ML20136G246

Application for Amends to Licenses DPR-39 & DPR-48,deleting 800229 Confirmatory Order in Response to Disproportionally High Contribution to Total Societal Risk from Reactor Accidents.Fee Paid

ML20136G246
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	11/18/1985
From:	Reed C COMMONWEALTH EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
0838K, 838K, NUDOCS 8511220288
Download: ML20136G246 (9)

Text

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• ' Y Commonwo-Ith Edison O ) One First National Plaza. Chicago. litenois C '/ Address Reply to: Post Othee Box 767

.q Chicago, I!!inois 60690 November 18, 1985 Mr. Harold-R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Zion Nuclear Power Station Units 1 and 2 Proposed Amendment to Facility Operating License Nos. DPR-39 and DPR 2/29/80 Confirmatory Order NRC-Docket Nos.-50-295 and 50-304 l References (a): . February 29, 1980 letter from H. R.

Denton to D. L. Peoples.

(b): September 8, 1981 letter from L. O.

DelGeorge to H. R. Denton.

(c): December 15, 1982 letter from F. G.

Lentine to H. R. Denton.

(d): August 17, 1983 letter from F. G.

Lentine to H. R. Denton.

(e): January 27, 1984 letter from Cordell Reed to H. R. Denton.

(f): January 30, 1984 letter from F. G.

Lentine to H. R. Denton.

(g): October 19, 1984 letter from R. N.

Cascarano to H. R. Denton.

(h): February 28, 1985' letter from R. N.

Cascarano to H. R. Denton.

(1): June 25, 1985 letter from P. C. LeBlond to.H. R. Denton.

(j): August 26, 1985 letter from S. A. Varga to D. L. Farrar.

Dear Mr. Denton:

The purpose of this'l'etter is to transmit a proposed license amendment to delete the Zion Confirmatory Order, dated February 29, 1980.

Reference (a) imposed the Zion Confirmatory Order in response to the perception that Zion Station represented a disproportionate share of the total societal risk. Commonwealth. Edison Company has never shared this view.

Thus, this issue has been the subject of much correspondence. References (b) through (i) all represent requests to modify segments or rescind all of the Confirmatory Order. Attachment 1 provides a brief ription of this correspondence. g 0g )

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.H. R. Denton November 18, 1985 Attachment 2 contains a description of a proposed amendment to Facility Operating License Nos. DPR-39 and DPR-48. This amendment request involves the deletion of the Zion Confirmatory Order, dated February 29, 1980.

- Attachment 3 provides Commonwealth Edison Company's analysis of the issue of no significant hazards consideration as required by 10 CFR 50.91.

This amendment request has received on-site and off-site review and approval.

This amendment request supercedes the requests contained in References (b) through (h). These submittals can be considered closed.

Reference (1) contains a request to delete Items A.1 and A.2. It is anticipated that this request will be approved shortly. Thus, reference (1)

-should remain open until NRC approval has been issued.

.A $150.00 fee remittance is enclosed in accordance with 10 CFR 170. As provided by 10 CFR 50.91, the State of Illinois is being notified of this amendment request by transmittal of a copy of this letter and the attachments.

. If there are any further questions regarding this matter, please

-contact Comonwealth Edison's Nuclear Licensing Department.

Three signed originals and thirty-seven (37) copies of this letter

-and its attachments are hereby provided for your review.

Very truly yours, Cordell Reed Vice-President 1m Attachments

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NRC Resident Inspector - Zion l J. A. Norris - NRC l M. C. Parker - State of Ill.

I SUBSCRIGED AND*S to beforp me_th}s day of .4/gbit/u4 , 985 i i  ? Odh Notary,Publ'ic g 0838K

V ATTACHE NT 1 DESCRIPTION OF ZION CONFIRMATORY ORDER CORRESPONDENCE The Zion Confirmatory Order was transmitted to Commonwealth Edison by Reference (a). This order was prompted by the perception that the Zion Site represented a disproportionately high contribution to the total societal risk from reactor accidents. This belief stemmed from the fact that the population density surrounding the Zion Site is relatively high as compared to other nuclear power plant sites. The Order was comprised of a number of extraordinary interim measures that were intended to significantly increase the level of safety at Zion Station.

Commonwealth Edison Company subsequently performed the Zion Probabilistic Safety Study (ZPSS) which demonstrated that the risk associated with Zion was less than either previous NRC Staff estimates or the estimate for the WASH-1400 PWR, The ZPPS was completed in August,1981 and was transmitted to the NRC by reference (b).

Reference (b) also contained a request to rescind the Order, while agreeing to continue the testing of the residual heat removal system check valves. This requirement was orginally contained in Item A.5 of reference (a).

References (c) and (d) transmitted proposed changes to the Technical Specifications regarding the Auxiliary Feedwater System and the Emergency Diesel Generators, respectively. Since these issues were also discussed in reference (a), references (c) and (d) also contained requests to rescind Items E.1.C and B.6 to preclude any conflict between the Order and the Technical Specifications. The proposed Technical Specification changes concerning the Auxiliary Feedwater System contained in reference (c) have been approved.

Reference (e) provided the status of each order item and reiterated the original request of reference (b) to rescind the entire order. Reference (f) discussed the detrimental effects of the diesel generator testing program imposed by Item B.6 and requested the deletion of the restrictions on allowable outage time.

Reference (g) requested the renoval of Items A.1 and A.2 in conjunc-tion with the approval of a recently submitted LOCA reanalysis. Items A.1 and A.2 imposed restrictions on the calculated peak clad temperature during a LOCA and on the performance of load follow manuevers.

Reference (h) discussed the conflict between Zion's efforts to improve diesel generator reliability and the continued enforcement of Item B.6. A proposed modification to Item B.6 was also transmitted.

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Reference (i) transmitted a request for a license amendment to delete Items _A.1 and A.2. This request has been public noticed on September 11,-1985 and NRC approval is anticipated.

Reference (j) requested Commonwealth Edison's comments on the NRC Staff's report on the ZPSS. It also contained a number of recommendations for changes in Zion's design and operation. These changes were intended to increase the level of safety at Zion.

In summary, the Technical Specification change transmitted with reference (c) is the only request that has been approved. All other requests

~ discussed above remain open.

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e ATTACHMENT 2 l

PROPOSED CHANTS TO ZION OPERATING LICENSE NOS.

OPR-39 and DPR-48 CONFIRMATORY ORDER DATED FEBRUARY 29, 1980 DESCRIPTION OF CHANCE An amendment to Facility Operating License Nos. DPR-39 and DPR-48 is proposed to celete the Zion Confirmatory Order, dated February 29, 1980.

PAGES DELETED Zion Confirmatory Order, dated Fe'ruary o 29, 1980 Order - Pages 1, 2, 3, 4 Appendix A - Pages 1,2,3,4,5,6,7,8 Annex 1 - Page 1 Table 1 - Pages 1, 2 Annex 2 - Pages 1, 2, 3, 4, 5, 6 0838K

ATTACHMENT 3 Evalulation of Significant Hazards Consideration Proposed Changes to Zion Operating License Nos. DPR-39 and DPR-48 Confirmatory Order dated February 29, 1980 DESCRIPTION OF AMENDHENT ,

An amendment to Facility Operating License Nos. DPR-39 and DPR-48 is proposed to delete the Ziun Confirmatory Order, dated February 29, 1980.

BACKGROUND 10 CFR 50.92 states that a proposed amendment will involve a no significant hazards consideration if the proposed amendment does not:

(1) Involve a significant increase in the probability of consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a signflicant reduction in a margin of safety.

In addition, the Commission has provided guidance in the practical j

application of these criteria by publishing eight examples in 48 FR 14870.

The discussion below addresses each of these three criteria and demonstrates that the proposed amenoment involves a no significant hazards consideration.

BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Does the proposed amendment (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or dif ferent kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety?

DISCUSSION - ITEM 1 The Confirmatory Order addressed a large number of varied issues.

Each individual item placed some additional restriction on a given activity. The sum total of these restrictions was believed, in 1980, to result in a signficantly lower level of risk. This belief now appears to be unsupportable. The details of how this reassessment was arrived at apply more directly to Item 3 and thus they will be discussed under that heading.

However, the conclusion reached applies to Item 1 also. That is, that the presence or absence of the Order's restrictions has no significant effect on the level of risk at Zion Station. Thus, the probability or consequences of any previously evaluated accident is similarly unaffected.

DISCUSSION - ITEM 2 As discussed above, the Confirmatory Order has been shown to have a very slight effect on the overall level of risk at Zion Station. In addition, the individual order items are generally directed at accidents that were previously evaluated. For example, Item A.7 required licensed operators to be retrained in the pre-existing Emergency Procedures, which cover only previously evaluated accidents. Also, Item E.1 addressed the status of pre-existing procedures and safety-related systems. This logic is repeated tnroughout tne Order.

Thus, the Order not only has a minor effect on overall safety, but it is directed primarily at previously evaluated accidents. Therefore, its removal does not create the possibility of any new or different type of accident.

DISCUSSION - ITEM 3 The Zion Confirmatory Order was enacted because the Zion Site was believed to be a risk outlier. Specifically, reference (a) stated in part; Due to the relatively high population density surrounding the Zion site as compared to other nuclear power plant sites, the Zion site is believed to present a disproportionately high contribution to the total societal risk from reactor accidents. ...the Staff has identified a number of extraordinary interim measures that should be accomplished both by the licensees and the Staff. These measures will significantly increase the level of safety at tb ' Zion Station and thereby further reduce the probability of a severe reactor accident.

Both the belief that the Zion site may be responsible for the hi;her societal risks and that the Order significantly reduces those risks have ber.n dispelled. The NRC conducted hearings which specifically addressed the effect of an analogous order on the risks at Indian Point.

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The decision in that case (CLI-85-06, dated May 8,1985) found that the Indian Point Order did not significantly affect the level of safety.

Specifically, the Board Concluded; The staff was unable to quantify the extent to which compliance with the Director's Order reduced risks but estimated the reduction as less than a factor of 3. ...On the basis of uncontroverted testimony of I the licensees and staff, the Board found that the measures required or referenced by the D114ctor's Order of February,1980 had a small, positive effect on risa reduction, and that the effect is not amenable to quantification, but is probably considerably less than an order of magnitude. 18 NRC at 908.

l The Commission then decided to rescind Indian Point's Order by  !

stating; On the basis of the record, the Commission finds,it difficult to conclude that all of the measures imposed by the Director in 1980 provide substantial, additional protection which is required to protect the public health and safety. ...Second, the special proceeding record contradicts .the Director's previous conclusion that "these measures will signficantly increase the level of safety at the Indian Point Station."

00-80-5,11 NRC 351 (1980). Therefore, we have decided to rescino all of the requirements of the Order unless they are required to meet other license requirements for he Indian Point units or are required to fulfill generic requirements applicable to similar types of power reactors.

The NRC Staff has reached similar conclusions regarding Zion's overall safety and the need for the continued enforcement of Zion's Confirmatory Order. Specifically, the Staff concluded in Section 1.3 of Reference (j);

The staff concludes that Zion poses no undue risk to public health and safety. This conclusion does not depend upon the continued enforcement of the Directors Order of February 1980. Those few clauses of the Directors Order that significantly affect our risk evalation are complete or covered by other requirements.

In addition, the Staff concludes that Zion's design has attributes S

that directly counter-balance the relatively high population density surrounding the Zion site. That is; The staff review of the Zion plant systems indicates that the Zion units have strengths in the area of the response of plant systems to transients and small-break loss-of-coolant accidents (LOCA). The staff has also determined that large, dry containments (such as Zion contain-ment) are likely to contain most core melts, should they occur,

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resulting in a significant reduction in the magnitude of off-site  !

. consequences. For Zion, the site characteristic obviously most >

important is the population density around the plant, which is at the i high end of the population spectrum for plants licensed by the NRC. s Thus, Commonwealth Edison Company has concluded that the Zion site  ;

m - poses no undue risk and that the removal of the Zion Confirmatory Order does j not significantly reduce the margin of safety.

USE OF COMMISSION EXAWLE IV TO DEMONSTRATE NO SIGNIFICANT HAZARDS l CONSIDERATION Reference (a) stated that the Confirmatory Order was imposed because; The Zion site is believed to present a disproportionately high .I contribution to the total societal risk from reactor accidents. I

...These measures will significantly increase the level of safety at the Zion Station and thereby further reduce the probability of a severe reactor accident.

However, the conclusion of reference (j) states; l The staff concludes that Zion poses no undue risk to public health and safety. This conclusion does not depend upon the continued enforcement of the Directors Order of February 1980.

While an acceptable level of risk had not been demonstrated to the NRC Staff in February 1980, this task had been completed by August of 1985.

Thus, example iv is applicable in this instance. The fourth Commission example of No Significant Hazards Consideration reads as follows; (iv) A relief granted upon demonstration of acceptable operation from  ;

an operating restriction that was imposed because acceptable operation was not yet demonstrated. This assumes that the operating restriction and the criteria to be applied to a request for relief have been established in a prior review and that it is  !

justified in a satisfactory way that the criteria have been met.

Based on the above discussion, the proposed changes satisfy the criteria of 10 CFR 50.92 and are similar to the Commission's examples. ,

Therefore, Coninonwealth Edison Company has made a determination that no significant hazards consideration is involved.

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