ML20125D499
| ML20125D499 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/14/1992 |
| From: | Leslie Hill LONG ISLAND POWER AUTHORITY |
| To: | |
| Shared Package | |
| ML20125D489 | List: |
| References | |
| NUDOCS 9212150229 | |
| Download: ML20125D499 (11) | |
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LONG ISLAND POWER AUTHORITY NRC License NPF-82 Docket No. 50-322 License Chnnge Application #1 l
This License Change Appl ication requests modification to NRC License NPF-82 for the Shoreham Nuciear Power Station by 1.
Deleting the A.C.
!iources and onsite power distribution systems requirements and I
l 2.
Changing the frequency of radiological effluent release reporting requirements.
The request and supporting documentation are contained in Attachment 1.
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Long Island Power Authority l
}.l.I M[b By:
L.J4. Hill, Resident Manager Subscribed rnd sworn to before me this _/ L/ day of O cem e r',
l 1992.
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LSNRC-2013 I
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e LSNRC-2013 Page 1 of 9 To License Change Application #1 NRC License NPF-82 1.0 Descript_ioJ1_ of Change This proposed amendment deletes the technical specification requirements currently imposed on the SNPS Electrical Power Systems (3/4.4 and corresponding section B3/4.4).
Specifically, LIPA requests the deletion of two sections: (1) 3/4.4.1 "A.C. Sources" and (2) 3/4.4.2 "Onsite Power Distribution Systems."
Additionally, Section 6.8.1.4 of the technical specifications currently requires a radioactive offluent release report to be issued semiannually; however, on October 1, 1992 a change to 10CFR50.36a, " Technical specifications on effluents from nuclear power reactors,"
became effective (see 57 Fed. Rec. 19353 - 39358) and reduced the reporting requirements from semiaimually to annually.
Thus, LIPA requests a change wbich w
. reduce the reporting i
frequency to achieve consistency witn the Commission's regulations.
2.0 Beason_for Change I.
Deletion 3f Electrical Power Systems s
There are several reasons for this request and each is discussed below.
A.
The A.C.
Sources And Onsite Powen_pistributign Systema __llo I&Dner lipve A EDJ_ely-Related FunctionJA_Sboreham The Shoreham Defueled Safety Analysis Report (DSAR) and the Shoreham Decommissioning Plan (DP) were reviewed and rpproved by the NRC Staft.
The DP contains the bases for che June 11, 1992 Decommissioning Order and the DSAR contains the bases for NPF-82 license amendment number 7 which (1) transformed the SNPS operating license to r possession only license and (2) replaced the SNPS operating technical spec..fications with Defueled technical specifications The SNPE DP was incorporated into the DSAR in August L992 (rev. 4) and resulted in no change to the SMPS defueled technical specifications.
Chapter 8 of the DSAR describes the details of the plant onsite power distribution system and A.C.
sources.
As reported in Chapter 8, "The defueled condition of the
LSNRC-2013 Page 2 of 9 plant does not require the operation of any Class 1E power system."
This is because LILCO, LIPA and the NRC Staff have agreco that no active systems, including the electric power sources and distribution systems, are needed in any defueled accident analyses to assure acceptable radiological results.
The accidents contained in DP Section 3.4 have either been previously evaluated in the DSAR or are subsets of accidents previously evaluated in approved Shoreham licensing basis documents (see Section 11.0 of the NRC Staff Satety Evaluation Related to the Order Approving the Decommissioning Plan and Authorizing Facility Decommissioning dated June 11, 1992).
Thus, operation of any Class 1E power system is equally unnecessary during decommissioning.
Section 3.0 of the " Safety Evaluation By The Cffice Of Nuclear Reactor Regulation Related To Amendment No. 7 To Facility Operating License No. NPF-82" contains the NRC Staff's evaluation of the acceptability of twenty-two requested changes technically supported by the DSAR.
In Section 3.0 the NRC Staff states "...the DSAR indicates that active systems for spent fuel pool water make-up are not required and that passive cooling in the fuel pool is sufficient to maintain fuel cladding integrity.
The staff reviewed the fuel condition and operating experience, and concurred with the licensee's analysis on decay heat.
Further, th( Staff's review and analysis concurred with the licensee on the need for active spent fuel pool cooling systems."
Three of the twenty-two changes described in Section 3.0 (Nos.
3, 9 and 20) involve the Staff's findings associated with the removal of emergency diesel generator (EDG) requirements.
In item number 3 on page 5, the eva)uation concludes "with regard to the EDGs recairements, the Staff has found that no active systems, including the EDGs, were needed in accident analysis to assure acceptable results, and, therefore, the deletion of the reference to specific requirements in the attachment is acceptable."
On page 7 of the safety evaluation, the Staff discusses an agreement reached between LILCO and the NRC which resulted in the specification for one EDG when handling irradiated fuel in the Reactor Building.
The discussion states that "...the licensee [LILCO) and Staff concluded that the specification for one EDG operable during irradiated fuel movement provides additional flexibility
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LSNRC-2013 Page 3 of 9-in case of a potential loss of electrical power event."'
LIPA agrees with'this conclusion; however, it doesn't consider the benefits of additional flexibility to outweigh the costs, and believes the additional flexibility to be unnecessary to assure public health and safety.
Furthermore, the NRC has acknowledged the nonsafety-related classification of the EDGs by footnoting the technical specifications to permit the use of commercial grade parts.
B.
The Safety Sionificance of The A.C.
Sources And Onsite Power Distribution Systems Is_Neolicible The. availability or operability of A.C.
sources'and onsite power distribution systems has a negligible contribution.in assuring acceptable accident analysis consequences (i.e. radiological dose consequences).
-In item number 9 of the safety evaluation described above, the NRC Staff concludes that, for this reason, the EDGs are not needed.
LIPA submits its determination for NRC review that not only are the EDGs unnecessary, but all A.C.
sources and onsite power distribution systems _are unnecessary for safety because there are no-active systems, including the EDGs, needed to' assure acceptable results of the accidents analyzed for the defueled condition of the plant.
- Thus, a_ loss of electric power at Shoreham will result in no challenges to or automatic actuation of any safety-related systems or components.
C.
This Chanac Is Intended To Achieve Consistency With Defueled Technical Specifications Of Another Plant Similarly Situated 1
(i.e. 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br />)-is A significant amount of time avaf'.able to take corrective action to restore offsite power in the unlikely' event of a Loss of Offsite Power (LOOP), at Rancho Seco.
LIPA believes 1that-the limited:
-demand for spent fuel pool cooling coupled with the amount of time available to restore electric power-is the-principal; reason that the Rancho Seco DTSido not contain requirements for electric power sources or distribution systems.
For Shoreham, an unlimited amount'of time is available-since active fuel pool cooling is unnecessary and no active systems are needed in accident analyses to assure acceptable results.
In= fact, LILCO_ layed up the spent fuel-pool cooling system in 1989.
Therefore, the granting of tnis request will achieve consistency with
-the Rancho Seco DTS which were issued subsequent-to
LSNRC-2013 Page 4 of 9 Shoreham's DTS.
Many important NRC decommissioning policy issues oi first impression were decided on the Shoreham, Rancho S2co and Ft. St. Vrain dockets because these three premat'arely shutdown plants were the first to undergo decomnissioning in accordance with the Commission's final decormissioning rules published in June 1988 and effective in July 1988.
LIPA requests that the recent staff experience with the Rancho Seco DTS be considered and applied to this request because the technical basis is similar.
In fact, the basis for LIPA'p request is much stronger than Rancho Seco's because LIPA would have no concerns about the spent fuel pool temperature in the event of a loss of A.C.
power.
D.
LILCO's Oriaiqal Pronosal For Defueled Technical Specifications Lasked EDGs On January 5, 1990 LILCO submitted a request which, among other things, contained its first draft of defueled technical specifications.
In its request, LILCO deliberately excluded emergency diesel generators, DC sources and DC distribution systems for the reasons contained in the DSAR and stated above.
On June 27, 1990 the NRC Staff sent LILCO their comments on LILCO's proposed DTS.
In the A.C.
Sources specification, the NRC indicated that a diesel generator should be operable when handling irradiated fuel in the reactor building and asked the licensee to propose an appropriate surveillance requirement.
On August 2, 1990 the licensee and NRC Staff met to discuss and agree upon the contents of the Shoreham DTS.
The licensee agreed to keep one nonsafety-related diesel generator operable when handling irradiated fuel in the reactor building.
This agreement provides the licensee with some additional flexibility; however, it subsequently provided an NRC inspector with an opportunity to suggest that since the diesel generator is in the technical specifications, it must be important to protect the fuel and consequently, certain FHAR surveillance requirements should be applied to the EDGs and associated equipment.
Currently, these FHAR surveillance requirements are only applied to safety-related areas.
The NRC suggestion is in the form of an unresolved item (50-322/92-04-02) and the granting of this request will resolve this issue.
9 LSNRC-2013 Page 5 of 9 II.
Radioactive Effluent Release Report - Frequency Change Section 6.8.1.4 of the SNPS technical specifications requires LIPA to issue a radioactive effluent release report semiannually.-
This requirement has been in effect since Shoreham was first licensed and may be found in 10CFR50.36a(2).
On October 1, 1992, however, a change to 10CFRSO.36a became effective and the semiannual reporting requirement was changed to an annual reporting requirement.
Thus, LIPA requests this change to achieve consistency between the SNPS technical specifications and the Commissions' regulations.
3.0 Analysis of No Sionificant Hazards consideration Pursuant to 10CFR50. 91(a) (1), LIPA has performed a "no significant hazards consideration" analysis, assessing the proposed changes to the SNPS defueled technical specifications using the standards set forth in 10CFRSO.92(c).
Based on this analysis, LIPA has determined that the proposed changes de not involve a s'ignificant hazards consideration.
Section 50.92 provides that.the NRC may make a determination "that a proposed amendment to an operating license... involves no significant hazards consideration" if "oneration" of the facility in accordance with the proposed amendment would not:
(1) involve a significant-increase in the probability or consequences of an accident previously.tvaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated;.or (3) involve a significant reduction in a margin of
. safety.
(emphasis added).
Since NRC license NPF-82 constitutes, in sum, a possession only_ license for Shoreham, as a' threshold matter-it-is highly unlikely that amendments-to the technical specifications could involve a "significant hazards consideration."
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LSilRC-2013 Page 6 of 9 I.
D_eletion of A.C.
Sources And Onsite Power Distribution Systems The Proposed Tech. Spec. Change Does Not Involve A Bignificant Increase In The Probability Or Qonsequences Of An Accident PreviouslY Evaluated The three accident scenarios described in the DSAR and those in Section 3.4 of the DP are discussed below.
A.
The simultaneous rupture of the liquid radwaste tanks is analyzed in USAR/DSAR Section 11.2.3.4.
There isn't any cause and effect relationship between the loss of A.C.
power and this nonmechasnistic accident scenario.
Therefore, it is reasonable to conclude that the proposed change will have no effect on this accident scenario.
Regardless of the effect, the doses from this accident (1.8E-05 mrom gamma dose to the whole body, 2.8E-06 mrom beta dose to the skin and 1.3E-03 mrem maximum dose to an organ) are very small fractions of regulatory guidelines and, thus, can be considered insignificant.
B.
The loss of A.C.
power accident is discussed in DSAR Section 15.1.19.
This is the sole " Core Coolant Temperature Increase" transient which is still applicable to spent fuel storage.
This section' states that active fuel pool cooling is not required.
It also states that the evaporation rate is so slow that ample time exists to restore A.C.
power to normal pool makeup sources so that pool level can be quickly restored.
Furthermore, the loss of A.C.
power will not in itself result in any release of radioactivity since fuel movements would not be conducted. -Therefore, any increase in the probability of a loss of A.C.
power accident, due to the proposed technical specification revision, is.irrele vant because this DSAR section shows that there are no adverse radiological consequences from this accident.
- Finally, this DSAR section states "Should the loss of A.C. power occur as part of any other event which causes damage to the fuel in the pool, while the release in this case would not be monitored, the offsite dose consequences would be insignificant."
It should be emphasized that the real accident of concern here is loss of spent fuel pool cooling and not loss of A.C. power.
Any increase in the probability of a loss of A.C.
power will not result in an increase in the probability of overheating the fuel.
This fact is
5 LSNRC-2013 Page 7 of 9 documented in Section 9.1.3 of the DSAR wnich states that because of the negligible amount of decay heat the Fuel Pool Cooling subsystem is not required.
C.
The fuel handling accident is analyzed in DSAR Section 15.1.36.
This accident is assumed to occur as a consequence of a failure of the fuel assembly lifting mechanism.
The Shoreham fuel handling mechanisms are pneumatically operated, fail safe, and do not depend upon A.C.
power to hold the fuel bundle.
Thus, a loss of A.C.
power won't increase the probability of this accident.
Also, a cask drop accident is not considered credible due to the single failure-proof polar crane design.
(DSAR b
Section 15.1.28)
D.
If a loss of A.C. power occurred while decommissioning work was in progress, then this work would be forced to stop.
On the other hand, it one of the ten accidents analyzed in Section 3.4.1 of the DP occurred first and then was followed by a loss of A.C. power,.the consequences of the accident would not be increased.
In five of these accidents the RBSVS exhausts Reactor Building air through HEPA filters.
However, the analyses demonstrate that the radiological consequences of these accidents are acceptably small fractions of the 10 CFR Part 100 Limits with or without HEPA filtration.
- Thus, the RBSVS is classified in the DSAR as nonsafety-related.
If A.C.
power is lost then there would not be any ventilation exhaust flow from the Reacator Building and the airborne radionuclides would most likely remain inside the building.
In the two accidents that involve fires, the fires are assumed to burn for two hours.
It is reasonable to assume that the Fire Brigade could still extinguish these fires within two hours even with a loss of A.C.
power.
(The-fire main would be supplied by the diesel fire pump and portable fire extinguishers would be available.)
The consequences of the three remaining accidents would also not be increased upon a loss of A.C.
power because A.C.
powered components or systems are not required to mitigate the consequences of these accidents.
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LSNRC-2013 Page 8 of 9 The Proposed Change Will Not Create The Possibility Of A New or Different Kind Of Accident Prom Any Accident Previously Evaluated i
The proposed revision to the technical specifications could only affect the plant by causing a minor increase in the possibility that, 1) a loss of one offsite distribution system could lead to a loss of offsite power, and, 2) a loss of offsite power could lead to a loss of all A.C. power.
The worst of these two possibilities is the latter and this accident is already discussed in Section 15.1.19 of the DSAR.
Tha Proposed Chango Does Not Involve A Sianificant Reduction In A Margin Of Safety The bases for technical specifications 3/4.4.1 and 3/4.4.2 state that "The operability of the specified A.C. power sources and associated distribution systems during fuel storage and handling ensures that sufficient instrumentation and control capability is available for monitoring and maintaining the unit status."
Monitoring and maintaining the unit status is important for industrial safety and habitability reasons.
However, the only thing that must be monitored for nuclear safety reasons is the safe storage and handling of fuel in the spent fuel pool.
Because the decay heat is so low, monitoring the pool temperature is not important.
The fuel pool level is important but as stated in the Loss of A.C.
Power discussion, Section 15.1.19 of the DSAR, the evaporation rate is so slow that ample time exists to restore A.C.
power to normal pool makeup sources so that pool level can be quickly restored.
Additionally, the pool level can casily be monitored by an Equipment Operator on his rounds or, if-desired, a watch could be established on the Refuel Floor and contact maintained with the Control Room using sound-powered phones.
Therefore, the passive protection provided by the spent fuel pool and the ability to visually observe the spent fuel pool level ensure that the ability to monitor and maintain the fuel in the spent fuel pool will not be reduced even if the technical specifications on Electrical Power Systems are deleted.
f LSNRC-2013 Page 9 of 9
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II.
Qhance In Frecuency Of Radiolocical Effluent Release ReportiDS The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are not likely to involve significant hazards consideration.
Example (vii) relates to a change to the license enabling it to conform to changes in the regulations, where the change results in very minor changes to facility operations clearly in keeping with regulations.
In this case, the change will cause the license to conform to changes in the regulations as described below.
This change revises Sections 6.8.1.4 and 6.13 of the technical specifications to-reduce the frequency of submittal of the Radioactive Effluent Release F.eport.
The proposed revision is entirely administrative in nature. -The same data will be reported to the NRC except that it will be reported on an annual basis rather than semiannually.
This proposed change to the frequency of submittal is due to a corresponding revision to 10CFRSO.36(a).which became effective on October 1, 1992.
This proposed change will not increase the probability of occurrence or consequences of an accident or malfunction of equipment important-to safety previously evaluated in the SAR.
This proposed change is unrelated to any of the accidents analyzed in the DSAR.
It will not create the possibility for an accident or malfunction of a different type than any previously evaluated in the SAR.
This proposed change will not reduce the margin of safety as defined in the baces for any technical specification.
None of the bases discuss radioactive effluent release reporting.
4.0 Timinc Of Chance We believe it is mutually beneficial to. achieve closure of NRC inspection report items as quickly as possible.
Since granting the first part of this request, A.C.
Sources and Onsite Power Distribution Systems, will enable LIPA to close inspection report unresolved item.50-322/92-04-02, we ask for NRC review and approval as soon as possible.
Granting the second part of this request will enable the license to conform to the Commission's regulttions.
Therefore, we ask for NRC review and approval of this entire application as scon as possible.
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