ML20059K114
| ML20059K114 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/04/1993 |
| From: | Bortz A LONG ISLAND POWER AUTHORITY |
| To: | |
| Shared Package | |
| ML20059K102 | List: |
| References | |
| NUDOCS 9311150192 | |
| Download: ML20059K114 (48) | |
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LONG ISLAND POWER AUTHORITY NRC License NPF-82 l Docket No. 50-322 ,
License Change Application No. 2 This License Change Application No. 2 requests an amendment to the NRC License NPF-82 for the Shoreham Nuclear Power Station by:
- 1. Deleting Appendix A, Technical Specifications. i
- 2. Deleting Appendix B, Environmental Protection Plan (Non-Radiological) l
- 3. Revising the Possession Only License, No. NPF- 8 2, Amendment No. 9 The request and supporting documentation are contained in Attachments 1, 2 and 3. ,
Long Island Power Authority f
By: J-Resj) dent Manager A. J.
B[ t ,
Subscribed and sworn to before me this 9 day of //evee la n ,
1993.
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hwr l~/ w N6tary Public of New Yo'rk
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My Commission Expires: 7
/
/ 'l >
/
BRUCE W. EAKEN,JR.
Notay Pubitt., State of New York No. 31 1062830 Qualifted in New York Count _
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LSNRc-2115 Attochnent 1 License Change Application #2 ;
NRC License NPF-82 r
1.0 Description of Chance l This proposed amendment requests deletion of the NRC license provisions and the technical specification requirements .
related to nuclear safety and the safe storage and handling of !
irradiated fuel. !
For the Possession Only License (POL) No. NPF-82, LIPA requests the deletion or revision of the following sections, ;
as shown in the mark-up provided as Attachment 3: paragraph r 1A, related to application dates; paragraph 1B, related to the ;
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original construction of the facility; paragraph 1C, related to the application; paragraph 1D, related to a revision of a !
reference; paragraph 1E, related to POL; paragraph 1H, related-to environmental considerations; paragraph 2A, related to SNPS status; paragraph 2B(2), related to reactor fuel; paragraph 2B(3), related to fission detectors; paragraph 2C(1), related to Maximum Power Level; paragraph 2C(2), related to Technical Specifications and Environmental Protection Plan; paragraph 2C(3), related to Requirement to Obtain NRC Approval to. Place ,
Fuel in the Reactor Vessel; paragraph 2C(4) , . related to license reverting to LILCO; paragraph 2D, related to Fire Protection Program; paragraph 2E, related to Security Plan; and paragraph 3, related to effective date. >
For the Technical Specifications, LIPA requests the deletion of Appendix A to the POL in its entirety. Appendix A consists of the following: Section 1.0 through 1.14, " Definitions"; ,
3 /4. 0 through 4. 0. 4, " Applicability"; 3 /4.1 through 4.1.1. 3.1, *
" Instrumentation" which includes Radiation Monitoring, Seismic -
Monitoring, and Meteorological Monitoring Instrumentation; 3/4.3 through 4.3.3.1, " Plant Systems" which includes Sealed Source Contamination, Settlement of Reactor Building, and Area Temperature Monitoring; 3/4.5 through 4.5.5.1, " Fuel Handling Operations" which includes Communications, Fuel Handling Platform, Crane Travel, Water Level, and Water Chemistry; i 3 / 4. 6 through 4. 6.1.1, " Radioactive Effluents" which includes the Liquid Holdup Tanks; the entire Basis section for.3/4.0 ,
through 4.6.1; 5.0 through 5.4.3, " Design Features"; and 6.0 [
through 6.13.c, "Administrativ? Controls."
The following Technical Specification sections of Appendix'A had been previously deleted or not used at Shoreham: Section 2.0, " Safety Limits and Limiting Safety System Settings" (not _'
used); 3/4.2, " Containment Systems" (not used) ; 3/4.4 through 3/4.4.2, " Electrical Power Systems" (deleted).
Additionally, LIPA requests the deletion of Appendix B, the Environmental Protection Plan (Non-Radiological) in its entirety.
Page 1 of 27
- 1 LSNRC-2115 i Attachment 1 l 2.0 STATUS OF FACILITY AT COMPLETION OF FUEL REMOVAL Shoreham was originally licensed as an operating nuclear power station. During that period, the Shoreham Nuclear Power Station was tested by Long Island Lighting Company (LILCO), the original licensee, only briefly at low (up ;
to 5 percent) power for a total of two effective full #
power days. The License was amended on June 20, 1991 to a Possession Only License (POL) and the Technical ,
Specifications were then revised to eliminate !
requirements associated with reactor operation, while ,
retaining requirements associated with safe fuel handling i and storage and radiological safety. The License was ;
transferred on February 29, 1992 to Long Island Power Authority (LIPA). Decommissioning began in June 1.992 and is approximately eighty five percent complete as of October 31, 1993. Fuel shipments commenced on September !
25, 1993 and will continue until all irradiated fuel is removed from the site. ;
Due to the plant's limited operating history, the extent of activation and radioactive contamination at Shoreham was very limited as discussed in the Decommissioning Plan, as supplemented. Almost all of the radioactive inventory at Shoreham was located in the fuel, the Control Rod Blades, and the Reactor Pressure Vessel (RPV) and its internals. All of these have already been removed, except for the fuel, which is projected to be removed as early as April 1994. By the time the fuel is completely removed from Shoreham, it is expected that contaminated or activated structures and systems will {
have been decommissioned except for the structures and portions of systems associated with the Spent Fuel Storage Pool (SFSP). With the removal of the irradiated fuel, decommissioning of these remaining systems and structures will proceed as discussed below. !
The post-fuel decommissioning work may include: (1) draining and decontaminating the SFSP, and processing the water; (2) draining and decontaminating the Salt Water Drain Tank; (3) removing and decontaminating the ;
remaining portion of the Fuel Pool Cooling and Clean-Up i System; (4) removing, decontaminating and shipping the Spent Fuel Storage Racks; (5) shipping the remainder of i the fuel channels; (6) shipping of the remaining Rad- j waste; and (7) completion of the Termination Survey.
i The SFSP is assumed to be slightly contaminated. ;
Following the removal of the fuel the following tasks ;
will be performed:
(1) Determine contamination levels by performing a i radiological characterization; (2) decontaminating :
and removing fixtures such as underwater work {
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LSNRC-2115 l Attachment 1 !
I tables, tools, new fuel elevator, refueling bridge >
and components, as well as tools and equipment used ,
for fuel removal; (3) placing the removed-fixtures i into strong tight containers for shipping off-site i for further processing; (4) decontaminating walls j and floor using high pressure water and other ;
mechanical techniques; (5) ensuring that .all l contamination above the site release criteria has- !
been removed by performing a radiological !
characterization, and decontaminating as necessary. !
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The majority of the Fuel Pool Cooling and Clean-Up System has already been decommissioned. Those portions that- -
will remain until completion of fuel removal have been radiologically characterized as having contamination levels in excess of the site release criteria. Following ;
the removal of the spent fuel, the remaining i radioactively contaminated piping and equipment will be dismantled as follows: ,
The work will involve the decontamination of fuel :
pool cooling piping which can not be isolated from the filled SFSP, and the removal of fuel pool level and temperature monitors. Removal techniques will be as specified in the LIPA Shoreham Decommissioning Plan, as supplemented. Embedded l piping varying in size from 2" to 12" will be ;
mechanically decontaminated and termination .I surveyed in place. The Fuel Pool Cooling and -
Clean-Up System piping between the pumps and the ,
heat exchangers will remain in place, and will also t have to be termination surveyed in place. .l Radiological characterization of the Spent Fuel Storage 'i Racks has not been completed. LIPA is anticipating that i the racks are contaminated to levels in excess of the i site release criteria. Decommissioning of these racks -
may occur either in parallel with, or after fuel removal.
The tasks associated with decommissioning the Spent Fuel Storage Racks will include:
(1) removal (draining) and processing of water from (
the SFSP; (2) determining the level of contamination by a radiological characterization; .
(3) disconnecting the racks from the liner embedments; (4) surveying the racks to determine !
whether they satisfy the free release criteria. If t the fuel racks meet the free release criteria, they ;
will be released. Otherwise, they will be shipped ;
off-site for further decontamination or volume i reduction. (5) placing the racks into a strong ;
tight container for shipping for volume reduction
- and disposal, if necessary.
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l LSNRC-2115 l Attachment 1 ,
In the LIPA Decommissioning Plan, as supplemented, it was conservatively assumed that the spent fuel racks would be shipped to a low-level radioactive waste (LLRW) disposal ,
facility. No credit was taken for on-site or off-site :
decontamination or volume reduction. The waste volume was estimated to be 8,300 ft'non-reduced shipped in cargo containers as Type A low specific activity (LSA) .
material in accordance with Department of Transportation j (DOT) regulations as described'in 49 CFR 173._ It would be classified as Class A radioactive waste per NRC waste classification regulations as described in 10 CFR 61.
Termination Survey Status f The termination survey of the Shoreham facility began on. <
January 11, 1993. At the time that the fuel removal is completed, reports on survey results will have been completed and submitted to the NRC, as described in the ',
i Termination Survey Plan, reflecting completion of surveys of major areas of the facility. These phased reports include: l Termination Survey Final Report, Phase I (submitted September 30, 1993) covering 48 plant systems and 143 ;
structural or outside ground survey units comprising the ;
outer grounds of the facility, office buildings and miscellaneous structures outside the power block, and the Turbine Building.
f Ie.rmination Survey Final Report, Phase II.(scheduled to be submitted February 2, 1994) acticipated to cover 24 plant systems and 17 structural survey units encompassing the suppression pool, and non-fuel impacted areas of the Reactor Building.
l Termination Survey Final Report, Phase'III (scheduled to be submitted June 15, 1994) anticipated to cover li plant systems and 64 structural survey units which comprise the Rad-waste Building and piping trench areas.
Termination Survey Final Report, Phase IV With the removal of irradiated fuel from the Shoreham facility, the final phase (Phase IV) of the termination survey will begin. This phase, and the subsequent report of results, ,
anticipated to cover the remaining 13 plant systems and ;
113 structural survey units within the Reactor Building.
The submittal of the Termination Survey' Final Report, Phase IV (scheduled to be submitted September 15, 1994)'
will demonstrate that the entire Shoreham facility has ,
been successfully decommissioned through decontamination j or removal, and that the facility is at levels of residual contamination suitable for release for unrestricted ur%
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LSNRC-2115 Attachment 1 ,
Radiological Controls From the preceding, it can be concluded that upon .
completion of fuel removal, there will be no safety- l related equipment or functions at the Shoreham site, and '
radiological safety concerns will be significantly reduced. j The limited radiological characteristics of the plant in >
the post-fuel condition virtually eliminate the scope of ,
requirements associated with plant design objectives .
required for radioactive material controls. The quantity of radioactive material left at Shoreham will be minimal resulting in very limited potential occupational radiation exposure for the balance of the project .
(estimated to be less than O.10 person-rem). The Shoreham station will continue to maintain personnel ,
exposures ALARA in accordance with 10 CFR 20, the Station ALARA Program, and Station Procedures. The post-fuel '
< radiological controls will be delineated in the Defueled Safety Analysis Report (DSAR). 4 Radioactive material above the Termination Survey site release criteria will still be present immediately following fuel removal in the form of remaining SFSP '
water, water added to SFSP due to hydrolazing, and associated contaminated components and piping systems. +
The ability to handle this material, dry active waste (DAW), process media, and to transport radioactive waste t off-site will be maintained in accordance with LIPA's ,
Decommissioning Plan, as supplemented.
Shoreham will still require the use of sealed instrument calibration sources. LIPA will maintain control of radioactive material on-site per the Health Physics ;
Program, as part of the effort required to allow the site's release for unrestricted use.
The station will still process DAW.and liquid rad-waste at the inception of the post-fuel stage. The post-fuel ,
organization will maintain a position equivalent to the present Radiological Controls Division Manager (RCDM).
The RCDM would be charged with ensuring adequate control
- of remaining decontamination, rad-waste packaging and shipping, and health physics functions. Additionally, the control methods established to maintain the remaining applicable portions of the Off-Site Dose Calculation Manual (ODCM) and Process Control Program (PCP) will fall under the jurisdiction of the RCDM. The applicable scope of the ODCM in the post-fuel stage will be limited to that associated with processing and release of SFSP ;
water, as well as final decontamination.
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LSNRC-2115 Attachment 1 Radiological Effluent Controls Other than SFSP water, and fuel pool decontaminating water, that will be processed as described in the PCP and released under ODCM controls, LIPA anticipates only non-radioactive effluent releases once all fuel is off of the site. These releases are regulated by the State Pollution Discharge Elimination System (SPDES) permit.
This permit provides limits on discharges from Shoreham, e.g., sanitary wastes, chlorine, miscellaneous metallic ions, oil, suspended solids, etc.
LIPA intends to separately pursue a revision to the SPDES permit with the New York State Department of Environmental Conservation.
Radiological State of Shoreham Environs The Shoreham environs contain no discernible dose components other than those from natural sources. This conclusion is based on 10 years of monitoring. This period, 1983-1993, covered the pre-operating, operating, defueled and decommissioning stages of the plant. Over this period, data obtained indicated that the concentration of the detectable radioisotopes has either decreased or has remained constant.
I After fuel is off-site, LIPA expects no radioactive effluent releases other than the ODCM-controlled release of water in the SFSP. Therefore there should be no change in the status of the Shoreham environs.
Management Organization / Staff LIPA will maintain an organization that is consistent with the LIPA Act and that is appropriate for the amount and type of work in progress. As the workload decreases, LIPA may combine or eliminate some divisions or sections within the decommissioning project organization, and will reduce the staff accordingly. If and when it may be appropriate, LIPA will also reduce the number of LIPA/NYPA co-employees. LIPA will ensure that management changes and staff reductions are conducted in a manner so as to ensure that sufficient numbers of qualified personnel are available to safely conduct the remaining decommissioning activities at Shoreham.
Programs and Procedures In the absence of Technical Specification requirements, which were designed to ensure the safe storage and handling of fuel, LIPA will retain the following documents, as necessary, to complete decommissioning and the Termination Survey: !
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-- -_________________________________________-.________-.________________________-.----______________a
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LSERc-2115 Attachment 1
- Defueled Safety Analysis Report (DSAR)
- Decommissioning Plan, as supplemented
- Off-Site Dose Calculation Manual (ODCM)
- Termination Survey Plan
- Records Management Plan.
- On-Site Review Committee Charter LIPA will maintain written procedures for decommissioning, termination survey performance, ,
radiation protection, rad-waste processing, packaging and shipping, reportable events and quality assurance.
Administrative controls have been established for procedure preparation, approval and use. LIPA will retain these controls for the areas noted above in the post-fuel stage. Elsewhere, organizations may perform t work under less formal work instructions.
Quality Assurance / Records Upon completion of the irradiated fuel removal, the LIPA Quality Assurance Program will continue to address activities affecting decommissioning, termination survey performance, radiation protection, and rad-waste packaging and shipment, which will continue to be ,
performed in accordance with LIPA's remaining regulatory commitments and requirements. All structures, systems and components, however, will be classified as "Non-Safety Related."
Activities affecting quality will continue to be prescribed by documented instructions, procedures, and appropriate acceptance criteria. Procedures will continue to be in place for the control and issuance of documents, including control of purchased material, equipment, and services, to . tne extent required for maintaining quality in the areas noted above.
Retention of records will be in accordance with the applicable requirements of 10CFR50 as well as commitments contained in the Termination Survey Plan. Also, a records management plan will be in place to capture records retention provisions of the Possession Only
- License as it exists prior to completion of irradiated fuel removal.
Security LIPA will not need to maintain an on-site physical protection system and security organization since quantities of special nuclear material are well below the <
limit to qualify as low strategic significance, and'are not inimical to the common defense and security and do not constitute any risk to the public health and safety.
Page 7 of 27
LSNRC-3115 ;
Attachment 1 i e
i The physical protection system will be downgraded to a level appropriate for an industrial facility since it was originally designed to protect against the design basis threat of radiological sabotage, and this threat no longer exists.
Fire Protection {
Shoreham was designed with fire protection features required to satisfy Criterion 3 of Appendix A to 10 CFR Part 50.
t Criterion 3 of Appendix A to 10 CFR Part 50 specifies that " Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires j and explosions."
As discussed above, structures, systems and components ,
will no longer be classified as " Safety-Related," due to the fact that spent fuel has been removed from the site, that Shoreham has been dismantled to the point where design basis accidents are not credible events, and that post-fuel fire conditions would not radiologically impact public safety. Therefore, a nuclear fire protection program will no longer be a requirement at Shoreham.
Emergency Planning LIPA has been exempted from all Emergency Planning requirements of 10 CFR 50.47 and 10 CFR 50. Appendix E, i per NRC letter dated September 30, 1993, subject: ,
Issuance of Exemption from the ' Emergency Preparedness Requirements of 10 CFR 50.54 (q) for the Shoreham Nuclear t Power Station, Unit 1.
i 3.0 Reason for Change
- I. Revision of the Possession Only License (POL) No. NPF-82 The following sections of the POL are proposed for deletion or
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revision ,
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- 1) Section 1.A, would be revised to add that this application will be filed by Long Island Power Authority ,
on November 4, 1993, and that - it complies with the l standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I.
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l LSNRC-2115 Attachmsnt 1 '
- 2) Section 1.B, would be deleted in its entirety because it !
is in reference to the original construction of the :
facility, which is no longer of any significance at this stage of the facility's history. Deletion of this reference has no bearing on any applicable accidents or i margins of safety. All subsequent sections of paragraph I will be renumbered accordingly. This is merely for ;
editorial clarity. ;
- 3) Section 1.C, would be revised to delete the words "as i amended," since the current application will replace the '
amended application referenced in paragraph 1.A of the current POL. This is also merely an editorial clarification.
- 4) Section 1.D, reference to section 2.D would be revised to refer to section 2.C, which is the only paragraph in the newly proposed license which discusses exemptions that are currently in place. This is again merely an editorial clarification.
- 5) Section 1.E, ld be revised to change the term
" operating licem: e" to " Possession Only License". This j is also merely an editorial clarification.
- 6) Section 1.H, would be revised to delete reference to Appendix B, the Environmental Protection Plan (EPP) (Non-Radiological). All aquatic and terrestrial issues addressed by the EPP are either no longer applicable, were resolved previously, or are covered by other regulatory agencies. j
- 7) Section 2.A, would be revised to update the licensing basis documents and reference to "a boiling water nuclear ,
reactor and associated equipment." The facility will be l described in the Shoreham Defueled Safety Analysis Report !
and the Shoreham Environmental Report, as supplemented and amended.
- 8) Section 2.B(2) would be deleted. The reactor fuel will no longer be at Shoreham.
- 9) Section 2B(3) would be revised. Fission detectors will not be present at Shoreham.
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- 10) Section 2.C would be revised to add the following l condition: " Licensee Certification of Post-Fuel ;
Condition. Regardless of the issue and approval date of !
this license Amendment No. 11 the effective date of this j amendment shall be the date the licensee provides I certification that all special nuclear material as irradiated fuel'has been permanently removed from the site." This condition is analogous to the condition placed on the POL issued to SONGS 1. The difference is 1
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LSNRC-2115 Attachment 1 ;
that Shoreham's proposed amendment is based on irradiate'd I fuel being permanently removed from the site, where as the SONGS 1 POL was based on reactor fuel being ,
permanently of f-loaded from the reactor. This condition i allows flexibility in the implementation of this amendment and would provide the most cost savings. I i
- 11) Section 2.C(1) would be deleted. In'the post-fuel state i of Shoreham, LIPA will not be able to operate the i facility at any core power level. ;
- 12) Section 2.C(2) would be deleted. The Technical l Specifications in Appendix A, and the Environmental .
Protection Plan contained in Appendix B are proposed to !
be deleted by this License Change Application No. 2. !
- 13) Section 9.C(3) would be deleted. The fuel will be l totally emoved from Shoreham and will never be placed ;
into the reactor pressure vessel.
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- 14) Section 2.C(4) would be deleted. LIPA has proven itself ;
as a qualified and viable organization by being able to j manage and decommission the SNPS for 1 1/2 years after l license transfer, and remains in active existence under statutes of the State of New York. There are no challenges to LIPA's existence and, LIPA expects to {
manage Shoreham throughout the removal of fuel and l Termination Survey until the site is released for ;
unrestricted access. i
- 15) Section 2.D would be deleted. The provisions of this condition were to ensure that LIPA maintains the fuel in i the spent fuel storage pool in a safe condition in the ;
event of a fire. Once the fuel is removed from the fuel l pool, this condition would no longer be applicable. {
- 16) Section 2.E would be deleted. The provisions of the SNPS :
Security Plan are based on complying with 10 CFR 73 for l fuel storage in the Spent Fuel Storage Pool.- With the ,
removal of fuel,10 CFR 73 will no longer apply to LIPA. j
- 17) Section 3 is being revised to make this license amendment i effective as of the date the licensee provides i
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certification that the irradiated fuel has been permanently removed from the Shoreham Nuclear Power Station.
II. Deletion of Technical Specification Definitions (Sections 1.0 i through 1.14) i i
The Definitions Section of the Technical Specifications can be j deleted in its entirety. These definitions no longer serve any purpose since they are only used in Section 3 and 4, and (
these two sections are also proposed for deletion.
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LSNRC-2115 Attachmsnt-l' Other definitions such as SITE BOUNDARY, MEMBER (S) OF-THE PUBLIC, UNRESTRICTED AREA, REPORTABLE EVENT, OFF-SITE DOSE CALCULATION MANUAL and PROCESS CONTROL PROGRAM remain relevant to post-fuel activities at Shoreham, but are adequately described in either NRC regulations, Station Procedures or in the program manuals themselves.
III. Deletion of Technical Specification Limiting Conditions for Fuel Handling Operations and Surveillance Requirements (Sections 3/4.0 through 4.6.1.1).
A. Applicability (Sections 3/4.0 throuch 4.0.4)
This section provided guidance in the areas of compliance with the Limiting Conditions, use of ACTION requirements, commencement and continuation of FUEL HANDLING OPERATIONS and time intervals for performing Surveillance Requiraments.
With irradiated fuel removed from the site, the Limiting Conditions for Fuel Handling Operations will no longer be relevant. With no Limiting Conditions, there is no reason to retain the corresponding guidance and applicability on their use.
B. Instrumentation (Sections 3/4.1 throuch 4.1.1.3.1)
This section contained the Limiting Conditions for Radiation Monitoring, Seismic Monitoring .and Meteorological Monitoring Instrumentation. The radiation monitors (also called criticality monitors) were required only for the New Fuel Storage Vault and Spent Fuel Storage Pool. The seismic monitoring instrumentation was only required for the Reactor Building. (The Reactor Building was maintained as a Seismic Category I structure because it contained the fuel.) The meteorological monitoring instrumentation was originally required for estimating potential reactor accident radiation ~ doses to the public and was retained 'in the POL Technical Specifications for potential fuel handling accident dose i estimation. With the irradiated fuel removed from the site, this instrumentation would not be required to be 4 operable.
C. Plant Systems (Sections 3/4.3 throuch 4.3.3.1)
This section contains Limiting Conditions for Sealed Source Contamination, Settlement of Reactor Building and Area Temperature Monitoring. Sealed Source Contamination requirements are applicable at all times. Therefore, even though LIPA requests that this Limiting Condition be deleted from the Technical Specifications, LIPA Will continue to meet its requirements by complying with 10 ;
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.. I LSNRC-2115 Attachmsnt 1 _
CFR 31.5. The requirements of this regulation will be implemented through the use of Station Procedures for j those sealed sources still in use. (Since permanent ;
shutdown of the plant, approximately two thirds of the sealed sources have been disposed of and LIPA is i currently making arrangements for disposal of those i sealed sources which will not be needed when the fuel is off the site.) .
The Limiting Conditions on Settlement of the Reactor Building and Area Temperature Monitoring were only [
retained in the POL Technical Specifications because fuel F remained in the Reactor Building. These Limiting ;
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Conditions will no longer be applicable when the fuel is removed from the site.
D. Fuel Handling Operations (Sections 3/4.5 throuch 4. 5.5.1) l P'
This section contains Limiting Conditions on y Communications, the Fuel Handling Platform, Crane Travel, l Water Level -
Spent Fuel Storage Pool, and Water Chemistry -
Spent Fuel Storage Pool. These Limiting :
Conditions are all required whenever storing or handling irradiated fuel or control rods. None of these Limiting Conditions will be applicable since all fuel and control rods will have been removed. }
E. Radioactive Effluents (Sections 3/4'.6 throuch 4.6.1.1)
This Limiting Condition places a 10 curie limit on the i amount of radioactive material which can be contained in each outside t'emporary tank. This is to ensure that in j '
the event of an uncontrolled release, the resulting concentrations would be less than the limits of 10 CFR >
20, Appendix B, Table II, Column 2. It is applicable at all times. However, with the exception of sealed ,
sources, after the fuel is removed, there will only be a very small amount of activity left on-site (less than 8 millicuries) which will be several orders of. magnitude below the 10 curie limit. Therefore, this Limiting '
condition will no longer be needed.
F. Bases (Title pace throuch caue B 3/4 6-1)
The Bases Section summarizes the reasons for the Specifications in Section 3.0 and 4.0. With the deletion of Sections 3'and 4 of the Technical Specifications, there will no longer be a need for any Bases.
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LSNRC-2115 :
Attachment I l IV. Deletion of Design Features (Sections 5.0 through 5.4.3) {
A. Site (Sections 5.1 throuch 5.1.3) i i
This section contains figures which show the Exclusion Area, .
Low Population Zone, and Site Boundary for Radioactive Gaseous and Liquid Effluents. These items are associated with r radiological releases to the off-site environs. Even with the [
present worst-case fuel damage accident, there is insufficient radioactivity remaining which could be released and result in any significant exposure to the general public off-site.
Removal of fuel from the site will further eliminate the ;
potential for this low-consequence event. Furthermore, there }
have never been any detectable isotopes in the Shoreham gaseous effluents other than naturally occurring isotopes.
Finally, before completion of fuel removal, the liquid rad-waste system will have been isolated and a temporary !
filtration and demineralizer system will se used for the Spent Fuel Pool water. Therefore, the only remaining anticipated off-site release with potential radioactive material content (within ODCM limits) will be the final disposal of water from the SFSP. Deletion of these figures is acceptable because the l equivalent information is already provided in Figure 5.1.3 of the ODCM.
B. Fuel and Control Rod Data (Sections 5.2 throuch 5.2.2)
This section is no longer pertinent since the irradiated fuel and the control rods will have been removed from the site. ,
C. Meteorolooical Tower Location (Sections 5.3 throuch 5.3.1)
The meteorological tower contains the meteorological i monitoring instrumentation. The technical specification requirements on this instrumentation would be deleted so the location of the tower can also be deleted.
D. Fuel Storace (Sections 5.4 throuch 5.4.3) l This section is no longer pertinent since the irradiated fuel will have been removed from the site. {
V. Deletion of Administrative Controls (Sections 6.0 through ;
6.13.c) !
A. Responsibility (Sections 6.1 throuch 6.1.2) ,
Technical Specification 6.1.1 requires that the Resident l Manager be responsible for management of the overall ;
plant and for ensuring the safe storage and handling of irradiated fuel. Upon removal of the fuel, however, the l
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LSNRC-2115 :
Attachment I latter responsibility will no longer be required and -l
- there will be no safety-related responsibility associated with management of the overall plant. Thus, there will ,
be no basis for retaining this requirement in a Technical Specification. Similarly, there is no basis for the r associated Technical Specification requirement to delegate the succession of the Resident Manager's i responsibilities in writing during his absence. l Technical Specification 6.2 requires that the Watch ,
Engineer be responsible for the Control Room command l
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function. It also requires that a directive to this effect be issued annually by the Executive Vice President of the Shoreham Project.
i In the absence of the fuel or any other safety-related !
functions, the need for a Technical Specification - f required designation of responsibility for Control Room l' command is no longer warranted, nor is an annual directive to that effect required. l B. Orcanization (Sections 6.2 throuch the sentence following [
Section 6.2.2.e.3) {
Technical Specification 6.2 describes LIPA's responsibility for the station and corporate management organizations. The opening paragraph in Section 6.2.1 ;
clearly emphasizes that this responsibility is oriented j toward the safe storage and handling of irradiated fuel. !
The removal of the fuel from SNPS will thus remove the primary rationale behind the specific requirements of l this section. An additional rationale is indicated for :
section 6.2.1.d with respect to " organizational freedom ;
to ensure.... independence from operating pressures" for !
health physics personnel, quality assurance personnel, and personnel who train the operations staff. While LIPA t will ensure that there is sufficient freedom for such !
personnel to be independent of operating pressures, LIPA ;
believes that the low radiological hazard and absence of 3 safety-related functions in the post-fuel stage warrants !
removal of this requirement from the Technical !
Specifications. j 4 Technical Specification 6.2.2 describes the required station staff organization, and is similarly oriented i toward safe storage and handling of irradiated fuel and !
nuclear safety. In the absence of both fuel and nuclear safety-related functions, the specified requirements are ,
no longer warranted.
i l
l Page 14 of 27
. , )
LSNRC-2115 3 Attachment-1 ,
C. Unit Staff Oualifications (Sections 6.3 through 6.3.1)
The Technical Specification pertaining to Unit Staff '
Qualifications is no longer necessary in light of the i elimination of all irradiated fuel and nuclear safety- .
related functions from the site, and the minimal !
radiological hazard posed by the limited remaining l decommissioning activities. The current Technical :
Specification provides no specific qualification l requirements, but merely references Section 13.2 of the Defueled Safety Analysis Report (DSAR). Appropriate ,
staff qualification requirements will continue to be t defined in Section 13.2 of the DSAR. [
D. Trainina (Sections 6.4 through 6.4.1) i The Technical Specification pertaining to retraining and i replacement training program requirements for the station staff will no longer be necessary in light of the I elimination of all irradiated fuel and nuclear safety- !
related functions from the site, and the minimal j radiological hazard posed by the limited remaining '
decommissioning activities. In addition, the duration of '
decommissioning or other radiological activities at Shoreham following removal of the fuel will be brief, ,
i.e. several months. Therefore, no formal retraining and i replacement training programs would be warranted. ;
r E. Review and Audit (Sections 6.5 throuch 6.5.2.7c) [
(1) Site Review Committee i
At the station operating level, the Site Review Committee !
(SRC) will no longer be warranted as a Technical i Specification requirement after the slightly irradiated !
fuel is removed. The Snoreham site will be classified as i "Non-Safety-Related" as described in Section 2.0 of this document.
As described in Technical Specification Section 6.5.1.1, the main function of the SRC is to advise the Resident ;
Manager on all matters related to nuclear safety. With !
the irradiated fuel shipped off-site, nuclear safety ;
issues relating to the fuel will no longer exist and all
- other nuclear safety-related functions have already been j removed. All procedures and programs and future changes !
thereto, tests and experiments, proposed changes to the i Possession Only License, proposed changes or modifications to unit systems or equipment, reportable events, and station operations, will have no possibility l of affecting nuclear safety. Shoreham will also no longer have a Security Plan, Emergency Plan, or a Fire Protection Plan, as discussed in Section 2.0, and the ,
Technical Specifications, once eliminated, can not be )
violated. Thus, none of the above items will warrant a review by SRC.
Page 15 of 27
, 1
LSNRC-2115 Attachment 1 Proposed changes to the Process Control Program and the Off-Site Dose Calculation Manual, proposed major changes to the radioactive vaste systems, and radioactive releases may still be made in the post-fuel stage at SNPS, however, SRC review thereof will no longer be warranted. Any such changes or releases will be precluded from having any potentially significant off-site radiological consequences due to the low remaining radioactive material inventory, i.e, less than 8 millicuries, at SNPS.
Lastly, proposed changes to the approved Decommissioning Plan, as supplemented, may still be required in the post-fuel stage. However, the Technical Specification requirement for review of such proposed changes by the SRC is redundant to Condition 4 of the SNPS Decommissioning Order. Condition 4 already requires that an on-site review committee approve changes to the SNPS Decommissioning Plan, as supplemented. LIPA will maintain an on-site review committee for this purpose (at a minimum), and will have a written charter specifying its function, composition, use of alternate members, meeting frequency, quorum, responsibilities, and records requirements. The requirements to be specified in the charter will be determined by LIPA in consideration of the ongoing activities at the site and their radiological significance.
Based on the above, there will be no reason to maintain any Technical Specification requirements for a Site Review Committee.
Continued SRC review of Personnel Radiation Records is not warranted since exposures are expected to be minimal (less than 0.10 person-rem total) in the post-fuel stage.
Even at this low exposure level, the Shoreham station will continue to maintain personnel exposures ALARA in accordance with 10CFR20 through appropriate Station Procedures.
(2) Independent Review Panel The Independent Review Panel (IRP) responsibility for providing reviews and audits as required by Technical Specification 6.5.2 will not be necessary after the irradiated fuel is removed. The Shoreham site will be classified as "Non-Safety-Related" as described in Section 2.0 of this document. The IRP's function as described in the Technical Specification is to provide independent reviews in the areas of nuclear safety, radiological controls, and regulatory compliance.
Nuclear , safety will no longer be an issue for review and/or audit at the site since there will no longer be ,
any nuclear safety-related functions. !
l l
i Page 16 of 27 a
LSERC-2115 i Attachment 1 i
5 Based on the above, (i.e. the greatly diminished scope and minimal potential consequences of radiological activities, and the remaining applicable regulatory ,
requirements during the post-fuel stage at SNPS), no !
independent review is warranted -of nuclear safety, !
radiological controls or regulatory compliance. Aside from the audit function of the IRP, and their required l review of SRC meeting minutes and reports, the presently ,
required IRP review items are the same as many of those reviewed by the SRC. However, the basis for elimination of the SRC review of these items also applies to the IRP, ,
i.e. the items either will not exist, will have no !
nuclear safety significance, or will have no potential !
for significant off-site radiological consequences. For the same reasons, IRP review of SRC meeting minutes and reports would also be unnecessary.
With respect to audits performed under the cognizance of the IRP, the activities and programs required to be audited in the Technical Specifications will either no longer exist upon fuel removal, or would not remain active long enough following fuel removal for an audit to j be of any benefit. Further, once again, there would be no nuclear safety significance and greatly diminished radiological significance associated with these ;
activities and programs.
i Based on the above, the requirement to maintain an Independent Review Panel and associated administrative controls is not necessary.
F. Recortable Event Action (Sections 6.6 throuch 6.6.11 ,
With all irradiated fuel off-site and with only a small amount of contaminated / radioactive material on-site, most '
reportable events will no longer be applicable to ;
Shoreham. However, those events that could still occur l would have no nuclear safety-related significance. ;
LIPA's actions, in response to a reportable event, are delineated in two Station Procedures: SP 12X009.03, ,
Report of Abnormal Condition (RAC) and SP 12X009.07, Licensee Event Reportina. The first procedure covers immediate notifications of station management and the .
NRC, as well as initial corrective actions. The second ;
procedure addresses the preparation, review, approval and distribution of Licensee Event Reports submitted pursuant to 10 CFR 50.73 and various other sections of the Code of Federal Regulations. These procedures will remain in effect and will ensure that all reportable events will be .'
reviewed by the proper management personnel and that all required reports are submitted to the NRC.
- Page 17 of 27 i
k LSNRC-2115 I Attachment 1 l I
I G. Procedures and Procrams (Sections 6.7 throuch 6.7.4.b(31) a LIPA will retain and if necessary, prepare written procedures for performance of those decommissioning tasks ;
that still remain, as well as for tasks that involve I potential exposure to radiation. However, most of the ;
remaining procedures of Technical Specification 6.7.1 l will not be required in the absence of any fuel or !
safety-related functions for the following reasons a) The procedures listed in Appendix A of Regulatory l Guide 1.33 Revision 2 are identified in the i Regulatory Guide as applicable to safety-related l activities. Upon fuel removal, there will be no i nuclear safety-related activities at SNPS. i b) Procedures required to implement the requirements l of NUREG-0737 are related to ensuring the ability to monitor and recover from reactor accidents. i Such accidents are no longer applicable to SNPS. !
c) Procedures for fuel handling operations will no longer be applicable. !
~
d) Procedures for surveillance and test activities of safety-related equipment will no longer be required I because only non-safety-related functions will exist. j e) Security Plan implementing procedures will no longer be necessary upon fuel removal because there will be insufficient quantities of special nuclear material to invoke the Security Plan requirements i of 10 CFR 73. ,
i f) Emergency Plan implementing procedures will no !
longer be required because LIPA has been exempted from all Emergency Planning requirements of 10 CFR 50.47 and 10 CFR 50 Appendix E, per NRC letter dated September 30, 1993, subject: Issuance of Exemption from the Emergency Preparedness l Requirements of 10 CFR 50. 54 (q) for the Shoreham i Nuclear Power Station, Unit 1.
g) Fire Protection Program implementing procedures will no longer be required because there will no longer be a nuclear safety-related based fire protection program as described in Section 2.0 of this application.
Procedures for implementation of the Process Control Program, the Off-Site Dose Calculation Manual, and the Quality Assurance Program for effluent monitoring will still be applicable in the post-fuel stage. However, Page 18 of 27
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LSNRC-2115 Attachment 1 retention of the requirement for such implementing procedures in the Technical Specifications is not ,
warranted. LIPA, however, is committing in this I application to retain these programs and associated !
implementing procedures until they are no longer applicable. Given the low potential consequences associated with any of the post-fuel remaining activities at SNPS, deletion of these items from Technical Specifications is justified. Quality Assurance Program implementing procedures for environmental monitoring will no longer be applicable because environmental monitoring ,
itself is being deleted (see discussion of Technical Specification 6.7.4.b below), and would not be retained. l I
Technical Specification 6.7.2 provides requirements for the review and approval of procedures required by l Specification 6.7.1. However, as noted above, the l procedures specified in Specification 6.7.1, with the exception of the Process Control Program implementation, ;
~
the Off-Site Dose Calculation Manual implementation, and the Quality Assurance Program for effluent monitoring, will not be required after all of the fuel is removed. ,
i Additionally, LIPA has already incorporated the administrative requirements of Technical Specification 6.7.2 into appropriate station and departmental procedures. LIPA will maintain these administrative requirements (or others as appropriate) for those procedures necessary to complete the decommissioning of 1 Shoreham as noted above. Changes to the implementing ;
procedures for the Process Control Program, the Of f-Site .
Dose Calculation Manual, and the Quality Assurance Program for effluent monitoring will continue to be.
reviewed by an on-site review committee. In the absence ,
of any nuclear safety significance, changes to all other '
station procedures will be performed as determined to be :
appropriate by LIPA station management. .
Technical Specification 6.7.3 is not needed due to the !
absence of the fuel or any nuclear safety functions. t l LIPA may retain administrative controls in effect to address temporary changes to procedures but the Technical ;
- Specification requirements will no longer be necessary. l Technical Specification 6.7.4.a requires that a Radiological Effluent Controls Program be established, implemented and maintained via the ODCM. However, by the time the irradiated fuel is removed from Shoreham, the only contamination remaining will be associated with the ;
SFSP. The SFSP water will be cleaned by a temporary '
filtration unit and demineralizer located adjacent to the SFSP. The water will be released only after it has been i verified that applicable isotope concentrations are less !
than their Lower Limits of Detection (LLD) as specified Page 19 of 27
y -
-- _b
LSi'RC-3115 Attachment 1 .
in the ODCM. Administrative controls invoking the ODCM '
for draining the SFSP are already specified in NRC. letter dated May 26, 1993, subject:-Approval of Decommissioning Plan change, and will be incorporated into SP 23X708.01, i Temporary Fuel Pool Clean-Uo. The remainder of the 'i decommissioning work can be performed in the SFSP area. ,
LIPA will have radiological controls in place to address l decontamination of these components or to address shipping them off-site for disposal. !
Even in the postulated event- that unanticipated f radiological effluent releases were to occur, LIPA has ;
determined that the amount of radioactivity remaining at !
Shoreham will be so small that none of the Appendix I dose guides would be exceeded, even if all of this i
~
radioactivity was released to the surrounding environment (see attached No Significant Hazards Consideration). g Thus, radiological effluent controls required by the NRC ,
will be satisfied through the implementation of SP 23X708.01, Temocrary Fuel Pool Clean-Up and Technical ,
~
Specification requirements are unnecessary.
Technical Specification 6.7.4.b requires that LIPA establish, implement and maintain a Radiological l; Environmental Monitoring Program (REMP).
The Shoreham environs have been extensively monitored throughout the life of the plant in order to determine the magnitude and effects of radiological effluents from the Shoreham Nuclear Power Station. A REMP program has been in effect during.the preoperational, operational, i and defueled stages of the plant. The preoperational period covered mainly 1983 and 1984. The operational 3 period included the years 1985 through 1987 when SNPS-operated at up to 5%.of rated core thermal power.for short periods. The defueled period began on August 9, ;
1989 when transfer of all of the fuel assemblies to the j Spent Fuel Storage Pool was completed. Since the plant began operating, the conclusions of the REMP program have ,
always been the same. Specifically, with the exception of a few instances where positive identifications were ,
traced to non-Shoreham origin sources, at the end of each !
year it has been concluded that the environmental :
concentrations found during_ the year are consistent with i those found during the previous years. (The previous years includes the preoperational period.) Therefore,-
there have been no discernible dose components in the-Shoreham environs other than those from natural sources.
No radioisotopes have ever been detected in the gaseous effluents from SNPS except naturally occurring .
radioisotopes. Furthermore, there has only been minute activity attributable to SNPS in the liquid effluents of '
the last 3 years. This activity consists of the isotope ,
Fe-55 which was identified in a number of quarterly ,
composite samples. .
F Page 20 of 27
LSNRC-2115 l Attachment 1 J Technical Specification 6.7.4.b requires that LIPA's'REMP program conform to the guidance of 10 CFR 50, Appendix I. ,
However,Section I of Appendix I states, "the guides l presented in this appendix are appropriate only for !
light-water-cooled nuclear power reactors and not for other types of nuclear facilities." LIPA_ is not licensed to operate Shoreham and even if it was, LIPA could not because Shoreham's reactor (except for the bottom bowl) has been dismantled and removed. Even in the event of a -
decommissioning accident during the post-fuel stage, the potential exposure to individuals in an unrestricted area due to Shoreham's liquid effluents, gaseous effluents, or releases of radioactive material in particulate form would be much less than the Appendix I limits on annual doses to either the whole body or any organ.
Therefore, a REMP program is unnecessary when irradiated fuel is off of the site.
H. Reportina Reauirements (Sections 6.8 throuch 6.8.2)
LIPA will continue to comply with the applicable.
reporting requirements of Title 10, Code of Federal' Regulations. However, the annual report of personnel receiving exposures greater than 100 mrems/yr, the Annual Radiological Environmental Operating Report, the Annual Radioactive Effluent Release Report, and Special Reports are not warranted.since they will no longer have useful information to provide to the Commission, as described below.
Report of Personnel Receivina Greater Than 100 mrem /vr Since January 1, 1986, only two people at Shoreham have received greater than 100 mrem in one year. Both of the exposures were received prior to the receipt of the Decommissioning Order. Furthermore, LIPA does not i anticipate any additional personnel exposures greater than 100 mrem in one year. In fact, since the start of decommissioning activities in June 1992 through November +
1993, the highest cumulative dose to a single worker at Shoreham has been less than 50 mrem. Finally, radiation levels at Shoreham are so low that direct-reading dosimeters will not register actual personnel doses. ;
LIPA will continue to comply with the reporting requirements of 10 CFR 20.407,- Personnel Monitoring Reports. These reports provide information to the NRC that is comparable to the Technical Specification requirement.
Page 21 of 27
. _ _m. . __m . .
., u i LSNRC-2115 ,
Attachment 1 i Annual Radiological Environmental Operatina Report r (Section 6.8.1.3) i The Shoreham environs have been confirmed to be free of i any background dose components attributable to Shoreham. l The background environmental radiation levels have either remained fairly constant or decreased in the Shoreham i environs. This conclusion is based on the results of !
monitoring the environment for 10 years. This 10 year i period included the preoperational, operational and l decommissioning stages of the plant. Due to the very l small amount of radioactivity that will be on-site after fuel is removed, less than 8 millicuries, LIPA believes f that the Shoreham environs will remain unaffected by the remaining decommissioning work. Therefore, this report i i will no longer be warranted.
i Annual Radioactive Effluent Release Report (Section 6.8.1.4)
Except for naturally occurring radioisotopes, there have been none detected in gaseous effluents from Shoreham, i even during the period when Shoreham conducted low power testing at up to 5% of rated core thermal power. During !
the last two years there has been only minute radioactivity detected in liquid effluents. The majority _;
(95% as of August 31, 1993) of the solid rad-waste !
associated with decommissioning has already been shipped ,
off-site. Therefore, this report will no longe:c be warranted. }
t Special Reports (Section 6.8.2)
Special Reports were required when certain Limiting ,
Conditions could not be met. These Limiting Conditions !
were applicable during fuel storage at SNPS and therefore will not apply after the irradiated fuel is removed.
Thus, Special Reports will no longer be warranted under the Technical Specifications.
I. Record Retention (Section 6.9 throuch 6.9.3.i)
LIPA will continue to comply with the record retention t requirements of Title 10, Code of Federal Regulations. I All of the record retention requirements of Technical Specification 6.9.2 and 6.9.3 have been incorporated into L Station Procedures or programs. LIPA will maintain the appropriate procedures in effect until license termination in order to ensure the retention of these l' specific records. Thus, this Technical Specification is no longer warranted. l f
?
Page 22 of 27
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LSNRC-2115 Attachment 1 (
i J. Radiation Protection Procram (Section 6.10)
- The Shoreham Radiation Protection Program will be maintained in accordance with the requirements of 10 CFR Part 20. Station Procedures that already exist, such as the Station ALARA Program, Radiation Work Permit, Conduct of Health Physics, and Control of Radioactive Sources, will be adhered to, and will be maintained for personnel ,
radiation protection and all operations involving i personnel radiation exposure as described in Section 2.0.
Based on the fact that this Technical Specification is covered by Station Procedures, retention of this j Technical Specification is no longer warranted. :
K. Hiah Radiation Area (Sections 6.11 throuah 6.11.2)
During the post-fuel stage, high radiation areas may exist from filter media and/or SFSP debris where the j intensity of radiation may be slightly greater than 100 '
mrem /hr. Controls as required by the Technical :
Specification will be maintained in accordance with 10 ;
CFR Part 20 and already established Station Procedures.
Exposures will be maintained ALARA and consistent with j the Radiation Protection Program. Radiation monitoring,- !
barricading, posting, the use of Radiation Work Permits !
(RWPs), radiation surveys, and Health Physics coverage will continue to be maintained until potential radiation i sources have been eliminated from Shoreham.
Based on the extent of the decommissioning effort when irradiated fuel has been removed from Shoreham, the doses associated with possible radiation levels present will be i
)
such that a major portion of the body could not receive 1000 mrems or more in one hour. Therefore, plant areas will not be required to be locked to prevent unauthorized entry.
t Based on the above, retention of these requirements in I the Technical Specifications will no longer be warranted. ;
i L. Process Control Program (PCP) (Section 6.12)
During the post-fuel stage there may be continued need for conducting solid rad-waste packaging in conformance with a Process Control Program, however, the extent of ,
such packaging will be extremely limited. The Technical i specification only directs how changes to the PCP are to be made. It is proposed that these requirements be [
transferred into the PCP itself, and the Technical ;
Specification could therefore be eliminated.
1 I
Page 23 of 27 I k
LSNRC-2115 I Attachment 1 M. Off-Site Dose Calculation Manual (ODCM) (Section 6.13) ,
During the post-fuel stage there will be continued need ,
for maintaining control of .ef fluents to unrestricted l areas in conformance with the off-Site Dose' Calculation !
Manus.1, particularly with respect to the final draining of the Spent Fuel Storage Pool water following completion of irradiated fuel removal. The Technical Specification only directs how changes to the ODCM are to.be made. It i is proposed that these requirements be transferred into the ODCM itself, and the Technical Specification could therefore be eliminated.
VI. Deletion of Environmental Protection Plan (EPP) (Non-Radiological), Appendix B ,
In the Final Environmental Statement - Operating License (FES-OL) dated October 1977, the NRC staff considered the environmental impacts associated with the operation of the Shoreham Nucisar Power Station, Unit 1. Certain environmental issues were identified which required study or license ;
conditions to resolve environmental concerns and to assure adequate protection of the environment. These' issues were incorporated into the Environmental Protection Plan.
Specific aquatic issues raised by the staf f . in the FES-OL ,
were:
(1) The need for discharge related aquatic monitoring programs to confirm that the station's cooling water system with its offshore submerged diffuser-performs as predicted and is protective of indigenous biota of Long Island Sound, from a thermal and chemical discharge standpoint. -
(2) The need for intake-related studies to document levels of
-intake entrainment and impingement, to determine survival of entrained ichthyoplantkton, and measure the effectiveness of the fish return system in protecting ;
impinged fish. l (3) The need for monitoring existing wells on.the Shoreham ;
site and the Shoreham-West site to detect effects of plant operation on both water level and water quality. l Issues (1) and (2) are addressed by the effluent limitations, monitoring requirements and other conditions ' contained in the SPDES permit issued by the New York State Department of Environmental Conservation v.YSDEC). The NRC relies on the NYSDEC for regulation of matters involving water quality and ;
aquatic biota. Furthermore, since the circulating water.
system is no longer in use, issue (2) is also no -longer applicable. NRC requirements with regard to issue (3) have #
Page 24 of 27
. I LSWRC-2115 l Attachment 1 i
not been applicable since the plant was placed into the
- DEFUELED MODE. Therefore, none of these aquatic issues should require monitoring by the NRC. Consequently, LIPA's compliance with the SPDES permit. will ensure that the objectives of the Environmental Protection Plan, for aquatic issues, continue to be met and that there will be no adverse impacts as a result of removal of these conditions. ;
The specific terrestrial issues raised by the staff in the ;
FES-OL are:
(1) The need to protect Wading River Marsh from deposition of sand and other materials transported from the Shoreham
- site.
This issue was carried over from a condition placed on !
the Shoreham construction permit (CPPR-95). It was
- applicable during the construction period when site excavation and building construction could cause the accumulation of sand and other materials. However, the construction stage and the operating stage are over.
Now, the decommissioning stage is nearly complete. All land and ~ marsh areas have been and continue to be stabilized. Furthermore, it is extremely unlikely that :
the Wading River Marsh could be affected by deposition of [
sand and other materials from Shoreham. This is ,
especially true since a paved two-lane road, with 7 foot high chain link fences on each side, separates the Wading River Marsh from the Shoreham site. Therefore, there will be no adverse environmental impacts as a result of removal of this condition.
(2) The need for monitoring and mitigating beach erosion.
This issue was also carried over from a condition placed r on the Shoreham construction permit. It was originally i intended that the Shoreham licensee replace beach material eroded from east of the intake canal jetties with accumulated sand, if any, from the Wading River l
Creek or intake canal. However, the Wading River Creek
- l 1s being dredged only by the Town of Riverhead and they-are using the dredge spoils to nourish only the beach east of the Wading River Creek. Also, the intake canal will not need to be dredged by LIPA after fuel is removed since cooling water requirements have been reduced to a i minimum. Therefore, LIPA will not have any accumulated ,
sand to nourish the beach east of the jetties, should !
erosion require this.
l l There is no foreseeable way that LIPA's possession of Shoreham could affect the 700' beach between the intake ;
canal and the Wading River Creek. In f act, LIPA does not ,
~
even own this property. The beach is only significantly affected by an occasional severe storm which is Page 25 of 27 I
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i a
LSNRC-2115 !
- Attachment 1 i
i accompanied by high tides. However, beach erosion due to storms and high tides occurs in many places on Long ;
Island and not just at Shoreham. !
The presence of the intake canal jetties, which extend out into Long Island Sound 600' from the beach, may have l some effect on beach erosion because the jetties restrict -
the flow of sand caused by the normal tidal currents. l' However, both erosion of the beach and sedimentation of i
the adjacent Wading River Creek have been cbserved to n occur simultaneously, so this effect is not -large.
Furthermore, the jetties are not on LIPA property and will remain in place after termination of LIPA's Part 50 license. LILCO, the NYSDEC and the Town of Brookhaven l will address future beach needs.
Therefore, elimination of this condition will not result !
in any adverse environmental impacts.
3 2
(3) The need for controlled use of herbicides. !
i This condition applies only to vegetation control in transmission line corridors. As in the preceding case, LIPA does not own any land which contains transmission
, lines. The transmission lines are all on property owned -
and maintained by the Long Island Lighting Company and i
,! i LIPA has no control over their use of this property, Regardless of what LIPA does, LILCO is separately l j required by the New York State Department of l l Environmental Conservation and the EPA to use only those !
- chemicals which have been approved by these agencies. i The use of these chemicals is restricted to areas that do i not conflict with any watercourse, wetland area, crops or i
drinking water source. Therefore, there will be no adverse environmental impacts as a result of removal of !
this condition. (
i (4) The need for monitoring the mortality of migratory birds
- resulting from collision with the meteorological tower !
i and plant structures.
This avifauna survey was one portion of the terrestrial ;
monitoring program conducted as part of the larger i j preoperational monitoring program. It was only required
- for the preoperational period. It was never intended that the avifauna survey be continued indefinitely. This survey was discontinued in 1978 after only four avifauna mortalities occurred during the previous two migration r seasons. The NRC was notified of this decision on May 1, 1978. Therefore, there will be no adverse environmental impact as a result of removal of this condition.
9 1
i
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Page 26 of 27 i
- ___ . .=.
LSNRC-2115 Attachment 1 I In conclusion, the terrestrial issues contained.in this plan are either no longer relevant, are not under LIPA's control, are covered by other regulatory agencies, or are no longer required. .
The review and audit requirements under the Administrative Procedures section of this plan will no longer be necessary
- since the plan itself is to be deleted. The records retention requirements of this same section will continue to be met by LIPA since these records may be required by other agencies.
There are no routine reporting requirements associated with the conditions contained in this Environmental Protection Plan. This plan only requires non-routine reports for unusual !
environmental events. However, Shoreham has never experienced ;
any unusual environmental events and the probability of one occurring now is substantially less than one occurring at the time this plan was issued. The plan lists several examples of !'
unusual environmental events. One example is excessive bird impaction events. As previously noted, excessive bird
. impaction has not been observed at Shoreham. Another example .!
. is fish kills. This is no longer a significant concern ;
because the circulating water system is shut down. A final example is unanticipated or emergency discharge of waste water
- or chemical substances. This is not a probable event becausa ;
most of the Shoreham fluid systems are already shutdown and/or ;
layed up, and at the time this plan is deleted, the liquid rad-waste system will not be needed and the use of chemicals ;~
at Shoreham will be at a minimum. Therefore, deletion of this plan will not result in the commission being less informed about the environmental effects of the facility. '
i i
Page 27 of 27 l
LSNRC-3115 Attachment 2 ;
NO SIGNIFICANT HAZARDS CONSIDERATION EVALUATION FOR LICENSE CHANGE APPLICATION NO. 2 Scope of Evaluation:
The purpose of this evaluation is to determine if a significant . hazards consideration is involved !
with the proposed amendment to the SNPS Possession ,
~
Only License (POL) and with the proposed deletion of Appendix A and B (Technical Specifications and Environmental Protection Plan) to the Possession l Only License.
References:
- 1) Defueled Safety Analysis Report (DSAR)
- 2) SNPS Decommissioning Plan (SDP), as supplemented
- 3) Order Approving the Decommissioning Plan and .
Authorizing Decommissioning of Shoreham Nuclear Power Station, June 11, 1992.
- 4) Final Environmental Statement Related to the ,
Operation of Shoreham Nuclear Power Station, ;
NUREG-0285 (FES-OL)
- 5) SNRC-283, May 1, 1978 - Avifauna Mortality Survey
- 6) Emergency Preparedness Exemption dated ;
September 30, 1993 (C.L. Pittiglio to L.M. ;
Hill)
- 7) Title 10, Code of Federal Regulations [
- 8) NUREG-0737, Clarification of TMI Action Plan Requirements
- 9) ANSI N18.1-1971, Standard for Selection and ;
Training of Personnel for Nuclear Power Plants j
- 10) ANSI N18.7-1976, Administrative Controls and i Quality Assurance for the Operational Phase of ,
Nuclear Power Plants. !
- 11) Regulatory Guide 1.33, Rev. 2, Quality ;
Assurance Program Requirements (Operation) !
- 12) State Pollution Discharge Elimination System l Permit #1-4722-01075/00001-0
- 13) Shoreham Construction Permit, No. CPPR-95 ,
- 14) NED Memorandum, LDD-NED-93-552, from S. Moss to D. Filipowicz, dated October 15, 1993
- 15) NRC (J.C. Bradfute) letter to SCE (H.B. Ray) dated October 23, 1992, subject: Issuance of '
Amendment for the San Onofre Nuclear Generating Station, Unit No. 1 (TAC No.
M83123)
INTRODUCTION License Change Application No. 2 is a proposed amendment !
to the Possession Only License which would revise various license conditions and which would delete Appendix A -
Technical Specifications, and Appendix B - Environmental a Protection Plan -(Non-radiological) . This proposed change to-Page 1 of 15 ,
1
)
i l
LSNRC-2115 l
~
Attachment 2 J i
the license would become effective as of the date the licensee provides certification that the irradiated fuel has been permanently removed from the site. There are several reasons for this proposed change.
- 1. With the irradiated fuel removed from the site, the plant will no longer be in the DEFUELED MODE, which is defined i as having all fuel removed from the Reactor Pressure f Vessel and there is fuel in the Spent Fuel Storage Pool or in the new fuel storage vault. Thus, most of the -
Limiting Conditions for Fuel Handling Operation and the ,
Administrative Controls requirements for the Nuclear .;
Organization would no longer be applicable.
- 2. By the time the irradiated fuel is removed, all of the -
l decommissioning work, except that work associated with the Spent Fuel Storage Pool and its associated components, will have been completed.
i
~
- 3. The amount of contaminated / radioactive material on-site at that point will be very low. Personnel radiation !
! exposures and potential doses to the public due to i effluent releases will be sufficiently low indicating that formal Technical Specification requirements l associated with their control are not warranted. !
s
- 4. All systems, structures and components will be 4 reclassified as "non-safety-related." !
- 5. There will not be any " nuclear safety" concerns .
associated with the operation, maintenance and decommissioning of Shoreham. i
- 6. The liquid radwaste system will be decommissioned and an ,
industrial waste processing system will be in use. .
i i
- 7. The Termination Survey will have demonstrated by that !
time that most areas of the site, except those used to {
support fuel storage and off-site shipments have ;
radiation and contamination levels below the criteria for unrestricted use.
I Therefore, this evaluation examines the plant conditions that !
are expected to be present at the time the last fuel assembly l is removed from the site. This evaluation demonstrates that- l the changes to the POL and deletion of the Technical :
Specifications and Environmental Protection Plan (Non-
- Radiological) involve a no significant hazards consideration ,
as defined in 10 CFR 50.92(c). l I
l i
i Page 2 of 15
i LSNRC-2115 l Attachment 2 i i
EVALUATION I. Review of Proposed Changes to the Possession Only License (POL) j Paragraph 1.A is to be revised to delete out of date l references to LILCO (the previous licensee), the joint application for transfer of the POL from LILCO to LIPA, and [
license application supplements. These references are :
associated with the issuance of the current license and do not apply to the is sur.nce of the proposed license. Deletion of-these references has no bearing on any no significant hazards ,
consideration criteria, i.e. such deletion would not: l A) Involve a significant increase in the probability or l consequences of an accident previously evaluated; or !
B) Create the possibility of a new or different kind of ,
accident from any accident previously evaluated; or C) Involve a significant reduction in a margin of safety.
Paragraph 1.B is to be deleted in its entirety because it is in reference to the original construction of the facility, which is no longer of any significance at this stage of the !
f acility's history. Deletion of this reference has no bearing on any applicable accidents or margins of safety.
All subsequent sections of paragraph 1 will be renumbered accordingly. This would be merely for editorial clarity. !
Existing paragraph 1.C is to be revised to delete the words .
"as amended", since the current application will replace the l amended application referenced in paragraph 1. A of the current ;
POL. This would also be merely an editorial clarification.
In existing paragraph 1.D, reference to section 2.D is revised to refer to section 2.C, which is the only paragraph in the newly proposed license which discusses exemptions that are currently in place. This would be again merely an editorial clarification. l 2
Existing paragraph 1.E is to be revised to change the term "opert. ting license" to " Possession Only License". This would ,
be merely an editorial clarification. l The above editorial clarifications have no bearing on any ,
applicable accident analyses or margins of safety.
Paragraph 1.H is to be renumbered, as well as revised to delete a reference to the conditions set forth in the Environmental Protection Plan (EPP), since the proposed ;
license would not have an EPP. The Environmental Protection !
Plan (Non-Radiological), by definition, is unrelated to !
nuclear safety or radiological issues. Therefore, its ;
Page 3 of 15 .
f
__ __ _ _ _ _ _ _ _ , _ _ w y =
- 1 LSNRC-2115 !
Attachment 2 !
i elimination and deletion of references to it cannot influence i any previously evaluated accidents, create new or different !
accidents, or affect any margins of safety. {
i Paragraph 2.A is to be revised to reflect the current status of the Shoreham facility, to eliminate reference to the !
Shoreham Updated Safety Analysis Report (USAR), and to remove !
the link between the Defueled Safety' Analysis Report (DSAR)
basis document in support of the expected operation of Shoreham, and is no longer valid considering the current advanced state of decommissioning of the facility. The j accident analyses provided therein are no longer applicable +
and are more severe than those that are currently applicable ,
as described in the Shoreham Decommissioning Plan, as supplemented. Thus, elimination of the USAR does not increase ;
any accident probabilities or consequences, create new or i different accidents, or affect any margins of safety. ,
Updating the description of the facility status and removal of i DSAR links to the USAR is therefore appropriate, and also has [
no bearing on the no significant hazards consideration criteria. l Paragraph 2.B(2) is to be deleted in its entirety. This paragraph authorized LIPA to possess one core load of original .j
~
reactor fuel. However, LIPA will not possess any reactor fuel l at the time the proposed license will become effective and i LIPA will not be authorized, and has no intent, to receive '
fuel. Thus, elimination of this license condition in fact i reflects a decrease in previously evaluated accident ,
probabilities and consequences, and an increased margin of ;
y safety. This removal of authority inherently does not create
- any new or different accidents. ,
i Paragraph 2.B(3) is being revised by the deletion of LIPA's ,
license to receive, possess and use at any time byproduct, .
source and special nuclear material as fission detectors. l This deletion merely updates the license to reflect .the actual conditions at the plant, since LIPA currently does not possess i any fission detectors and will not obtain any in the future.
- 1 License Condition 2.C(1) through (4) are also to be deleted
- ,
2.C(1) addresses the maximum power level and no longer applies '
to SNPS; 2.C(2) addresses Technical Specifications and.the l EPP. This condition will not apply because both of these r documents are to be deleted (see below). Condition 2.C(3) i
]
addresses placing the fuel back in the reactor pressure t
vessel. Clearly, this condition is totally irrelevant since there will be neither fuel nor a reactor pressure vessel.
Condition 2.C(4) is a condition placed on the license transfer ;
order. It was applicable at the time the order was issued due !
to litigation that challenged LIPA's qualifications to hold f the NPF-82 license. However, this litigation was resolved at the time of the license transfer. LIPA has held the license since February 1992 and there have been no problems with the Page 4 of 15
LSNRC-3115
^
Attachment 2-L qualifications of LIPA, both financially and legally, with ,
regard to holding the license. Furthermore, there are no LIPA
" qualification" issues pending in either the courts or the New York State Legislature or Assembly. Thus, this condition is ,
no longer applicable.
E Clearly, since all conditions in paragraph 2.C will no longer be applicable, they can have no bearing on accident considerations or margins of safety. I A new License Condition 2.C(1) has been inserted. This condition will allow LIPA to implement this proposed license F amendment when LIPA provides certification to the NRC that all 'l special nuclear material as irradiated fuel has been permanently removed from the site. This condition is ,
analogous to the License Condition which the NRC approved for Southern California Edison (Reference 15). In that case,
- SONGS 1 was issued a conditional Possession Only License while it was still operating. The condition placed on their POL was ,
that all special nuclear material as reactor fuel had to be permanently removed from the reactor and stored in the spent fuel pool. The new License Condition 2.C(l) is acceptable for l SNPS because this license amendment is dependent upon removal of all fuel from the site, it will allow the NRC to have ;
i control over the license amendment implementation even though the date of complete fuel removal is not known, and the !
requirement to have the licensee (LIPA) certify to the NRC ,
that all fuel is removed has been used in the past at an '
operatina nuclear power plant. This license condition will ;
not influence accident considerations or margins of' safety.
License Condition 2.D is associated with the fire protection program (FPP). This condition allows LIPA to make changes to (
the FPP without NRC approval provided that it would not j adversely affect the ability to maintain the fuel in the SFSP in a cafe condition in the event of a fire. There will be no l fuel on site when this license becomes effective.
Therefore, there are no possible changes to the FPP which would require ,
NRC approval, and removal of the condition which sets a !
threshold that can not be reached will not adversely affect ;
any applicable accident considerations or margins.of safety. l i
License Condition 2.E applies to the physical security, guard j t
training and qualification, and safeguards contingency plans.
These are all requirements of 10CFR73. However, at the time j the proposed license is to become effective, LIPA will not. ! ~
possess a formula quantity of special nuclear material (SNM).
The only SNM that may still be on-site will be a small .
calibration source in an amount less than a formula quantity. !
I Therefore, 10CFR73 will not apply to LIPA and the three plans specified in license condition 2.E will not be required. In .
the absence of any hazard associated with formula quantities !
of SNM, deletion of this license condition will not influence i accident considerations or margins of safety.
Page 5 of 15
LSNRC-2115 :
Attachment 2 Paragraph-3 of the license is to be revised to state that the license will become effective as of the date the licensee provides certification that the irradiated fuel has been permanently removed from the site. The effective date will have no effect on accident considerations or margins of safety, provided all fuel has been removed from the site as stated.
Based upon the discussion above, the proposed changes to NPF-82 are either editorial, e.g., deletion of "LILCO", or deletion of requirements that do not apply to SNPS because all fuel is of f-site, e.g. , deletion of physical security plan, or are deletions of requirements which were applicable at the time of license transfer but not today, e.g., placing fuel in the reactor vessel, Commission Condition on LIPA's qualifications CLI-92-4, etc.
The proposed changes to the license will not increase the probability of occurrence or the consequences of an accident previously evaluated. As indicated in subsequent sections of this evaluation, the accidents analyzed in the DSAR and in the Shoreham Decommissioning Plan, as supplemented, are fuel-related or involve decommissioning accidents. However, these proposed changes will only be effective after fuel removal, reflect elimination of the fuel and its related hazards, and ;
are not related to decommissioning accidents. The changes in I the license update it to reflect the current status of the .
facility by deleting non-applicable conditions and ,
requirements. Thus, there can be no increase in applicable accident probabilities or consequences.
The proposed changes to the license will not create the possibility for an accident or malfunction of a different type :
than any previously evaluated. As stated before, the proposed changes merely update the license by deleting requirements which no longer apply to LIPA. They will have no adverse ;
effect on the operation of remaining plant systems and ;
components.
The. margin of safety related to fuel hazards is no longer relevant since fuel is not on-site. Appropriate program l changes as reflected in these proposed revisions are merely consistent with this objective, and do not reduce any margins of safety.
II. Deletion of Appendix A - Technical Specifications A) The proposed Technical Specification deletions will not l involve a significant increase in the probability or ,
consequences of an accident previously evaluated. J Page 6 of 15 1
)
i LSNRC-3115
. Attachment 2 As discussed in Attachment 1, the majority of the Technical Specifications pertain to the safe storage and handling of irradiated fuel. Upon removal of the fuel from the site, any postulated accidents involving fuel damage will no longer be applicable. All non-fuel-related Technical Specifications, such as-those relating to radioactive sources, radiological controls, effluent releases, etc., are related to operational considerations and are not associated with the evaluation of accident probabilities or consequences as described in the ;
DSAR or the Decommissioning Plan, as supplemented. In fact, the present Technical Specifications were in place at the time of Decommissioning Plan approval and were not affected by the submittal and approval of the Decommissioning Plan.
With the removal of the fuel and the completion of the vast majority of decommissioning activities at Shoreham, the probability of a fuel damage accident will be zero and the already-low probability of a decommissioning accident is significantly diminished. As noted below, however, the Technical Specifications had no bearing on the evaluated decommissioning accidents, and their deletion will not influence their probabilities.
With respect to the accident consequences, an analysis has l been performed which demonstrates the extremely low hazard l which will exist at the time that the fuel removal is completed. This analysis shows that the radioactive material inventory at Shoreham, other than sealed sources, will be so
- low (less than 8 millicuries) that an instantaneous release ,
involving all such material would not exceed the guidelines of 10 CFR 50 Appendix I for allowable releases from ~ normal operation of a nuclear facility. Thus, it is clear there will ,
be no possibility of having accident consequences which could exceed those previously evaluated, whether the Technical Specifications are deleted or not.
B) The proposed Technical Specification deletions will not ,
create the possibility of an accident of a different type than any evaluated previously.
The proposed change is a deletion of Technical Specification ,
requirements which are no longer applicable or no longer !
warranted when all fuel is off of the site. The proposed :
change does not change the way any system or component is-operated, or only deletes controls for remaining radiological activities which are already required by other regulations or >
license basis documents, which will continue to be addressed in station programs and procedures. The change will remove' from the Technical Specifications the radiological control requirements. These requirements will, however, be maintained ;
in station procedures and programs as long as they are ;
required. Therefore, the deletion of all Technical ,
Specifications will not cause the possibility for a new type t of accident.
i Page 7 of 15 i
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LSNRC-2115 !
. Attachment 2 C) The proposed Technical Specification deletions will not involve a significant reduction in a margin of safety. l Most of the Technical Specification Limitinn Conditions for Fuel Handling Operation and Surveillance Requirements are ;
applicable only during the DEFUELED MODE. This is because !
they were designed to ensure the safe storage and handling of ,
fuel. Therefore, with all fuel removed from the site, these :
Limiting Conditions and Surveillances will not be required, l and no reduction in a margin of safety is involved.
Two Limiting Conditions were required at all times. The firsts :
is for Sealed Source Contamination. This Limiting Condition i is also a requirement of 10CFR31.5. LIPA will continue to :
comply with this latter requirement and will meet the intent !
of the Limiting Condition, and its Basis by implementation of ,
Station Procedures. The second Limiting Condition is on Liquid Holdup Tanks and will not be applicable to Shoreham '
because when the fuel is off-site, there will be significantly less than 10 curies of activity available for storage in an outside temporary tank, even if these tanks were to be used. i The Basis for this Limiting Condition is ensuring that [
10CFR20, Appendix B, Table II, Column 2 concentrations will ,
not be exceeded. Clearly, the margin of safety here will not ,
be reduced. !
There are no bases for the Administrative Controls Section of !
the Technical Specifications. However, since the !
Administrative Controls section is the largest part of the !
Technical Specifications, the effect of their deletion is i discussed below with regard to a significant-reduction in a ;
margin of safety. ;
As stated in 10CFR50. 3 6 (c) (5) , the purpose of the !
Administrative Controls section is to assure operation of the ,
facility in a safe manner. Operation of the Shoreham facility as intended in 10CFR50.36 is no longer relevant. With the fuel off of the site, the only significant activity is the completion of decommissioning (i.e. removal of less than 8 .
millicuries of activity). Adequate margins of safety will be [
provided through station programs and procedures. which ;
implement the applicable regulatory requirements and licensing i commitments, as described below.
- Technical Specification 6'.1 describes the responsibilities of ~I the Resident' Manager and includes " ensuring the safe storage .
and handling of irradiated fuel." Clearly, this will-not .
apply with the fuel removed. Furthermore, the Control Room' ,
command function requirement, which is derived from Reference 8, is only applicable to the operation of a nuclear power plant and not to Shoreham due-to its permanently shutdown, defueled and nearly decommissioned status. Thus, the original safety margin provided by this Technical Specification is no longer applicable.
]
Page 8 of 15
i LSNRC-2115 Attachment 2 Technical Specification 6.2 lists requirements for the nuclear !
organization in the DEFUELED MODE. This organization is i designed to ensure the safe storage and handling of irradiated i fuel. With all irradiated fuel removed, this technical !
specification and its original safety margin is no longer applicable. j Technical Specification 6.3 requires that members of the unit i staff meet the minimum qualifications outlined in Section 13 ;
of the DSAR. The DSAR states that Shoreham qualifications for i key personnel meet the minimum requirements of ANSI N18.1-1971 i (Reference 9) in the defueled status of the plant. (This ANSI _:
standard was also the basis for the original Shoreham ;
positions during the operating stage.) Reference 9 is ;
applicable for personnel in the operating and support ;
organizations appropriate for the safe and efficient operation ,
of a nuclear power plant, i.e., one that contains a nuclear reactor. Clearly, this standard is no longer applicable to Shoreham when the reactor and the irradiated fuel is removed. ;
Future changes to staff qualifications, which differ from the !
requirements of Reference 9, are appropriate given the status !
of Shoreham and the limited amount of work that will be needed to complete decommissioning. Thus, the Technical l Specification and its original margin of safety will no longer 7 be applicable. j Technical Specification 6.4 requires that a retraining and [
replacement training program be maintained as described in l Section 13.2 of the DSAR. This DSAR section only contains two ;
subsections: Training to Support Maintenance and Training to j Support Decommissioning. By the time the irradiated fuel is l removed, the amount of work remaining will be small and so !
will the training needs, if any. It is reasonable to expect ;
that LIPA can complete this decommissioning work with i previously trained and qualified personnel, or obtain contract ' ;
personnel who already have the required skills. Thus, the !
Technical Specification and its original margin of safety will j no longer be applicable.
Technical Specification 6.5 contains requirements for a Site !
Review Committee (SRC) and an Independent Review Panel (IRP). l These two organizations are based on the guidelines of ANSI !
N18.7-1976 (Reference 10) and endorsed by Reg. Guide 1.33 ;
(Reference 11). Both this ANSI standard and Reg. Guide are I applicable to operating plants. Shoreham is long past its .l' operating phase and by the time _ the irradiated fuel is removed will be nearly at the end of its decommissioning phase. !
Furthermore, SRC's function was to advise the Resident Manager !
r on all matters related to nuclear safety. With the fuel I removed and only very limited contamination remaining, nuclear safety is no longer an applicable concern. Thus, the originally intended margin of safety associated with the SRC ;
Technical Specification will no longer be applicable. '
Page 9 of 15
_ . . - ~ , ._ - = _ . _ . _ __
I LSNRC-2115 !
) Attachment 2 ;
I l
The independent review function of the IRP also includes t nuclear safety, .as well as radiological controls and i regulatory compliance. As noted above, nuclear safety review (
l will no longer be pertinent. Activities requiring j radiological controls and regulatory compliance, while still !
required in the post-fuel stage, will be greatly diminished in l both scope and radiological significance. Independent review j of these areas will therefore be of minimal benefit. By the i time the fuel is removed, the only decommissioning activities remaining will be similar to those activities already reviewed ,
by the IRP. The items that require review by the IRP involve !
nuclear safety, unreviewed safety question determination, or ,
review of SRC minutes and reports. None of these items will l be applicable after the fuel is off-site. Furthermore, since r the time needed to complete the decommissioning will be short, !
there will not be sufficient time to receive any benefits from i IRP reviews, or from the audits performed under their !
cognizance. Thus, the originally intended margin of safety [
associated with the IRP Technical Specifications will no ;
longer be applicable. !
l The REPORTABLE EVENT requirements of Technical Specification !
6.6.la are redundant with 10CFR50.73 and will continue to be implemented by Station Procedures. The review requirements of i 6.6.lb are incorporated in already Station-Procedures. There l would be no possibility of a reportable event with nuclear !
~
safety significance in the absence of the irradiated fuel. !
Based on the above, the margin of safety associated with this i Technical Spet:ification will not be reduced. !
. Technical Specification 6.7 requires procedures and programs !
! to be established, implemented and maintained. .
A list of I required procedures and programs along with a discussion of i,
. their applicability follows. Most of these procedures and !
programs will no longer be applicable to Shoreham. :
i 8
f 6.7.la: The applicable procedures recommended in Appendix. A l of Reg. Guide 1.33, Revision 2, February 1978.
Appendix A of this Reg. Guide lists typical safety- }
related activities. With the fuel off the site, !
there will not be any safety-related activities. I 6.7.lb: The applicable procedures required to implement the requirements of NUREG-0737. ,
The NUREG-0737 requirements were for licensees of i operating power reactors and applicants for ;
4 operating licenses. They do not apply to Shoreham.
6.7.le: Fuel handling operations procedures. -
l There will not be any irradiated fuel to handle.
1 Page 10 of 15 l 1
l
LSNRC-2115
. Attachment 2 ;
6.7.1d: Procedures for surveillance and test activities of safety-related equipment.
All remaining safety-related equipment will be ;
reclassified as non-safety-related. Accordingly, i no safety-related implementing procedures will be needed. ,
6.7.le: Security Plan implementation procedures.
A Security Plan and implementing procedures- will ;
not be required since 10CFR73 will not apply to :
LIPA after the irradiated fuel is removed. l 6.7.lf: Emergency Plan implementation procedures.
LIPA has received an exemption which eliminates the ,
need for , an Emergency Plan (Reference 6) and, !
hence, the associated implementing procedures will not be required. :
6.7.lg: Fire Protection Program implementation procedures. ;
LIPA has a license condition which allows it to make changes to the Fire Protection Program which ;
do not adversely affect the ability to safely ;
maintain the fuel in the Spent Fuel Pool in the event of a fire. With the irradiated fuel removed, LIPA could make changes to this program, including >
its deletion, without NRC approval. Thus, the Fire Protection Plan no longer _ warrants an j administrative control on associated implementation ;
procedures. -
6.7.1h: Process Control Program implementation' procedures. ,
Process Control Program requirements' exist' in i Station Procedures, and will be maintained for the '
duration of radioactive waste processing.
Technical Specification administrative controls to ,
require having such; procedures are- therefore redundant. ,
6.7.li: Off-Site Dose Calculation Manual implementation ,
procedures. l l
Most ODCM requirements will no longer be relevant.
once the fuel is removed. By that time, there will !
be insufficient radioactivity on-site to result in' ;
an off-site dose comparable to the_10CFR50 Appendix I limits, even in the event all .of this radioactivity was released' (Reference 14). i Although implementing procedures will be maintained,- there will be no basis iforf an {
associated Technical Specification requirement. -]
l Page 11 of 15 j I
H
LSHRC-2115
. Attachmant 2 6.7.1j: Quality Assurance Program implementing procedures for effluent and environmental monitoring.
Because of the low level of radioactivity remaining -
on-site, environmental monitoring will not be i necessary, and, consequently, neither will the associated Quality Assurance Program requirements.
L7.PA has committed to retaining written Quality ;
Assurance. Program implementing procedures for effluent monitoring.
Based on the fact that the requirements of Technical Specification 6.7.1 are either no longer applicable or their intent is captured in station programs and procedures, deletion of this Technical Specification will not reduce the :
associated margins of safety.
Technical Specifications 6.7.2 and 6.7.3, addressing review of i the above procedures and temporary changes thereto, ;
respectively, will no longer be applicable for those fuel and nuclear safety-related functions which will be eliminated.
Thus, there can be no reduction of the Technical Specification margins of safety. For the balance of the specified procedures that are to be retained as noted above, the necessary administrative controls for review and temporary changes are also contained in station programs and procedures.
Thus, the Technical Specification margin of safety for.the remaining applicable procedures will not be reduced.
Technical Specification 6.7.4 requires a Radiological Effluent .,
Controls Program to be implemented via an Off-Site Dose i Calculation Manual (ODCM), and also a Radiological ,
Environmental Monitoring Program (REMP). An ODCM will still be required during the post-fuel stage to control the final release of water from the Spent Fuel Storage Pool, however, t the ODCM is a stand-alone document which already contains the Technical Specification requirements and is implemented through Station Procedures. Thus, elimination of the-Technical Specification requirement would not reduce the ,
associated margins of safety. The REMP, however, is not required in the post-fuel stage at Shoreham because of the low radioactive material inventory remaining upon fuel removal and' the historical evidence that Shoreham activities, including decommissioning, have not resulted in any discernible dose components in the surrounding environs. Further, even if all radioactive material remaining on-site after fuel removal were >
to be instantaneously released, off-site doses.would be less than the REMP's basis criterion, i.e., 10 CFR 50 Appendix I limits on whole body and organ doses.: Thus, elimination of ,
the REMP and the associated Technical Specification would not- 'l reduce the original margins of safety. ;
i l
Page 12 of 15 I
LSNRc-2115 !
o' Attachment 2 ;
Technical Specification 6.8 provides the controls for various reporting requirements. LIPA will comply with those reports '
required by Title 10, Code of Federal Regulations. However, the annual man-rem report required by specification 6.8.1.2 is no longer of any value since radiation levels are so low that direct-reading dosimeters will not register actual personnel doses. Consequently, exposures tabulated by work and job function are not meaningful. The Annual Radiological Environmental Operating Report will not be necessary since environmental monitoring (i.e., REMP) will not be performed.
The Annual Radioactive Effluent Release Report will only be :
required one time following removal of the fuel. Thus, a l Technical Specification requiring it annually will no longer ,
be warranted. Finally, special reports will no longer be needed because the Limiting Conditions that required these i reports are no longer applicable. Elimination of the reporting Technical Specifications will thus not reduce any associated margins of safety.
6 LIPA will comply with the record retention requirements of Title 10, Code of Federal Regulations as well as those requirements presently indicated in Technical Specification 6.9, by implementation of Station Procedures. Thus, elimination of the Technical Specification will not reduce any margins of safety since the record retention itself will not ;
be changed.
i Technical Specification 6.10, Radiation Protection Program, i will not be necessary. LIPA will maintain a radiation (
protection program and appropriate procedures to comply with i 10 CFR Part 20. However, this program will be necessary only for a limited amount of work and for a limited time. The only l work involving radiation exposure following fuel removal will ,
be the SFSP decommissioning. Following this, the only sources of radiation on site will be calibration sources for radiation i detectors and these will be disposed of when no longer needed.
Thus, elimination of the Technical Specification will not >
reduce any margins of safety since the program requirements will be maintained.
The requirements on the control of high radiation areas .
provided by Technical Specification 6.11 will not be needed after fuel removal. In the remote chance that a high t radiation area does exist, LIPA's radiation protection: ]
procedures,-which comply with 10 CFR Part 20, provide the i necessary controls to prevent excessive exposures, consistent .l with the Technical Specification requirements. Thus, elimination of the Technical Specification will not reduce any margins of safety.
Technical Specifications 6.12 and 6.13 provide administrative requirements for control of changes to the Process Control Program and the Off-Site Dose Calculation Manual, respectively. However, these change control requirements will be transferred into the stand-alone program documents. Thus, elimination of the Technical Specification will not reduce any margins of safety. ,
Page 13 of 15 l
LSNRC-2115
. Attachment 2 III. Deletion of Appendix B - Environmental Protection Plan (EPP)
A) The probability of occurrence or the consequences of an i accident previously evaluated will not be significantly increased.
i The accidents analyzed in the DSAR and in the Shoreham Decommissioning Plan, as supplemented, are radiological accidents. None of these accidents are affected by deletion of the EPP because the issues covered by the EPP are related i to monitoring or protecting the Shoreham environs from non-radiological impacts.
B) The possibility for an accident of a different type than ;
any evaluated previously will not be created.
- The EPP is only concerned with monitoring and protecting the Shoreham environs from non-radiological impacts. Nothing in the EPP affects the operation of the Shoreham plant, nor of the plant systems and components in any way which is related i to nuclear safety or radiological concerns.
C) Margins of safety will not be significantly reduced.
Margins of safety as referred to in 10 CFR 50.92 are related f to nuclear safety and radiological concerns. The EPP is for !
non-radiological issues in the vicinity of the Shoreham ,
environs. Thus, the EPP requirements are unrelated to any 10 ;
CFR 50.92 margins of safety. [
IV. Environmental Impact Assessment of Proposed Deletion of EPP EPP Section 5.3, Changes in Shoreham Environmental Protection Plan, requires that an assessment of the environmental impact of the proposed change be included in the request for the change. The following sections provide this assessment for the two types of issues addressed in the EPP, i.e. aquatic and .
terrestrial issues.
The EPP lists three aquatic issues which were identified in !
the FES-OL that needed further study or license conditions to ;
resolve. The first aquatic issue was for a discharge related ,
aquatic monitoring program to confirm that the. cooling water i system performed as predicted and is protective of indigenous ;
biota of Long Island Sound, from a thermal and chemical !
discharge standpoint. The second aquatic issue was for studies to document levels of intake entrainment and ;
impingement, determine survival of ichthyoplantkton, and measure effectiveness of the fish return system in protecting i impinged fish. However,' the Shoreham plant cannot operate at :
anywhere close to.the originally intended power level, so i thermal discharge impacts are negligible. Furthermore, the l circulating water system is layed up and cooling water flow is ,
greatly reduced, so the survival of entrained ichthyoplantkton {
Page 14 of 15 i
i
LSMRc-2115
- Attachment 2 and fish is of very limited applicability. Regardless, these two aquatic issues are addressed by the SPDES permit issued by NYSDEC. The NRC relies on NYSDEC for regulation of matters ,
involving water quality and aquatic biota. A third aquatic issue was identified but it was not applicable in the DEFUELED MODE and will remain so after the fuel is removed. Therefore, it is concluded that there will be no adverse environmental impacts associated with aquatic issues since the few applicable issues are adequately covered by the SPDES permit. .
The EPP . identifies four terrestrial issues. The first
- terrestrial issue was the need to protect Wading River Marsh from deposition of sand and other materials from the Shoreham site. This was a condition carried over from the Shoreham i Construction Permit. It no longer applies because construction is complete, the site has been developed, and there is a paved 2-lane road with chain link fences on either ,
side, which separates the marsh from the Shoreham site. The second terrestrial issue was the need to monitor and mitigate ;
beach erosion. This issue is only partially . applicable. ,
originally, the Shoreham licensee was required to replenish the beach east of the jetties with any accumulated sand. ,
However, the Town of Riverhead now dredges the beach east of Wading River Creek. This issue is therefore now only applicable to the 700' beach between the canal and the creek.
Furthermore, since the Town of Riverhead dredges the Wading River Creek, and since minimal cooling water requirements have eliminated the need to dredge the intake canal, LIPA does not have any sand to replenish the beach, should erosion occur.
The third terrestrial issue was on the control of herbicides I used in the Shoreham transmission line corridors. This issue is completely covered by NYSDEC's regulations on the use of :
herbicides. LILCO, which owns the land, is only permitted to ,
use herbicides approved by NYSDEC. The fourth terrestrial issue concerned monitoring the mortality of migratory birds resulting from collision with the meteorological tower and plant structures. This survey was part of a preoperational monitoring program. This survey was discontinued in 1978 after only four dead birds were found during two migration seasons. The NRC was notified of this in Reference 5. ;
Therefore, based on the above discussion, there will be'no .i adverse environmental impacts associated with terrestrial I issues as a result of deletion of the EPP.
I CONCLUSION l Based on the ' foregoing, revisions to the Shoreham POL and !
deletion of Appendices A and B of the Shoreham POL as proposed I in LSNRC-2115 will not involve a significant hazards consideration. Additionally, there will not be any adverse environmental impacts associated with deletion of Appendix B.
Page 15 of 15
@ua 1 l
- n UNITED STATES LSNRC-2115 4 NUCLEAR REGULATORY COT,1 MISSION Attachment 3 3" -@()> $
' 3s i
WASHINGTON D.C. 20655
- o i
....+
LONG ISLAND POWER AUTHORITY SHOREHAM NUCLEAR POWER STATION. UNIT 1 AMENDMENT TO TRANSFER POSSESSION ONLY LICENSE DOCKET NO. 50-322 P ll Amendment No. O License No. NPF-82
- 1. The U.S. Nuclear Regulatory Commission (the Commission or the NRC) has found that: 4 4 -$>jc393-Ch Ms cuna.nderhoases-acn OnN Liu%. -
A. The fe4*t M TcationXfiled by Long I: land Lighting Comp;ny (LILCO) and Long Island Power Authority (LIPA or the licensee), of Junc 23, 1000, :nd :: ;upplemented on Junc 13, June 27, October 21, 2nd y December 5, 100: :nd March 27, and f,pril 10,1992,fciimplieswiThthe standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; S. Cor. tructier of the Sherchr Nuclear Pc;cr Station, Urit ! (the faci'ity), has beer completed " ccnfermity with Construction Pem4t-
'b. CPoo-95 and the :pplication, :: = ended, the pavi:icn: cf the f.ct, 2nd the regulation: Of the Ce mi::icr. !
~s. C . The facility will be maintained in conformity with the application, t
- ended, the provisions of the Act, and the rules and regulations of the Commission; O, D. There is reasonable assurance (i) that the activities authorized by this license can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I (except as exempted from compliance in Section 2 p below);
Qbssesui n OA Ls c_ ens rQ .c D -b The licensee is techKicaTTyjyualTri~e~d to engage in the activities authorized by thisfcper: ting licen n in accordance with the Commission's regulations set forth-in 10 CFR Chapter I; E -f- The licensee has satisfied the applicable provisions of 10 CFR t Part 140, " Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; E The issuance of this license will not be inimical to the common defense and security or to the health and safety of the public;
?
Page 1 of 4
. LSNRC-2115 ,
Attachment 3 G%~4b i
After weighing the environmental, economic, technical and other (6 -A benefits of the facility against environmental and o er costs and considering available alternatives, the issuance oflPossession Only License No. NPF-82J:cbj::t to the c+ndition; fee-protection of-the-env4ren unt set fc"rth in th Environmental Protection Plan attached 2: ^ppendix B, is in accordance with 10 CFR Part Sl of the Commission's regulations and all applicable requirements have been satisfied: and .
R -h The receipt, possession, and use of source, byproduct, and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30, 40, and 70.
- 2. Accordingly, Possession Only License No. NPF-82 is hereby amended in its entirety to read as follows:
A. The license applies to the Shoreham Nuclear Power Station, t o n7t 1, a] boiling water nuclear reactor and associated
[U N equipmenE owned by the licensee. The facility is located in Tuffolk County, New York, and is described in the Shoreham undego g Defueled Safety Analysis Report (DSAR), which includ :, by dwe.ss en, n< reference, the :ppropri:t++eetion: Of the "pd ted-Gafett -
C _ _
- n:1yri: Report (USM), :: supplemented and amended, and the Shoreham Environmental Report, as supplemented and amended.
B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses the Long Island Power Authority (LIPA or the licensee): ,
(1) Pursuant to Section 103 of the Act and 10 CFR Part 50, to possess, use, but not operate the facility at the designated location in Suffolk County, New York, in accordance with the .
procedures and limitations set forth in this license; l (2) Pur:uant to the Act nd 10 CFR Part 70, te p0::c:: :t :ny time mecial nuclear mater 4+1 :: re:cter fuel, " accordance eith .
tne '4-it: tion; for ster:ge and : cunt: required for tAe--
criginal rc::ter cor< 10:d, :: described in the-Gefa4ed-Safett-
-Ane4y i Report, a upplem:nted and :::nded t-
) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to
- g. receive, possess, and use at any time any byproduct, source, !
and special nuclear material as sealed neutron sources for radiation monitoring equipment calibration :nd :: #f::f en -
detector: in amounts as required; i
f Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to '
(f) receive, possess, and use in amcunts as required any byproduct, 3 source, or special nuclear material without restriction to 4 chemical or physical form, for sample analysis or instrument l calibration or associated with radioactive apparatus or <
components; and l I
Page 2 of 4 1
~
LSNRC-2115 Attachment 3 E
() Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear i materials as may have previously been produced by the operation of the facility.
C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations (except for those exemptions i from specific portions of the regulations, previously granted by .
the Commission, and are still applicable), and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below:
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e Amendment Ja' Page 3 of 4
INSERT TO SECTION 2.C OF ATTACHMENT 3 (1) Licensee Certification of Post-Fuel Condition Regardless of the issue and approval date of this license Amendment No. 11, the effective date of this amendment shall be the date the licensee provides certification that all '
special nuclear material as irradiated fuel has been permanently removed from the site. ,
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- Attachment 3
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- e_n_a_ t_ E. n_ r. +_ ht_ h. o_ r. n_ 4. n b, F. The licensee shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.
E. ". This license shall expire at minight on April 13, 2013.
- 3. This license amendment will become effective *ithir, thirty '30' calcr.dar den frc d;te of us"ance. a.s 4 #a d#c, ita. U cesu- prom d.ts c.o.rRG c.dio/\ %c4.ihe trMcdeci fue) has besu, ermee.n+iy4 FOR THE NUCLEAR REGULATORY COMMI SION c.ernose.d from 4hL CihL gf -
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Page 4 of 4