ML20198J930
| ML20198J930 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/16/1997 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BYRON-97-0234, BYRON-97-234, NUDOCS 9710220241 | |
| Download: ML20198J930 (12) | |
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!!1'11- IlYllON 97 0234 IllE 2010301 U. S Nuclear llegulatory Commission A'ITN: Document Conttof Desk Washington, DC 205%
Subject:
Application for Amendment to l'acihty Operatinglicenses ll) ton Station Units 1 and 2 Facility Operating licenses NI'F.37 and NPit66 NRClhrktLSDLhMSLAndhM55
!!xemption Request for 10 CFil 70.24(a)
Pursuant to 10 Clill 70.14(a) and 10 CFit 70 24(d), Commonwealth I?dison Company (Comlhl) prtposes to amend Facility Operating license NPF-37. Comlki requests an exemption from the trquisements of 10 CI:lt 70 24(a)," Criticality Accident llequirements," for flyton Statmn Unit 1. 'lhis request, as described in the enclosure, involves no change to radianon monitoring instmmentation or emergency procedures.
Ilyron Unit 2 is cunently exempt from the requirements of 10 Cl It 70.24(a); therefore, a Unit i exemption is desirable to maintain consistency between the two operating hcenses. 'the request for an exemption is technically appropriate for the same trasons the NitC granted the exemption for Ilyton Unit 2 in that the plant licensing and design bases features preclude an accidental 9d ctiticality event. Pleat,c note that, although the pnposed Operating iJcense change is applicable to llyton Unit i only, this request is being docketed to sc0cct Units 1 and 2 so that the amendment numbers remain identical.
'this exemption icquest is subdivided as folk >ws:
- 1. Attachment A gives a description and safety analysis of the pnposed changes. \ \
2 Attachment 16 includes the marked up Operating license page with the requested change indicated 1 Attachment C de scribes Coml?d's evaluation perfonned in accordance with 10 CFlt 50,92(c), which contiims that no significant hazards consideration is involved 9710220241 971016 PDR ADOCK 05000404 p PDit (p \97ti)ltr$\970234 tkg) {
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Oct(eer 16,1997 <
i Pige 2 U, S Nuclear Regulatory Commission t
4, Attachment D provides the F.nvirotunental Assessment. ,
t F 'this puposed amendment has l>cen teviewed and approved l>y Comiki Onsite and Offsite .i Heview in acconlance with Crnniki pnicedures.
CrnnlEd is notifying the State of Illinois of this application for amendment by transmitting a copy {
of this letter and its attachmenta to the designated State Official.
i I affinn that the content of this teansmittalis ime and correct to the best of my knowledge, infonnation, and belief, ;
4 Please direct any questions you may have concerning this sulunittal to Marcia lesniak at (630) 663 64M ,
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a o. aes)se +
, Site Vice Pre t ent :
Ilyron Nuclear Power Station i iscribed and swom l>cftne me on this day of C 1997 by Ub 4 Notary IUblic _
_ = . ,
Neeery of h Attachments -N I*N 1 i cc: llegional Administrator 11111 Ilyton Station Proiett Manager Nltit
- flynin Station Senior Resident inspector Office of Nuclear Facility Safety - IDNS I
1 i
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A'ITACilMENT A DESCRIPTION AND SAFETY ANAINSIS FOR Tile PROPOSED CilANGE TO FACILITY OPERATING 1.lCENSE NPF 37 A. Summary of the Pronosed Change Commonwealth IIdison (Comlid) proposes to add a permanent exemption from the l criticality monitoring requirements specified in Title 10 to the Code of Federal l Regulations, Section 70.24(a)(10 CFR 70.24(a)) for Ilyton Unit 1. An exemption was :
previously granted for Unit 2, as described in Section 2.D of the Ilyron Unit 2 operating ;
license, NPF-66.
l The marked up page from the Unit i operating license indicating the proposed change is provided in Attachment 11. A detailed discussion of the change follows.
H. Descrintion and Hases of the Current Reaulrement 10 CFR 70.24(a) states the requirements for a monitoring system that will energire clearly audible alarms if accidental criticality occurs in each area in which licensed quantities of special nuclear material (SNM)is handled, used, or stored to ensure that all personnel withdraw to an area of safety when the alarm sounds These procedures must include the conduct of drills to familiarize personnel with the evacuation plan, designation of responsible individuals for determining the cause of the alarm, and placement of radiation survey instruments in accessible locations for use in such an emergency.
C. Description of the Reuucsted Revision ComIId proposes to revise Part 2.D of the Byron Unit 1 operating license to add an exemption to 10 CFR 70,24(a). The exemption would relieve Comed from the requirement of having a criticality alarm system.
D. Hases of the Reauested Revision Comed believes that the exemption is technically appropriate for the same reasons the NRC granted the exemption for Dyron Unit 2. The NRC issued Materials License Number SNM 1916 for Dyron Unit 2 on March 4,1985. The license included an exemption from the requirement to have a criticality accident alarm system. The provision has been carried forward into the current operating license for Byron Unit 2, which was issued on January 30,1987. A criticality accident monitoring system was and is not
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an a f t ton (Jnits I and 2 because the station design and licensing bases preclude u neddtmii diicality event. Ilyron's design inects (icneral l)esign Criterior ((il)C) 62,
- g. ' i%ct;riw a criticality in fuel storage and handling," and GDC 63,"hionitoring ibel and g w e ,s. rage 4
(. The specific requireinenta for granting esernptions liorn part 70 egulations ate set forth in
% 10 Cl Il 70 24(d) and 10 CFil 70.14(a) Section 70 24(d) anticipates that licensees inay need relief florn 10 CI'It 70 24, in whole or in part, if good cause is shown Comlid beliem that good cause exists and that the exemption requirements of 10 CI lt 7014(a) are satisibd (Jnder 10 Clllt 7014(a), the Commission is authorized to grant an exemption to Par 170 requirements provided the exemption (1)is authoriicd by law,(2) will not endanger life, property, or the common defense and f.ecurity, and (3)is in the public interest. As described below, Comlid believes thy exemption request meets these lequirements
- 1. The !!xemption 1(equest is Auth<uired Ily I.aw
'Ihe NitC's authority to grant exemptions from the requirements of Part 70 is provided in 10 CI:lt 7014(a) hjorcover, Section 70 24(d) makes it clent that the NI(C has specific and express authority to exempt licensees from the requirements of Section 70.24 Therenne, granting the requested exemption for !!yron lJnit I is authoriicd by the NRC's regulations.
- 2. The lixemption Will Not lindanger 1.ife, Property, or the Conunon Defense and Security
't he manner in which SNhiis used, stored, and handled at Ilyton (Jnit I provides adequate protection for the health and safety of the public. Specifically, design characteristics, procedural controls, and accident analyses ensure that accidental or inadvertent criticality will not occur at flyson (Jnit 1.
a (Jse of SNN1 Special nuclear material is present, principally in the form of nuclear fuel llowever, other quantities of SNhi are used (and stored) at flyron in the form of fissile material, such as fission chamber detectors The small quantity of SNh1 present in these latter items precludes an inadvertent criticality.
Inadvertent or accidental criticality in the icactor vessel is prevented through compliance with the facility Technical Specitications, including reactivity requirements (e g , shutdown margin limits and contiol rod insertion limits), instnnnentation requirements (e g , power and radiation moniters), and control on refueling nerations (e g , refueling boron
V concentration and wurce range monitor requirements). Procedures for unloading and inspecting new fuel are based, in part, on preventing criticality during these operations. The new fuel storage racks and spent fuel storage racks are designed to prevent a critical configuration. In addition, the operators' attention is directed toward instruments that monitor behavior of the nuclear fuel in the reactor, ensuring that the facility is operated in a manner that precludes inadvertent criticality.
Therefore, the requirements of Section 70 24(a) are not necessary for SNhi in the form of nuclear fuel while used in the reactor vessel, thus, granting this exemption will not endanger life or property,
- b. Storage of SNh1 SNhi as nuclear fuel is stored in one of two locations - the spent fuel pool or the new fuel storage area The spent fuel pool is used to store irradiated fuel under water afler its discharge from the reactor, or new fuel tollowing receipt. The poolis designed to store the fuelin a geometric array that precludes criticality. In addition, existing Technical Speci0 cations limit spent fuel reactivity such that k it is maintained less than or equal to 0 95 with soluble boron credit, even in the event of ti.e most limiting design basis accident (a fuel handling accident) and less than 1.00 in the event the spent fuel poolis diluted to O ppm boron.
The new fuel storage area is used to receive and store new fuel in a dry condition upon arrival on site and prior to loading in the reactor. The nes -
fuel storage area is designed to store new fuel in a geometric array that precludes criticality, in addition, existing safety evaluations demonstrate that koir is maintained less than or equal to 0.95 when the new fuel storage vault is fully loaded under full water density and low density optimum moderation conditions (e.g., due to the presence of aqueous foam or mist) or in the event of a fuel handling accident.
Therefore, the requirements of Section 70.24(a) are not necessary for the SNhi stored in the new fuel storage racks or the spent fuel pool; thus, ,
granting this exemption will not endanger life or property.
- c. llandling of SNh1 Nuclear fuel is moved between the new fuel storage racks, the reactor vessel, the refueling pool, and the spent fuel pool to accommodate refueling operations. In addition, fuelis moved into the facility and within the reactor vessel, or within the spent fuel pool. In all cases, fuel movements are procedurally controlled and designed to preclude conditions invohing criticality concerns. In addition, the Technical
Specifications also preclude certain movements ove: the spent fuel pool to prevent an inadvertent criticality. Previous accident analyses have demonstrated that a fuel handling accident (i c., a dropped fuel assembly) will not create conditions that could result in inadvertent criticality.
Therefore, the criticality monitoring requirements of Section 70.24(a) are not necessary for the safe handling of SNM; thus, granting this exemption will not endanger life or property.
- 3. The Exemption Request is in the Public Interest The maintenance of a criticality accident monitoring system and program meeting the requirements of 10 CFR 70.24(a) would require an expenditure of resourcer withcot a significant increase in overall safety. These expenses would include the operation and maintenance of the system for the life of Byron Unit 1, as well as the planning and conducting of drills specifically decigmi to sc: pond to a criticality accident. Monitoring based on the guidance in 10 CFR 70.24(a)is unnecessary because the Byron i design and licensing bases preclude an accidental criticality.
Therefore, the exemption request is in the public interest.
As discussed above, an exemption from the requirements of 10 CFR 70.24(a) for Byron Unit I is authorized by law, will not endanger life or property or the common defense and security, and is in the public interest. An exemption from 10 CFR 70.24(a) for Byron Unit 1 is desirable to maintain consistency between the Unit 1 and Unit 2 operating licenses, and is technically appropriate for the same reasons the NRC granied 'hc exemption in connection with Byron Unit 2. For these reasons, Comed believes the specific requirements for granting an exemption from 10 CFR 70.24(a) have been met and respectfully requests the NRC to grant the exemption for Byron Unit 1.
Comed meets the intent of 10 CFR 70.24(a). Area radiation monitors ORE AR055 and OREAR056 are provided in the fuel handling building near the spent fuel storage pool. These monitors serve a dual purpose for plant operations as criticality and fuel handling accident sensors for both Unit I and Unit 2. Although these monitors are designed primarily to detect fuel handling accident releases, they are capable of ictecting an inadvertent criticality incident. The setpoint given in the requirement is established for the fuel handling building isolation function but is also adequate for an inadvertent criticality. The monitors alarm locally and in the main control room in the event of a criticality accident in the new thel storage area. The monitors are calibrated once per 18 months, in accordance with the Technical Specifications. The a monitors meet the intent of Regulatory Guide 8,12," Criticality Accident Alarm Systems."
li. the event ofincreasing radiation in the fuel handling building, Emergency Procedures IBOA REFUEL-1 and 2 BOA REFUEL-1 instruct the control room operator to initiate an evacuation of the building and to notify the station duty ollicer to evaluate for Generating Stations Emergency Plan (GSEP) conditions. The procedure includes determining the
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cause for the alarm, and contacting Radiation Protection for guidance in placing radiation survey irstruments. Additional station procedures also provide guidance on responding to a high radiation alarm in the fuel handling building. The procedures are controlled in a manner that exceeds the requirements in 10 CFR 70.24(a)(3)
Personnel in the vicinity of a criticality accident would be sufliciently Trotected due to self alarming personal dosimetry, which is required at Byron, and local area radiation alarms on the refuel floor. Annual general radiation training (NGET) enforces safe radiation practices including the requirement to exit an area immediately when personal dosimetry or local arca radiation monitors alarm due to high radiation conditions.
Although drills are not specifically conducted to evacuate the fuel handling building, the flyron GSEP envelopes the objectives for drills set forth in 10 CFR 70.24(a)(3).
Specifically, the GSEP sets forth the plan objectives and describes the related emergency organization, including assignments of authority and responsibility. The GSEP provides for detecting and evaluating emergency conditions; establishing protective action levels and protective measures when such levels are exceeded; communications; postaccident recovery and reentry; periodic emergency preparedness assessment; drills; and training of the participating personnel. The GSEP considers the spectrum of accidents that are considered credible Revisions to the GSEP are filed with the Nuclear Regulatory Commission in accordance with Appendix E to 10 CFR $0. The GSEP drills meet the intent of the rule since the underlying safety concern is high radiation levels and not the initiating event.
Ilased on the preceding discussion, Comed meets the intent of 10 CFR 70.24(a).
E. Schedule Requirements There are no specific schedule requirements.
Currently there is an outstanding application for amendment to the Byron operating licenses, submitted to the NRC on Marc i 1,1097. That request would delete several license conditions ti.at have been satistico and make other editorial changes. Since that change has not been approved, the markup in Attachment B is on the current operating license page that has not incorporated the outstanding request.
A*ITACHMENT H PROPOSED CilANGE TO FACILITY l OPERATING LICENSE NPF-37 l BYRON STATION UNIT 1 l f
\
Affected Page: 8' i i
i I
Note: Markups are provided on a copy of the operating license that was provided by the NRC. This page had a handwritten note that was not masked or changed in Comed's 4
8-J comon defense and securitf and are othemise in the public interest. ;
Therefore, th '
WitH"thf gran.e,se ting ofexemptigns are hereby these exemptions granted the facilitypursuant to'10 to will operate, CFR the50.12. ,
extent authorized herein, in confomity with the application, as amended, v the provisions of the Act, and the rules and regulations of the Connission. *
~ E. Ceco shall fully implement and maintain in effect all provisions !
of the Comnission approved physical security, guard training and . Am04.. ,
qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscel aneous Amendments and Search 4 g# .
Requirementsrevisionsto10CFR73.55(51FR27817and27822)andtothe authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain g :,
Safeguards Information protected under 10 CFR 73.21, are entitled: " Byron :
Nuclear-Power Station Security Plan," with revi: ions submitted through January 14,1988; " Byron Nuclear Power Station Security Personnel Training and Qualification Plan," with revisions submitted through ,
September 26.- 19868- and " Byron Nuclear Power Station Safe Contingency Plan," with revisions submitted through July guards 30, 1985, i Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.
F. Except.as othenvise provided in the Technical Specifications or Environmental Protection Plan, the licensee shall report any violations of the requirements contained in Section 2.C of this license in the following manners ir.itial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written followup within thirty daysinaccordancewiththeproceduresdescribedin10CFR50.73(b),(c) and(e).
G. 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 Atamic Energy Act of 1954, as amended, to cover public liability claims.-
/ .
- The-Securit Contingency,y PlanPersonnel Training are Appendices to theand Qualification Security Plan. Plan and the Safeguards . .
4
,% pctases is exem@ed .fm Se cdkca.l glum syk ,
provision 4 10 G R 70 t+ Sa lar ** Nif Set li+[ 9 es 1i lo Ac sky of futl cosedliu held uder W( b'ctus t. i f
A1TACilMENT C EVALUATION OF SIGNIFICANT ll AZARDS CONSIDERATIONS FOR PROPOSED CIIANGES TO FACILITY OPERATING LICENSE NPF-37 i
Commonwealth Edison has evaluated this proposed amendment and determined that it involves no significant hazards considerations According to 10 CFR 50.92(c), a ,
proposed amendment to an operating license involves no significant hazards if operation of the facility in accordance with the proposed amendment would not: !
1 involve a significant increase in the probability or consequences of an accident ,
previously evaluated, or
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated, or
- 3. Involve a significant reduction in a margin of safety.
Commonwealth Edison (Comed) proposes to add a permanent exemption from the criticality monitoring requirements specified in Title 10 to the Code of Federal Regulations, Section 70.24(a)(10 CFR 70.24(a)) for Byron Unit 1.
A. The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
The initial conditions and methodologies used in the accident analyses remain unchanged. 'Ihe proposed change does not change or alter the design assumptions for the systems or components use'l to mitigate the consequences of an accident.
Therefore, accident analysis results are not impacted.
There are no physical changes to the facility, and all operating procedures, limiting conditions for operation, limiting safety system settings, and safety limits are unchanged.
The specific requirements for granting an exemption from 10 CFR 70.24(a) have been met. The request is authorized by law, will not endanger life or property or the common defense and security, and is in the public interest. .
Therefore, the proposed change dces not involve a significant increase in the probability or consequences of ar accident previously evaluated.
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O .
IE The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change does not affect the design or operation of any system, structure, or component in the plant. The safety functions of structures, systems, or components are not changed in any manner, nor is the reliability of any structure, system, or component reduced by the revised surveillance or testing requirements. The change does not affect the manner by which the facility is operated and does not change any facility design feature structure, system, or component. No new or different type of equipment will be installed. Since there is no change to the facility or operating procedures, and the safety functions and reliability of structures, systems, or components are not afTected, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
C. The proposed change does not involve a significant reduction in a margin of safety.
The proposed change to the Operating License has no impact on the margin of safety of any Technical Specification, There is no impact on safety limits or limiting safety system settings. The change does not affect any plant safety parameters or setpoints. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Therefore, based on the above evaluation, Commonwealth Edison has concluded that the proposed change does not involve significant hazards considerations.
ATTACHMENT D ENVIRONMENTAL ASSESSMENT FOR PROPOSED CHANGES TO FACILITY OPERATING LICENSE KPF-37 Commonwealth Edison Company (Comed) has evaluated this license amendment request against the criteria fo: identification oflicensing and regulatory actions requiring envirenimental assessment in accordance with Section 51.21 of Title 10 to the Code of Federal Regulations, Part 51, (10 CFR 51.21). Comed has determined that this proposed license amendment request meets tt.e criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(9). This determination is based on the fact that this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50 that changes a requirement with respect to installation or use of a facility component located within the ;
restricted area, as defined in 10 CFR 20, or that changes an inspection or a surveillance requirement, and the amendment meets the following specific criteria:
(i) the amendment involves no significant hazards considerations h< demonstrated in Attachment C, this proposed amendment does not involve any significant hazards considerations.
(ii) there is no significant change in the types or significant increase in the amounts of any emuent that may be released ofTsite There will be no change in the types or significant increase in the amounts of any efilvents relea3ed offsite.
(iii) there is no significant increase in individual or cumulative occupational radiation exposure.
. The proposed changes will not result in changes in the operation or configuration of the facility There will be no change in the level of controls or methodology used for processing of radioactive efIluents or handling of solid radioactive waste, nor will the proposal result in any change in the normal radiation levels within the plant Therefore, there will be no h. crease in individual or cumulative occupational radiation exposure resulting from this change.
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