ML20205N144
| ML20205N144 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 04/24/1986 |
| From: | Erickson P Office of Nuclear Reactor Regulation |
| To: | Lynch O Office of Nuclear Reactor Regulation |
| References | |
| GL-86-03, GL-86-3, NUDOCS 8605010515 | |
| Download: ML20205N144 (3) | |
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April 24, 1986 Docket No.: 50-133 MEMORANDUM FOR: Oliver D. T. Lynch, Section Leader Standardization and Decommissioning Section Standardization and Special Projects Directorate Division of PWR Licensing-B FROM: Peter B. Erickson, Project-Manager Standardization and Decommissioning Section Standardization and Special Projects Directorate Division of PWR Licensing-B
SUBJECT:
REPORT ON MEETING - HUMBOLDT BAY UNIT 3 DECOMMISSIONING A meeting was held on April 11, 1986, in Bethesda, Maryland, with represent-atives of Pacific Gas and Electric Company (PG&E) to discuss Humboldt Bay Unit 3 decommissioning. Meeting participants are listed in Enclosure 1.
The requirements of 10 CFR Part 50.91, " Notice For Public Consnent" were discussed. The need for a licensee to justify a no significant hazards consideration position on any proposed amendment was stressed. Generic '
letter 86-03 (Enclosure 2) was cited as guidance for PG&E in submitting amendment requests.
PG&E discussed their schedule for proceeding with planned modifications to the spent fuel pool system to:
- 1) improve water quality control with the installation of a higher capacity ion exchange system, and
- 2) improve contamination control in the reactor building and protect spent fuel with the installation of a cover over the pool.
Plans were also discussed for the installation of a krypton-85 monitoring system in the exhaust stack.
PG&E will determine the need for revisions to their proposed decommissioning plan, for amendment requests and for 10 CFR Part 50.59 evaluations to expedite the above modifications at Humboldt Bay Unit 3.
original signed by Peter B. Erickson, Project Manager Standardization and Decorsnissioning Section Standardization and Special 8605010515 860424 Projects Directorate f ADOCK 0 3 Division of PWR Licensing-B
Enclosures:
)istribution:
As stated 2ctet Ffles HBerkow BGrimes SSPDReadinh PErickson ACRS(10) cc w/ enclosures: NRC PDR OELD NRC Participants See next page Lo 1 PDR EJo dan SPD DPWRL'AB:SSPD DPWI - :SSPD D W, -U:SSPD n PErickson:ac OL qh kow ,
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4 UNITED STATES 8 g NUCLEAR REGULATORY COMMISSION
- O j WASHINGTON D. C. 20555
- April 24, 1986 Docket No.: 50-133 MEMORANDUM FOR: Oliver D. T. Lynch, Section Leader Standardization and Decomissioning Section Standardization and Special Projects Directorate Division of PWR Licensing-B FROM: Peter B. Erickson, Project Manager Standardization and Decomissioning Section Standardization and Special Projects Directorate Division of PWR Licensing-B
SUBJECT:
REPORT ON MEETING - HUMBOLDT BAY UNIT 3 DECOMMISSIONING A meeting was held on April 11, 1986, in Bethesda, Maryland, with represent- '
atives of Pacific Gas and Electric Company (PG&E) to discuss Humboldt Bay Unit 3 decomissioning. Meeting participants are listed in Enclosure 1.
The requirements of 10 CFR Part 50.91, " Notice For Public Cormient" were discussed. The need for a licensee to justify a no significant hazards consideration position on any proposed amendment was stressed. Generic letter 86-03 (Enclosure 2) was cited as guidance for PG8E in submitting amendment requests.
PG&E discussed their schedule for proceeding with planned modifications to the spent fuel pool system to:
- 1) improve water quality control with the installation of a higher capacity fon exchange system, and
- 2) improve contamination control in the reactor building and protect spent fuel with the installation of a cover over the pool.
Plans were also discussed for the '.nstallation of a krypton-85 monitoring system in the exhaust stack.
PG&E will determine the need for revisions to their proposed decomissioning plan, for amendment requests and for 10 CFR Part 50.59 evaluations to expedite the above modifications at Humboldt Bay Unit 3.
W Peter B. Erickson, Project Manager Standardization and Decommissioning Section Standardization and Special Projects Directorate Division of PWR Licensing-B
Enclosures:
As stated cc w/ enclosures:
See next page
En. !osure 1 MEETING WITH PG&E
- APRIL 11, 1986
- HUMBOLDT BAY UNIT 3 DECOMMISSIONING Participant Organization Peter Erickson NRR Project Manager l
Frank Witt NRRfDBL/PSB Mitzi Young ELD Herbert Berkow NRR/DPWRL-B:SSPD l'
Jane Gibson NRR/DPWRL-B:SSPD Tom deUriarte PG8E/NRA Bryan A. Dettman PG&E/NOS R. J. Locke PG8E/ LAW R. T. Nelson PG&E/HBPP ,
G. H. Martin PG&E/NRA Charles E. Gaskin NRC/NMSS/SG J. R. Gray NRC/0 ELD I
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 k.....
February 10, 1986 T
LICENSEES OF OPERATING REACTORS AND RATING Gentlemen:
SUBJECT:
APPLICATIONS (Generic Letter 86-03)
FOR LICENSE AMENDMENTS notices issuance. in the Federal Reafster es in providing regarding timely license information' called for by 10 CFR r 50.91(a)(1) oo often the rega diO significant provided with thehazards amendmentconsideration request. using ng an analysis the standardsof no of 10 C R 50.92 is not The to reduceenclosed delays in discussion is for your information guidance and amendment requests. processing Federal Reaister Notices regar. Its purpose is ding license k whichconsideration.
hazards the staff found to contain an adequate analysisInclude m ttal of the no significant '
documentation to specifically address ent requests containeach sufficient factorY adequate submittal would include under a detailed 10 CFR 50.92(c). basis Ansuffi i k
. onfile athe issue timely of no Federal significant Register Notice. hazards consideration to cc ently com a license amendment request. routine Federal ctive is to have Reciiter most Notices* pu ng days of receipt of aInfindingthe event regarding thatno the staff is hazards significant unable consideratioan to find that adequate have directed the Project Director to return information can be included. n has the a provided been pplication so that the nec I essary This will also highlight to utility management an 1 Any receipt. such detemination will beendment made requests. by the staff w y 1 Your Project request accordingly. Manager will promptly notify you andn six working d return the amendment ($
N3 specific response to thi Manager if you have any que;s le, is required.
- ttent. Please contact your Project "
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Harold R. Denton Director
Enclosure:
Office of Nuclear, Reactor Regulation k As stated
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ENCLOSURE l l
l t RECENT PROBLEMS WITH LICENSE AMENDMENT REQUESTS l
1 10 CFR 50.91(a)(1) requires that licensees requesting an amendment provide an !
analysis "using the standards in 50.92" (the 3 factor test) about the issue i of no significant hazards considerations (NSHC). Staff final deteminations
! must also use the 3 factor test of 50.92. Proposed staff deteminations may use the examples of actions which are "likely" or "not likely" to involve l significant hazards considerations. These examples were provided in Enclo-I sure 1 to Generic Letter 83-19. l
{ The basic problem with many recent license amendment requests is that the '
! licensee does not provide an analysis using the 3 factor test. Often, all the t licensee provides is a simple bottom line assertion, copying the 3 factors, ,
but offering no analysis. In many cases the safety assessment is brief or i i
lacking in content such that the reader cannot conclude that the basis for '
the NSHC determination is in fact adequately provided in the description or
- in the safety assessment section. In other cases the safety assessment is j written so that the reader cannot detemine which part of the assessment j applies to which of the three factors. A simple assertion that references ,
4 an entire, fairly complex safety assessment as justification for satisfying '
the three factor test is not considered satisfactory. To expedite processing l of your application .each of the three factors should be addressed separately l for each part of the license amendment request. An assertion without appro-l priate analysis does not satisfy 10 CFR 50.91(a)(1).
While a licensee may offer an opinion to be helpful to the staff on which
- example is appropriate, that is not sufficient to satisfy 50.91(a)(1) -- a
! licensee is not merely to suggest that it is "likely" or "unlikely" that a proposed amendment involves a significant hazards consideration -- the
- licensee is required to give an analysis in tems of the 3 factors. The licensee should not need examples of what is "likely" or "unlikely"; the i licensee must complete a safety evaluation before submitting the proposed 1 amendment. Thus, the licensee should know on the basis of the completed l technical evaluation whether the proposed amendr,ent increases the probability 1 or consequences of an accident previously evalcated, creates the possibility 1 of a new accident or reduces a safety margin. On this basis, the licensee j should be able to articulate clearly the specific reasons as to whether the change is significant.
l . Attached is an example of a submittal which the staff found to meet the i above criteria.
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i ATTACHMENT 1
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Description of amendment request:
i The proposed amendment would modify Technical Specification 2.2.2, " Core -
Protection Calculator Addressable Constants"; Table 2.2-2, which provides a i listing of the Type I and Type II Addressable Constants; and the associated Bases. The proposed amendment would also revise the appropriate page of the ,
Index, delete the reference to Table 2.2-2 from Notation (9) and delete Notation (10) of Table 4.3-1, and delete the note in Administrative Control 6.8.1 (g).
The addressable constants of the Core Protection Calculators (CPC) provide a mechanism to incorporate reload dependent parameters and calibration
' constants to the CPC software so that the CPC core model is maintained current with changing core configurations and operating characteristics.
)
As a method to avoid gross errors upon operator entry of an addressable ;
constant, a reasonability check requirement was imposed by the original NRC CPC Review Task Force. The CPC software has been designed with automatic
- acceptable input checks'against limits that are specified by the CPC l functional design specifications. Therefore, inclusion of the addressable 1 : constants and the software limit values in the Technical Specifications l (2.2.2 and Table 2.2-2) is redundant, and serves only to enforce prior '
e approval of changes to these Ifmits. Proper administrative control
!. procedures are available to assure that appropriate values of addressable i constants are entered by the operator. Any CPC software changes involving '
addressable constants or software limit values are made and tested under NRC
- approved software change procedures and are available for NRC review.
j BASIS FOR NO SIGNIFICANT HAZARDS DETERMINATION:
The proposed change does not involve a significant hazards consideration
., because operation of Arkansas Nuclear One Unit 2 in accordance with this change j' would not:
i. (1) involve a significant increase in the probability or consequences an accident previously evaluated. This change merely eliminates redundant administrative reoufrements concerning the CPC addressable i
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constants. The function of these requirements is already implemented by the allowable value checks in the CPC software. Changes to the addressable constants are accomplished through strict administrative procedures. Therefore, this change cannot increase the probability or consequences of an accident.
(2) create the possibility of a new or different kind of accident from
!: any previously analyzed. It has been determined that a new or i different kind of accident will not be possible due to this change.
1 This elimination of redundant administrative requirengnts does not 1
)' create the possibility of a new or different kind of accident.
(3) involve a significant reduction in a margin of safety. Administrative procedures involving the CPC addressable constants ensure that the CPC
,; core model is calibrated to current plant conditions and therefore
- preserve the margin of safety. Elimination of redundant administrative i
requirements will not reduce the margin of safety, i
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The Commission has provided guidance concerning the appifcation of the
- standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are
- considered not likely to involve significant hazards consideration. Example (1) relates to a purely administrative change to Technical Specifications:
for example, a changeito achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclatur.e.
Example (iv) relates to 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.
In this case, the proposed change described above is similar to both Example (1) and Example (iv) in that deletion of Technical Specification 2.2.2, Table 2.2-2 and modifications to the related pages are purely administrative changes, and are also relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet demonstrated.
Conceptually, the addressable constants reasonability checks are the
- equivalent of the limits of an adjustable potentiometer in the conventional analog hard-wired type protection system. The Itaits of these potentiometers are not specified in the Technical Specifications, as this would be unrealistic and would make no contribution to plant safety. The addressable constants are basically calibration constants which"are used to assure that the CPC calculations of core parameters accurately reflect actual plant conditions. The proposed change may therefore be considered to achieve consistency throughout the Technical Specifications in that it removes a listing of calibration constants which is redundant in purpose and is not provided for any other system.
Removal of the listing of the addressable constants (and the allowable '
ranges of the Type I constants) may be considered a relief from an operating restriction that was imposed by the NRC CPC Review Task Force because acceptable operation was not yet demonstrated. ANO-2 was the first CE plant equipped with the CPC system; the addressable constants Technical Specification was imposed because this system was the first application of a digital computer based portion of a reactor protection system. Subsequent operational experience with the CPC system, both at ANO-2 and the other CPC equipped plants, has demonstrated acceptable operation. Relief from this administrative restriction has been allowed after several meetings between the utilities with CPC equipped plants and the NRC Core Performance Branch, which included members of the CPC Review Task Force. The criteria applied to the relief from this operating restriction have been established and there is satisfactory justification that they have been met. The NRC Core Performance Branch have issued a draft Safety Evaluation Report (concerning the removal of the addressable constants Technical Specification) which provides this justification. .
Therefore, based on the above considerations, AP&L has determined that this change does not involve a significant hazards consideration.
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