) an exemption from the emergency and (2) a license amendment preparednessrequirementsof10CFR50.54(q)(13)relatedtoemergency to suspend license conditions C.(9) through preparedness in Shoreham's operating license (NPF 82). In support of its submittal, LILCO provided a technical report, " Radiological Safety Analysis for Spent Fuel Storage and Handling," in which a spectrum of fuel handling accidents was evaluated.

On March 27, 1990, the NRC published a notice (55 FR 12076) that the Commission is considering the issuance of an amendment to the Shoreham license which would suspend the effect of the license conditions pertaining to emergency preparedness; i.e., license conditions 2.C(9) through 2.C(13).

The Commission has determined that the license amendment request involves no significant hazards consideration.

The licensee referenced in its submittal the Settlement Agreement with the State of New York whereby Shoreham will not be operated under LILCO ownership. Under the Settlement A Long Island Power Authority (LIPA)greement. LILCO in seeking NRC is cooperating approval with the to transfer Shoreham to LIPA. In anticipation of this transfer, LILCO has removed the

• fuel from the plant's reactor and placed it in the spent fuel pool. In a letter to the NRC dated January 12, 1990, the licensee committed to not place nuclear fuel back into the Shoreham reactor without prior NRC approval. Further, LILCO agreed to never place fuel back into the 9008060126 900731 DR ADOCK 0D00 2

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reactor without the prior establishment of ar. offsite emergency response organization comparable in effectiveness to the Local Emergency Response Organization (LERO), the utility organization responsible for implementing the offsite emergency plan for Shoreham. On March 29 1990, the NRC issued a confirmatory order prohibiting the licensee from placing any nuclear fuel into the Shoreham reactor without prior approval from the MC. (55FR12758).

The Shoreham Nuclear Power Station is currently defueled with all 560 fuel bundles in the spent fuel pool. Shoreham's operating history indicates a low amount of fuel burnup; i.e. three low power runs (0 5%) which LILCO equates to about two effective full power days of operation. Shoreham's last critical operations were conducted on June 7, 1987 The licensee has estimated that the total residual heat being generated by radionuclide decay and transferred to the spent fuel pool was approximately 550 watts as of June 1989 and will be approximately 250 watts by June 1991. LILCO states that, given Shoreham's defueled condition and the negligible decay heat being generated by the plant's fuel, the occurrence of an accident that would require offsite emergency response is not credible.

The NRC staff has reviewed the Defueled Emergency Preparedness Plan based on the acceptance criteria applicable to onsite plans included in the planning standards of 10 CFR 50.47(b), the requirements of Appendix E to 10 CFR Part 50, and the guidance criteria of NUREG-0654/ FEMA-REP-1, Revision 1. " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980. The staff review took into consideration the current defueled condition and inherent low risk of Shoreham. The NRC staff also reviewed the Defueled Emergency Preparedness Plan based on the standards of 10 CFR 50.47(d) which state the requirements for a license authorizin only fuel loading and low power testing.

The standards of 10 CFR 50.47(g) recognize the lower risk associated with low power operation d

and are considered by the staff to be generally appropriate for reviewing the offsite aspects of the Defueled Emergency Preparedness Plan.

2.0 ACCIDENT ANALYSIS AND STAFF EVALUATION The potential for emergency events to occur and their possible u nsequences are presented in LILCO's submittal, " Radiological Safety Analysis for Spent Fuel Storage and Handling." The safety analysis establishes that Shoreham's spent fuel is in a low burnup condition 7 (equivalent to two full power days) and that the amount of decay heat being generated by the fuel in the spent fuel pool as of June 1989 is negligible -- approximately 550 watts. With the fuel in such low burnup condition, the LILCO safety analysis indicates that active systems for pool water makeup are not required and that passive couling in the fuel pool is sufficient to maintain fuel cladding integrity.

Based on its safety analysis, LILCO has determined that the consequences of previously evaluated accidents are greatly decreased given Shoreham's non-operating, defueled status. The spectrum of accidents evaluated in the Shoreham Updated Safety Analysis Report (USAR) are reviewed in the .

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safety analysis and those events that apply to the storage and handling of spent fuel are identified. Two events have been found to be relevant:

(1) Fuel-Handling Accident (USAR Section 15.1.36), and (2) Liquid Radweste Tank Rupture (USAR Section 15.1.32). For the Fuel-Handling Accident, the safety analysis calculates that the integrated whole body dose (1.74E-06 rem) ,

at the site boundary is well below the Environmental Protection Agency's Protective Action Guides (EPA PAGs) for protecting the public from exposure I

(15 rem whole body dose). For the liquid radwaste tank rupture, the whole body dose (1.80E-08 rem) is also much less than the EPA PAG limits.

The safety analysis also postulates a " worst case" radiological event, in which thebody totaldose gaseous inventory)of the core For this event is released.

the whole (1.08E 03 rem is still well below the EPA PAG limits.

The dose to the thyroid from these postulated accidents is negligible.

Based on its review of LILCO's analysis of possible events at Shoreham, the staff concurs with the analysis and concludes that there is no credible accident for Shoreham in the defueled condition which could result in the release of radioactive materials to the environment in quantities that <

would require protective actions for the public.

2.1 Assignment of Responsibility (Organization Control)

The NRC staff has reviewed the Shoreham Defueled Emergency Preparedness ^

Plan and concludes that the planning standard regarding responsibilities for emergency response are adequately addressed in the plan.

The Shoreham Defueled Emergency Preparedness Plan describes the organizations that are intended to be part of the overall response effort in the event of an emergency at Shoreham. In addition to the normal plant operations staff, these organizations include the licensee's corporate headquarters staff and local su andfirefighting)pportorganizations(police, medical,assistance Federal radiological monitoring hospital, and ambulance

' support is available from the Brookhaven National Laboratory which is located within 10 miles of the Shoreham site.

LILCO states that Suffolk County and New York State will implement actions as needed to protect the health and safety of the public, consistent with New York Executive Law Article 2-B. However, with Shoreham in the defueled condition, postulated accidents at the plant are not expected to result in any offsite releases of radioactive materials at levels which would ,

require the implementation of State or County protective actions such as evacuation or shelter for the public.

2.2 Onsite Emergency Organization The planning standard regarding on-shift facility licensee responsibilities l for emergency response is adequately addressed in the Defueled Emergency Preparedness Plan considering the defueled status of the Shoreham facility.

4 The Defueled Emergency Preparedness Plan describes the onsite emergency organization. The licensee will maintain a minimum on-shift organization of four persons including at least one Senior Reactor Operator (SRO) and one reactor operator (RO). Fire Brigade and Security personnel will be on site as specified in plant Technical Specifications and the Site Security Plan. Health Physics shift coverage will be provided as needed.

In the event of an emergency, the normal on shift operations personnel are responsible for the initial evaluation of the incident, performing any immediate operations which are necessary to mitigate the consequences of the incident, and activating the Defueled Emergency Preparedness Plan.

The senior member of the operations staff, the Watch Engineer, or another qualified individual on shif t, assumes the position of Emergency Director.

There will be at least one qualified Emergency Director on duty at all times.

The Emergency Director has the authority and responsibility to classify the emergency, notify offsite agencies, and make )rotective action recommendations. An augmentation procedure will ae initiated to meet the staffing objective of providing an additional 19 persons with expertire in various emergency response functional areas within one hour. Upon activation of the Technical Support Center (TSC), the duties of the Emergency 01 rector will transfer from the Watch Engineer to a qualified Emergency Direr, tor-located in the TSC.

The basic responsibilities and authorities for each position in the LILCO emergency organization are specified in the plan. The responsibilities of the Emergency Director include actions to ensure that prompt emtergency notifications are provided. The Emergenc notifying or directing the notification (y Director is responsiole for of the State of New York, Suffolk County, and via the theControl NRC. Room Communicator)

The Assistant Vice President, Nuclear Operations, or his de:ignated alternate, will assume the emergency position of Response Mancger upon arrival at the Corporate Information Department. The Response Manager will coordinate corporate support for emergency response and will also be the main point of contact with Federal, State, and local government representatives.

2.3 Emergency Response Support and Resources The planning standard regarding arrangements for requesting and utilizing as,istance resources has been adequately addressed in the Defueled Emergency Preparedness Plan considering the defueled status of the Shoreham facility.

Arrangements have been made by the licensee to utilize offsite organizations to assist the recovery Shoreham plant operations staff in emergency mitigation and ef forts. A letter of agreement with the Wading River Fire Department is included in the plan. This agreement provides for immediate 24 hour-per-day response for fire, ambulance, and rescue services, i Letters of agreement with Central Suffolk Hospital and Radiation Management Consultants for medical support are also included in the plan.

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5 The LILCO Response Manager has the authority to request Federal assistance to support an emergency response effort at Shoreham if needed. Federal assistance is available through activation of the Federal Radiological Monitoring and Assessment Plan (FRMAP). The FRMAP is implemented from DOE's Northeast regional area office at Brookhaven National Laboratory (BNL), located within 10 miles of the Shoreham site. Arrangements for emergency assistance have also been made with the Institute of Nuclear Power Operations.

Arrangements for the accommodation of State and local staff at the licensee's near-site Emergency Operations Facility (EOF) have not been made as part of the Shoreham Defueled Emergency Preparedness Plan. The near-site EOF is an offsite emergency preparedness requirement. Due to the low risk of an accident with offsite consequences, a near-s4te EOF will not be maintained under the DEPP.

2.4 Emeroency Classification and Action. Level Scheme The Shoreham Defueled Emergency Preparedness Plan adequately addresses the emergency classification and action levels associated with the Shoreham facility in the defueled configuration, incidents at nuclear power plants are categ9rized itt classes accoroing to a graduated level of severit; 's).oneNotification of four emergency of an Unusual Event, Alert, Site Area Emergency, an? 4tralEmergency. The licensee has evaluated the potential consequences vi a spectrum of postulated accidents and concludes that there is no credible accident for Shoreham in its defueled condition which could result in an emergency classification more severe than an Alert. The licensee submitted its proposed Emergency Action Level classification scheme on April 2, 1990, in Proposed Defueled Emergency Preparedness implementation Procedure (DEPIP) 1-0 " Classification of Emergency Action levels." The licensee's proposed Emergency Action Level scheme demonstrates a comprehensive and anticipatory approach to emergency classification at the defueled Shoreham facility.

2.5 Notification Methods.and Procedures The Shoreham Defueled Emergency Preparedness Plan adequately aodresses the methods and procedures for notification of emergency response personnel, State and local organizations, and the public considering the defueled status of the Shoreham facility.

AccordingtotheDEPP,theEmergencyDirector(WatchEngineer,orother qualified individual), will announce the emergency condition over the page party system and direct the Control Room Consnunicator to initiate notifica-tion of emergency response personnel. The Control Room Communicator will notify appropriate station personnel, offsite organizations and other '

l personnel in the owner controlled area. Notification to the emergency organization is made by use of the page-party system, the pager system, the computerized callout system, and/or commercial phone, i

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i The Emergency Director will designate a Licensed Operator, if available, to notify the NRC or the Control Room Communicator will rake the call.

The Technical Support Center (TSC) upon its activation will assume notifica-tion and comunication responsibilities from the Control Room except for i j notifications to the NRC.

New York State and Suffolk County will be notified of an incident at Shoreham by means of the New York State Radiological Emergency Communica-tionsSystem(RECS) hotline. Comercial telephones will be used as backup to notify New York State and Suffolk County in the event the RECS phones  ;

are disconnected, i

1 LILCO notes that New York State and Suffolk County authorities apparently have disconnected their RECS phones in support of their litigation position i

t in the licensing proceeding. The NRC has recognized that, consistent with )

the "best efforts" principle in the event of an actual emer l t

' governmental authorities would reconnect their RECS phones.Ingency the these l interim, the New York State and Suffolk County warning points are notified by backup commercial phones until RECS communications are reestablished.

The LILCO Public Affairs Emergency Response Organization, under the direction of the Emergency Communications Director, will provide information on the event to the public via the news media. The Public Affairs Emergency )

Response Organization may be partially or fully activated at the Notification of Unusual Event classification, and will be fully activuted upon the declaration of an Alert. The licensee does not intend to test or maintain '

the Shoreham Emergency Notification System based on the unlikely need for offsite protective actions.

2.6 Emergency .comunications .

The planning standard for prompt comunications among response organizations is adequately addressed in the Defueled Emergency Preparedness Plan.

The licensee's communications capabilities include a variety of normal and emergency systems, several with redundant power supplies, to ensure adequate comunications between site emergency centers and offsite agencies.

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The licensee's Defueled Emergency Preparedness Plan lists the type and description of each system. Each onsite emergency facility has comercial telephone radio,telecopierdedicated phone lines, private automatic exchanges, two-way and microwave radio. The plant Control Room, additionally, has the Emergency, Notification System (ENS), a page-party system, and i sound powered telephones. The Technical Support Center has ENS, page-party and the Health Physics Network (HPN). The New York State Radiological Emergency Communications System Hotline (RECS) is also available in the i Control Room and Technical Support Center, although subject to the limita-tions noted above. Twenty-four hour per day manning of the communication links is provided by the Control Room staff, the local Police departments, and the New York State Police.

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7 2.7 Public Education and Information 4

The planning standard for public information is adequately addressed in the Defueled Emergency Preparedness Plan considering Shoreham's defueled condition.

The role of the licensee's Public Affairs Emergency Response Organization for providing and coordinating the release of up-to-date information to the public via the news media during an emergency at the Shoreham facility is described in the DEPP. The licensee's Emergency Comunications Director  ;

(ECD) and Emergency Communications Liaison (ECL) will be contacted by '

pager in an emergency situation. The LILCO Corporate Information Department in Hicksville, NY will be activated by the ECD as required.

The licensee does not intend to maintain a public education and information program under the DEPP nor to periodically issue information on what to do in an emergency based on the low risk of an accident with offsite consequences. ,

The public has been made aware of the defueled Status of the plant through '

extensive media coverage of the Shoreham licensing case, l

2.8 Emergency Facilities and Equipment The planning standard for adequate emergency facilities and equipment to support an emergency response effort is adequately addressed in the DEPP considering the defueled status of the Shoreham facility.

The Defueled Emergency Preparedness Plan identifies facilities which are intended to be used as emergency centers in the event of an emergency situation. These include the plant Control Room, the Technical Support Center (TSC) and the Operational Support Center. In general, each onsite emergency facility has commercial telephone, dedicated phone lines, private automatic two-way radio, telecopier and microwave radio. Due to the low risk of an accident with offsite consequences, a near-site Emergency Operations facility, an offsite emergency preparedness requirement, will i

not be maintained as part of the DEPP. In the event of an incident requiring the release of information to the public, the Corporate Information Department in Hicksville will be activated. Protective clothing, l

respiratory protection, air samplers, and other standard radiological i equipment and supplies are available for emergency use. Provisions have been made to periodically check the equipment and to maintain adequate supplies.

2.9 Accident. Assessment.

The planning standard for methods, systems and equipment to be used in accident assessment and radiological monitoring is adequately addressed in the DEPP.

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The systems and equipment for assessing and monitoring the actual or potential consequences of a radiological emergency condition are described in the DEPP. These include the liquid radwaste system monitor, the station vent exhaust system low range monitor, and the station, reactor building and radwaste building normal ventilation monitors.

Meteorological information at the Shoreham site is provided by instrumenta-tion on two meteorological towers. The Radiation Monitoring System (RMS) includes radiation detection systems and equipment located throughout the plant, redundant central processing units, and control and display systems in the Control Room, TSC, and Health Physics office. The RMS displays the process, and effluent radiation monitors. The RMS will calcu airborne.

readingsfromthemeteorologicalinstrumentationandthearea}ateand _

display atmospheric dispersion values and dose rate versus direction and distance based on site meteorological data, effluent monitor data, system flow rates, and either a hypothetical source term or a source term based on a sample of the effluent.

To supplement the plant instrumentation data, radiological survey teams will be dispatched as necessary to perform onsite and offsite surveys. ___

These teams will be equipped with portable radiation survey instruments and air samplers. All monitoring will be under the control and direction of the Radiological Assessment Coordinator. During an emergency the offsite radiological impact will be assessed by means of environmental measurements and predictive radiological dose consequence models.

2.10 _ Protective Response The slanning standard for protection actions is adequately addressed in the SEPP considering the reduced risk associated with Shoreham's defueled condition.

I, The protective response actions for onsite personnel, including plant staff, visitors and contractors, include the sounding of alarms and public address announcements. The page-or to issue safety instructions. party Thesystem will bethat DEPP states used plant toDefueled call personnel Emeigency Preparedness implementation Procedures will describe the detailed methods for the accountability of onsite persons, assembly points and protective actions to be taken.

It is not expected that protective actions for the public will be required '

under the DEPP due to the low risk of an accident with offsite consequences for Shoreham in its defueled condition.

2.11 Rad ological Exposure Control The planning standard requiring means to control the radiological exposure of emergency workers is adequately addressed in the DEPP.

Management of the exposure control program for onsite emergency workers during accident conditions is assigned to the Emergency Director, with assistance from the Radiological Assessment Coordinator (RAC). Monitoring Il III

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teams will be established under the direction of the RAC. The teams are responsible for duermining radiation levels around the plant and for monitoring individuals. The teams have various portable radiological instruments available for both routine and emergency use. There are also permanently mounted area radiation tonitors which will sound an alarm at preset levels. Respiratory protection equipment is also available.

' Onsite emergency workers will wear personnel dosimeters to monitor their exposure. The Emergency Director or the Radiological Assessment Coordinator may authorize volunteers to receive doses higher than 10 CFR 20 limits under emergency conditions in accordance with EPA PAG guidelines for emergency workers. Otherwise, the normal quarterly and annual exposure limits will be observed.

2.12 Medical Services The planning standard for medical services is adequately addressed in the DEPP considering the defueled status of the Shoreham facility.

The Defueled Emergency Preparedness Plan includes letters of agreement with Central Suffolk County Hospital, located in Riverhead, NY, which has agreed to accept and treat any person who is injured and contaminated, and with the Wading River Fire Department which has agreed to provide ambulance and rescue services to the Shoreham facility. Arrangements for backup hospitals and medical services have been made through a contract with l RadiationManagementConsultents(RMC). Letters of agreement with these support organizations are included in the plan.

A first aid / medical treatment room is located at the Shoreham site. First aid kits and stretchers are located throughout the facility. At least one ,

person per shift is trained in emergency first aid techniques.

2.13 Recovery and Recently Planning The planning standard for general plans for recovery and reentry is adequately addressed in the DEPP considering the defueled status of the Shoreham facility.

The Defueled Emergency Preparedness Plan describes the general actions to be followed by the licensee for recovery and reentry operations. Guide-lines have been developed for the protection of workers entering the affected areas of the plant. The Emergency Director and the Corporate Response Manager will organize the LILCO staff, as appropriate, to ensure that the recovery effort is properly managed.

1 2.14 Exercises.and. Drills The planning standard for periodic exercises and drills is adequately addressed in the DEPP.

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10 The Defueled Emergency Breparedness Plan discusses exercise staffing, simulation, monitoring and critiques. The Emergency Preparedness Coordinator 2

is responsible for exercise preparation, critique and corrective action.

The Shoreham periodic drill program covering various aspects of the Defueled Emergency Preparedness Plan is summarized in the plan. Specific drills to be performed include the following:

Fire drills in accordance with fire protection procedures tiedical drills annually Radiological monitoring drills annually Health Physics drills semiannually In addition, the communications equipment is tested monthly (communications with the State of New York is tested quarterly).

2.15 Radiological Emergency Response. Training <

The planning standard for radiological emergency response training is I adequately addressed in the DEPP. I i

The Defueled Emergency Preparedness Plan describes the licensee's program for training plant personnel in emergency response duties. The extent of the training is dependent on an individual's assigned responsibilities but all personnel receive basic instructions in the fundamentals of the l

i Defueled Emergency Preparedness Plan. Training is provided in emergency I procedures, emergency radiological monitoring, general radiation protection,  !

fire fighting, first aid and emergency communications.

LILCO states that training for offsite assistance agencies (fire, ambulance, medical) will be provided by LILCO personnel.

such subjects as emer This training will include I

during an emergency, gency plan activation, notification, expected roles radiation protection requirements during an emergency, and an indoctrination on the Defueled Emergency Preparedness Plan.

Training for those offsite emergency personnel who may be expected to l enter the site will include an onsite familiarity briefing, site access i procedures and applicable communications procedures, responsibilities and interfaces.

2.16 Plan Development and Review The planning standard for plan development and review is adequately address it, the DEPP.

The Emergency Planning Coordinator is responsible for the development, review and updating of the Defueled Emergency Preparedness Plan and for l

the coordination with offsite governmental agencies. The Einergency Planning Coordinator shall ensure that a review of the Defueled Emergency Preparedness Plan and procedures is conducted annually.

11 The licensee states that the emergency prepare 1 ness program will be audited by an independent review board annua / 11. Audit results vill be reported to the Vice President-Corporate Services Assistant Vice President-Nuclear Operations and other LILCO managers. The resultv Of each audit will be answered and details of corrective actions taken .11 be documented and raintained for an oppropriate period of time.

Revisions to the plan will be controlled and distt1buted in accordance with Shoreham document control procedures. Changes and revisions to the i plan will be issued to holders of controlled copies through the document  !

control process.

3.0 FINDINGS 3.1 Defueled Emergency. preparedness. plan The proposed Shoreham Defueled Emergency Preparedness Plan has been reviewed b the NRC staff against the acceptance criteria included in 10 CFR 50.47(y) b and (d), Appendix E to !O CFR 50, and NUREG-0654/ FEMA-R Revision 1. The staff review took into consideration the non-operating and defueled condition of the Shoreham plant including the low amount of fuel spentburnup fuel. and the negligible amount of decay heat being generated by the Based on a review of LILCO's analysis of possible events at Shoreham, the staff concurs with the analysis and concludes that there is no credible accident for Shoreham in the defueled condition which could result in the release of radioactive materials to the environment in quantities that  ;

would require protective actions for the public.

The staff concludes that the Shoreham Defueled Emergency Preparedness Plan provides an adequate basis for an acceptable state of emergency preparedness for Shoreham in its non-operating and defueled condition and provides reasonable assurance that adequate protective measures ca,n and will be taken in the event of a radiological emergency at Shoreham. It is therefore concluded that LILCO may cease all offsite emergency preparedness activities, except to the extent discussed above, and implement the Defueled Emergency Preparedness Plan upon approval of LILCO's request for license amendment and exemption from the requirements of 10 CFR 50.54(q). This determination applies only to Shoreham in its defueled condition and is not considered to be an irreversible step toward decommissioning in that emergency preparedness for full power operations can be re-established if fuel is ever placed back into the Shoreham reactor.

3.2 License Amendment The licensee has requested that Shoreham Facility Operating License NPF-82 be revised by adding a license condition that suspends the effect of license conditions 2.C(9) through 2.C(13) during Shoreham's current non-operating and defueled condition. The Commission has previously reached a proposed determination that the license amendment request

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12 involves no significant hazards consideration. (See 55 FR 12076). The license conditions involve (1) shutting down the plant in the event of a strike by LILCO employees involved in offsite response (i.e., the local Emergency Response Organization. LERO), (2) placing the reactor into a hot shutdown condition if a hurricane warning is issued by the National Weather Service for a hurricane approaching Long Island, (3) dispatching a LILCO (LFR0) representative to the Suffolk County Emergency Operations Center t; serve 6s a liaison and to assist county officials upon the declaration of an Alert or higher emergency classification involving a potential offsite response, (4) requiring that a trained person be at the Local Emergency Response Organization (LERO) Emergency Operations Center (EOC) at all times during #1 ant operations above 5 percent rated power, and (5) conducting quarterly drills of the offsite emergency plan by LERO.

Based on the defueled condition of the Shoreham plant, the NRC Confirmatory Order prohibiting the licensee from placing any nuclear fuel into the reactor, and our conclusion that the Defueled Emergency Preparedness Plan provides an adequate basis for an acceptable state of emergency preparedness, we find that the suspension of license conditions 2.C(9) through 2.C(13) is acceptable.

3.3 EXEMPTION The licensee has requested an exemption from certain emergency planning requirements of 10 CFR h rt 50. In particular. lit':0 will no longer meet the emergency preparedness standards for offsite preparedness and the standards for onsite preparedness which require a near-site Emergency Operation Facility, a prompt public notification system, and the distribu-tion of public information materials.

Based on a review of LILCO's analysis of possible events at Shoreham in its defueled status and the staff conclusion that the Defueled Emergency Preparedness Plan provides an adequate basis for an acceptable state of emergency preparedness, we find that the licensee's request for an exemp-tion is reasonable in light of the highly reduced offsite radiological risk associated with Shoreham's non-operating and defueled condition.

4.0 FINAL N0 SIGNIFICANT HAZARDS FINDING The Comission made a proposed determination that the amendments involve no significant hazards consideration, which was published in the Federal Register (55 FR 12076) on March 30, 1990, and consulted with the State of New York. Accordingly, the Notice afforded the Licensee an opportunity to request a hearing and provided that "any person whose interest may be l affected by this proceeding and who wishes to participate as a party in the proceeding" must file a written petition for leave to intervene within ,

1 30 days, in accordance with the provisions of 10 CFR 2.714. Any such petitions were required to " set forth with particularity the interest of '

the petitioner in the proceeding, and how that interest may be affected by the results of the proceeding."

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in response to the published notice, on April 30, 1990, petitions for leave to intervene and requests for hearin Engineers for Secure Ener Central School District (gy, Inc.and ("SE 2")g were filed t5e Shoreham-Wading

" District"). Therein, the Petitioners argued River by Scien '

that their interests would be adversely affected by the Application, based on their view that it constitutes merely one part of Shoreham's decomission-ing and that "the proposed cessation of offsite emergency preparedness  :

activities would unacceptably increase the risk of radiological injury and '

hence adversely affect the radio % Aal health and safety of Petitioner, its students, its employees, and Mr property." The Petitioners further

' contend that the Application will have an adverse impact upon other of their asserted interests.

Responses in opposition to these setitions were filed by LILCO and the NRC staff, and Commission review of tie requests for hearing and of the responses thereto is pending at this time.

The Commission's standards for determining whether a significant hazards consideration exists are stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves no significant hazards .

consideration if operation of the facility in accordance with a 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 of safety. evaluated; or (3) involve a significant reduction in a margin l A discussion of these standards as they relate to the amendment l request follows:

(1) Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

The probability of a previously evaluated accident will not be increased because the amendment does not affect the function or operation of any system or equipment, but merely permits the cessa-tion of certain offsite emergency preparedness activities. No physical changes will be made to the facility as a result of this proposed amendment, and all applicable Limiting Conditions for Limiting Safety Systems Settings and Safety Limits Operation,in specified the Technical Specifications w}ll remain unchang result of this proposed amendment. Likewise, the amendment will not degrade the performance of any safety system or increase challenges to any safety system assumed to function in the accident analyses.

Moreover, based on its review of the licensee's Safety Analysis, the Comission has determined that with Shoreham in its non-operating, defueled condition accident is signifIcantly reduced.the The probability of any reveals Safety Analysis previously that analyzed Shoreham's spent fuel is in a low burnup condition, and that the amount of deca negligible - y heat being generated approximately 550 watts.by the fuel With theasfuelof June-1989 in such a low is burnup condition, the Safety Analysis indicates that active

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l 14 systems for pool water makeup are not required and that passive cooling in the fuel pool is sufficient to maintain fuel cladding integrity.

' Furthermore, in light of the foregoing as well as the very small fission product inventory, the consequences of any potential accidents are greatly reduced. Therefore, the changes

' do not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Do the proposed changes create the possibility of a new or different i

kind of accident from any accident previously evaluated?

The amendment will only remove certain conditions related to emergency preparedness from Shoreham's operating license. The amendment itself does not affect the function or operation of any system or equipment.

Therefore, the changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

4 (3) Do the proposed changes involve a significant reduction in a margin of safety?

With Shoreham in its non-operating and defueled condition the cessation of offsite emergency preparedness activities will not increase the risk of radiological exposure to the offsite general public. As noted previously, the Safety Analysis establishes that the two appliceble events previously evaluated in the Shoreham USAR have no significant radiological consequences. The Safety Analysis also postulates a " worst case" radiological event, in which the entire gaseous inventory of the entire core is released to the reactor building. For this event the integrated whole-body and skin doses are less than 0.031 percent of the dose luits established by

• 10 CFR Part 100. Therefore, the changes do not involve a significant reduction in any margin of safety.

i Nothing in the submissions by the Petitioners affects these conclusions or the evaluation set out above. Petitioners have not shown or set out with particularity how the proposed amendment would increase the probability or consequence of a previously evaluated accident, create the possibility of a new or different type of accident, or cause a significant decrease in a margin of safety, considering the defueled condition of the plant and the Confirmatory Order of March 29, 1990. This Order prohibits the placer.at l of fuel in the Shoreham reactor vessel without prior NRC approval.

Based on the above, the Commission has reached a final determination that the requested amendment does not involve a significant hazards consideration.

5.0 ENVIRONMENTAL. CONSIDERATION Pursuant to 10 CFR 51.21, 51.32, and 51.35, an environmental assessment and finding of no significant impact have been prepared and published in ,

the Federal Register (55 FR 31111 ) on July 31, 1990 . Accordingly, based upon the environmental assessment, the Comission has determined that the issuance of this amendment will not have a significant effect on the quality of the human environment.

15 6.0 CONOLUSION The Commission made a proposed determination that the amendment involves no significant hazards consideration which was published in the Federal Reoister (55 FR 12076) on March 30, 1990, and consulted with the state of New Yori;. The State of New York cid not have any coments. A notice was published on April 9, 1990 (55 FR 13211) correcting the name and address of the attorney 'or the licensee. On April 30, 1990 counsel for the Shoreham-Wading River School District and Scientists and Engineers for Secure Ener9yfor hearing.Inc.

and requests filed withhas The Commission thereached Comission a finaltwo petitions finding that to intervene this amendment involves no significant hazards consideration.

The Commission has concluded, based on the considerations discussed above, that: (1) The amendment does not involve a significant hczards considera-tion, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Comission's regulations, and (4) the issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public.

Dated: July 31, 1990 Principal. Contributors:

F. Hasselberg F. Kantor S. Brown J