ML20199K374
| ML20199K374 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 06/26/1986 |
| From: | Hauston R Office of Nuclear Reactor Regulation |
| To: | DAIRYLAND POWER COOPERATIVE |
| Shared Package | |
| ML20199K352 | List: |
| References | |
| NUDOCS 8607090141 | |
| Download: ML20199K374 (6) | |
Text
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e 3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of DAIRYLAND POWER COOPERATIVE ) Docket No. 50409
)
(La Crosse Boiling Water Reactor) )
EXEMPTION 1.
Dairyland Power Cooperative (the licensee) is the holder of Provisional Operating License No. DPR45 which authorizes operation of the La Crosse Boiling Water Reactor (LACBWR). This license provides, among other things, that it is subject to all rules, regulations and orders of the Commission now or hereafter in effect. The facility is a boiling water reactor rated at 50MW(e) at the licensee's site located in Vernon County, Wisconsin.
II.
. 10 CFR 50.54(w), requires that each commercial power reactor licensee shall, by June 29, 1982, take reasonable steps to obtain on-site property damage insurance available at reasonable cost and on reasonable terms from private sources or to demonstrate to the satisfaction of the Nuclear Regulatory Commission (the Commission) (NRC) that it possesses an equivalent amount of protection covering the facility, provided, among other things, that "this insurance must have a minimum coverage limit no less than the combined total of (i) that offered by either American Nuclear Insurers (ANI) and Mutual Atomic Energy Reinsurance Pool (MAERP) jointly or Nuclear Mutual Limited (NML); plus (ii) that offered by Nuclear Electric Insurance 8607090141 PDR 860626 ~
ADOCK 05000409
.PDR
Limited (NEIL), the Edison Electric Institute (EEI), ANI and MAERP jointly, or NML as excess property insurance." On September 12, 1983, the NRC granted the licensee an exemption from the requirement to carry excess property insurance.
The licensee currently is required to carry the full amount of on-site primary property damage insurance coverage (500 million dollars). By letter dated July 26, 1985, the licensee requested an exemption to reduce the amount of primary property damage insurance from the full amount of 500 million to 180 million dollars. The licensee states that the requirement to fully comply with the regulation is an undue financial hardship and burden. Maintaining a lower level of primary property damage insurance will provide annual savings of more than 200,000 dollars which will reduce operating cost for LACBWR. By letters dated February 7, July 12, November 21, December 16, 1985 and February 19, 1986 the licensee provided its technical justification that 180 million dollars of primary property damage insurance provides an adequate level of coverage to return the LACBWR plant to a condition ready for decommis-sioning following an accident.
In support of this request for exemption, the licensee submitted estimates of the potential property damage to LACBWR and the recovery costs following 1) a design basis loss of coolant accident (LOCA) assuming 100 percent cladding failure without fuel melting, and 2) a second scenario that adds a 50 percent fuel melt criterion. Accident recovery cost estimates are contained in a report titled " Post Accident Recovery Cost Study of the La Crosse Boiling Water Reactor", Document No. 81A1087, Rev. 3 and Rev. 4, prepared by Nuclear Energy Services (NES) of Danbury, Connecticut. The base document (81A1087, Rev. 3) gives an estimate of
$152,042,200 in 1984 dollars for accident recovery at LACBWR following a LOCA that results in 100 percent cladding failure without fuel melting.
An addendum (81A1087, Rev. 4) gives an estimate of $179,325,150 in 1984 dollars for a second accident scenario that adds a 50 percent fuel melt criterion. The accident scenarios evaluated by the licensee are equivalent to the most severe accident scenarios postulated in NUREG/CR-2601.
NUREG/CR-2601 provided the technical bases for primary property damage insurance rule 10 CFR 50.5d(w).
III.
The staff with technical assistance from Pacific Northwest Laboratory (PNL) has reviewed the information provided by the licensee in support of its request for exemption from the on-site primary property damage insurance requirement of Section 50.54(w)(1) of 10 CFR Part 50. The staff's review has addressed the following items:
- evaluation of the postulated LACBWR accident scenarios evaluation of the postulated accident operations
- assessment of the estimated costs of accident cleanup The LOCA that provides the basis for the LACBWR accident recovery study is the maximum credible accident identified in the LACBWR safety analysis report. LACBWR accident scenarios are equivalent to scenarios 2 and 3 in NUREG/CR-2601, " Technology, Safety and Cost of Decommissioning Reference Light-Water-Reactors Following Postulated Accidents."
The accident recovery operations described in the LACBWR study provide an adequate tabulation of required cleanup tasks in the reactor containment building following a LOCA. Time requirements for accident recovery following l
the " base case" accident are conservative and consistent with time l
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requirements for BWR accident cleanup specified in NUREG/CR-2601. Staffing requirements for accident recovery are based on the actual LACBWR operating staff augmented by additional personnel needed to perform decontamination and defueling. operations. Provision is made for additional personnel to provide the support act'ivities needed during recovery operations. The postulated recovery staff is adequate to perform the recovery operations described in the study for all accident scenarios.
Bases and assumptions used to estimate accident recovery costs are reasonable and consistent with those in NUREG/CR-2601. The cost estimating methodology used is a standard methodology that has been employed with other decommissioning studies. Costs have been included for all of the recovery operations and support services identified in the study. Basic cost data used to develop the cost estimates are realistic and represent-ative of actual labor, material, waste management, and support services costs. The estimate of 152 million dollars and 179 million dollars, including contingency, are conservative estimates of the cost of LACBWR accident recovery following the " base case" accident and the 50 percent fuel melt accident. The staff finds the accidents evaluated by the licensee are sufficient to establish an adequate level of primary property damage insurance coverage as required by 10 CFR 50.54(w).
Damage from the worst possible accident at LACBWR would be a small fraction of a similar accident at most larger ar.d newer plants. LACBWR has a tight containment building and contains less coolant in the primary circuit 1
than most larger BWR units. Due to LACBWR's small size, the reactor contains
w a low inventory of fissionable material and fission products and yields a much smaller and more confined contamination area to be dealt with in the event of the worst case postulated accident. Moreover, since power output is directly related to the amount of possible damage, it is not reasonable to pro.iect that the amount of damage for a 50 MW plant would be the same as a much larger plant. 10 CFR 50.54(w) makes no provisions for the amount of primary property damage insurance coverage required based on the size of a plant and the postulated clean up cost following an accident.
Therefore the staff finds compliance with 10 CFR 50.54(w) results in an undue financial burden for the licensee.
IV.
The staff has reviewed the licensee's request for exemption and finds that requiring the licensee to carry the full amount of primary property insurance coverage, 500 million dollars, as required by 10 CFR 50.54(w)(1)(i) is an unnecessary financial burden.
Based on its review, the staff concludes that issuance of this exemption will have no significant effect on the safety of the public or the plant.
Further, the licensee has shown special circumstances as described above and in the staff's supporting safety evaluation to support the exemption.
Pursuant to 10 CFR 51.31, the Commission has determined that the granting of this exemption will have no significant impact on the environment (December 12, 1985, 50 FR 50877).
- h. Li Accordingly, the Commission has determined that pursuant to 10 CFR 50.12(a) an exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. As indicated above, compliance with 10 CFR 50.54(w)(1) would result in undue costs for the size of the La Crosse facility that are significantly in excess of the relative cost incurred for similar insurance by the other much larger facilities covered by the rule. Thus, special circumstances as described in 50.12(a)(2)(iii) exist. Consequently, the exemption falls within special circumstances determined by the Commission to be sufficient to support the exemption. Therefore, the Commission hereby approves the following exemption:
The licensee is exempt, until further Order of the Commission, from the requirement to carry primary property damage insurance coverage in the full amount called for by 10 CFR 50.54(w)(1)(i), provided that the licensee maintain such primary property damage insurance in an amount not less than $180 million.
Dated at Bethesda, Maryland, this 2 6 day of dn e_, 1986.
FOR THE NUCLEAR REGULATORY COMMISSION 7 / N I
R." Wayne Hou on, Acting Director Division of BWR Licensing Office of Nuclear Reactor Regulation i
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