ML20211K040
| ML20211K040 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/31/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20211J975 | List: |
| References | |
| NUDOCS 9909070091 | |
| Download: ML20211K040 (11) | |
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- UNITED STATES t NUCLEAR REGULATORY COMMISSION N
WASHINGTON, D.C. 30006 0001 49
- SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULAT DEFUELED STATION EMERGENCY PLAN AND i
EXEMPTION REQUEST FROM CERTAIN REQUIREMENTS OF 10 CFR 50.47 l EMERGENCY PLANNING COMMONWEALTH EDISON COMPANY ZION NUCLEAR POWER STATION l
DOCKET NOS. 50-295 AND 50-304
1.0 INTRODUCTION
, By letter dated April 13,1999, Commonwealth Edison Company (Comed or licensee)
! submitted and requested approval of its Defueled Station Emergency Plan (DSEP) for the Zion
' Nuclear Power Station (ZNPS or plant), and requested an exemption from parts of 10 CFR
- 50.47(b) and 10 CFR 50.47(c)(2).- ZNPS was shut down on February 21,1997, and is now in a l permanently shutdown and defueled condition. In a letter dated May 4,1998, the Nuclear Regulatory Commission (NRC) acknowledged that pursuant to 10 CFR 50.82(a)(2), the 10 CFR
- Part 50 licenses for ZNPS, Units 1 and 2 no longer authorized operation of the reactor or l emplacement or retention of fuel in the reactor vessel. The DSEP reflects the shutdown and
! defueled status of the plant. The requested exemption from 10 CFR 50.47 would allow the licensee to discontinue offsite emergency planning activities and reduce the scope of onsite f emergency planning.' Following conference calls on June 16, June 24, and July 8,1999, l between the NRC staff and the licensee's staff, the licensee submitted a revision to the ZNPS l DSEP dated July 8,1999, which provided additional details or clarification of various sections of l the plan and a revision to the list of requirements found in Section IV of Appendix E to 10 CFR Part 50 that would continue to be met by the licensee.
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2.0 BACKGROUND
j The NRC may grant exemptions from the requirements of its regulations that, pursuant to 1 10 CFR 50.12(a), are (1) authorized by law, will not present an undue risk to public health and safety, and are consistent with the common defense and security, and (2) preser$t special i
! circumstances. Section 50.12(a)(2)(ii) of 10 CFR Part 50 describes one of thess special ,
circumstances, that is, where application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.
In the licensee's submittals, the following special circumstances were presented. The underlying purpose of the standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50.47(c)(2) is to ensure that nuclear power reactor licensees have emergency response plans that provide reasonable assurance that adequate protective measures would be 9909070091 990831 PDR ADOCK 05000295 F PDR i
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taken in the event of an emergency at a nuclear power reactor. The standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50.47(c)(2) were developed taking into consideration ,
the risks associated with operation of a nuclear power reactor at its licensed full-power level. 1 Those risks include the potential for an accident with offsite radiological dose consequences.
The risk associated with ZNPS has been significantly reduced since ZNPS is no longer authorized to operate. There are no design basis accidents or other credible events that would ]
result in a radiological dose beyond the exclusion area boundary (EAB) that would exceed the i EPA's early-phase Protective Action Guidelines (PAGs). Therefore, application of all the standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50.47 (c)(2) are not necessary to achieve the underlying purpose of those rules.
The staff used the same acceptance criteria for the review of the DSEP as are used to evaluate the adequacy of onsite emergency plans for operating nuclear power reactors, taking into consideration the current shutdown status of the ZNPS. The acceptance criteria include the planning standards of 10 CFR 50.47(b); the requirements of Appendix E to 10 CFR Part 50; and the guidance criteria of NUREG-0654/ FEMA-REP-1, " Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, dated November 1980; and the guidance contained in NUMARC/NESP-007, " Methodology for Development of Emergency Action Levels," Revision 2, dated January 1992.
For eny potential offsite impacts, the staff reviewed the DSEP using the standards of 10 CFR 50.47(d), which states the requirements for a license authorizing fuel loading and low-power testing only, and 10 CFR 72.32(a), which establishes the information required in an emergency plan for an independent spent fuel storage installation. These standards are considered by the staff to be generally appropriate for reviewing the offsite aspects of the DSEP.
3.0 DISCUSSION AND STAFF EVALUATION 3.1 Radiological Consequences ZNPS's Defueled Safety Analysis Report (DSAR) includes analyses of postulated accidents pertinent to Zion's permanently shutdown status. Chapter 5 of the DSAR describes the l radiological consequences of an accident that could release radioactive materials as well as the consequences of a beyond-design-basis event involvin'; a loss of spent fuel pool (SFP) inventory. Comed also submitted with this exemption quest a calculation of the gamma shine dose at the EAB from a complete loss of SFP invento y. The staff reviewed these analyses to I determine whether the radiological impact of these accidents would require an offsite emergency plan.
3.1.1 Radioactive Waste Handling Accident Decontamination of systems during decommissioning and dismantlement operations is expected to generate significant quantities of radioactive waste in the form of contaminated demineralizer resins. The licensee has postulated a bounding accident for the release of radioactivity: the dropping of a high-integrity container in the interim radwaste storage facility (IRSF) such that the entire contents of radioactive, dewatered, demineralizer resin escapes. A
fraction of the escaped resin is nonmechanistically assumed to be released as airborne radioactivity and passes from the IRSF directly to the environment. The analysis indicates that an individual at the EAB could receive up to 0.918 rem total effective dose equivalent from this event. This projected dose is less than the EPA's early-phase PAG of 1.0 rem.
The licensee did not postulate a fire concurrent with the radioactive waste handling accident; however, the licensee did assume that the release consists of the worst case mix of fission products that contribute to dose consequences (100% Co-60), and the solid-to-aerosol release fraction is the worst case nonmechanistic, mechanically initiated release fraction (0.1%). The release fraction assumption is the same fraction of material expected to be released by a fire and is consistent with the release fraction listed in Schedule C to 10 CFR 30.72 for Co-60. The calculational methods and assumptions used in this analysis are acceptable to the staff.
3.1.2 Cask Drop and Fuel Handling Accidents in the Fuel Building i
in the DSAR, the licensee c".alyzed a spent fuel cask drop. The casks are moved into the cask loading area from the side of the pool. The analysis shows that a tipped cask cannot fall on the fuel. The licensee explicitly states in the DSAR that no loads heavier than the weight of a single spent fuel assembly plus the tool for moving that assembly shall be carried over fuel stored in the spent fuel pool. There are guard walls between the cask area and the spent fuel area. The guard walls rise to the full height of the pool and are structurally designed to withstand the impact from a falling spent fuel cask. The DSAR further states that an analysis was performed on the integrity of the fuel pool floor, which took into account the highest elevation from which the cask could be dropped. The licensee concluded that no through-the-slab cracking would
- occur. Based on the existing licensing basis in the DSAR, which includes the initial condition of no movement of heavy loads over the spent fuel, the staff finds that the existing analysis sufficiently addresses the potential for offsite consequences for this exemption request due to a l cask drop. !
The licensee performed an analysis evaluating the dropping of a spent fuel assembly onto the SFP floor. The licensee assumed 1 year of decay time, the breaking of all fuel rods in the dropped assembly, and release of all the radioactivity in the gap between the fuel and cladding directly to the environment. No credit for lodine scrubbing or shielding by the pool water was !
used by the licensee (see staff summary dated August 10,1999, and licensee's letter dated August 30,1999). The licensee calculated a 2-hour integrated whole-body dose at the EAB of 0.88 rem, which is less than the EPA early-phase PAG of '6.0 rem and is bounded by the radioactive waste handling accident. The staff reviewed the licensee's calculational methods and assumptions for this evaluation and found them acceptable.
3.1.3 Spent Fuel Pool Draindown For the loss of spent fuel pool inventory and cooling, the licensee evaluated the duration of the event to the time when personnel exposure in the spent fuel pool building was unacceptable to personnel. The licensee determined that 3.9 feet of water shielding was required for adequato shielding to personnel in the spent fuel pool building. A decrease in level to eight feet above the fuel due to a pipe rupture of the spent fuel pool cooling water pump retum line and a boiloff of the remaining water to 3.9 feet above the fuel were used in the evaluation. The licensee calculated that it would require 3.2 days to boil off the spent fuel pool water from 8 feet to
3.9 feet above the fuel. The spent fuel pool has a low level alarm at the 614-foot 4-inch elevation (24 feet above the fuel). In a letter dated August 30,1999, the licensee confirmed
- that the low water level alarm in the control room will alert personnel to the reduction in water level and instruct personnel via the abnormal operation procedure on the various means to restore water level in the pool to the normal elevation. The licensee stated at least two sources of water would be available for the SFP makeup. In the letter of July 8,1999, the licensee proposed a station unusual event status if the level decreased to the 613-foot elevation.
Additionally, radiation monitors, as described in the DSAR, will alert personnel to a low water level in the spent fuel pool. The diverse alert signals that occur at varying times, procedures that instruct operators on various means to restore level, and the long time period required to reduce the level to an unacceptable level will provide sufficient time and capability to restore cooling and/or water level to the spent fuel pool. i Although the fuel onsite has decayed for over two years, a significant quantity of radioactive material remains in the SFP. Water and the concrete pool structure provide radiation shielding at the sides of the pool. However, water alone provides the majority of shielding above the spent fuel. A loss of shielding above the fuel could increase the radiation levels at the EAB because of the scattering of gamma rays streaming up out of the pool. The licensee calculated the offsite radiological impact of a postulated complete loss of SFP water (a beyond-design-basis event). The licensee concluded that with spent fuel decay time through October 1,1998 (just over 19 months). the gamma radiation dose rate at the EAB would be 0.00294 rad per hour at an outside air temperature of 21 *C. It is reasonable to assume that the licensee would be able to take effective corrective actions or protective acticns (even without an offsite
- emergency plan in place) or both within the 14 days it would take to exceed the EPA early-phase PAG of 1.0 rem. The staff reviewed the licensee's analysis and determined that the calculational methods and assumptions are acceptable.
3.1.4 Spent Fuel Pool Heatup The licensee evaluated the beyond design basis accident of a complete loss of water inventory from the spent fuel pool. The pool is a Seismic Category I structure. The walls vary in thickness from three feet, five inches to nine feet. The walls are reinforced concrete with a seam-welded stainless steelliner. No piping or tubing exists below the top of the spent fuel. In the analysis, the licensee performed a calculation to determine the peak cladding temperature in the SFP under the assumption that all water had been lost from the pool and only air cooling was available. ' By letter dated July 8,1999, the licensee provided the results of the SFP heatup in the event that all water had drained out of the pool. The licensee analyzed bundles with the highest bumups and the shortest decay time in order to determine the fuel bundle with the highest decay power using the ORIGEN2.1 computer code. The bundle bumup history was used 'n the ORIGEN2.1 calculation, and the decay heat was calculated to be 5.67 KW/MTU as of June 30,1999, for the limiting bundle F50D. This calculation corresponds to a total decay power of 2.6 KW for bundle F50D The building temperature was calculated using the KITTY- ,
1S code to be 139"C on the basis of a decay heat level of 5.5E6 BTU /hr for the pool. The pool L decay heat level was determined from experimental determination of the pool heat balance.
The COBRA-SFS code was used to perform the peak cladding temperature calculation using a detailed subchannel model of the highest power fuel bundle and assuming adiabatic boundary ,
conditions on the outside of the fuel channel. The peak temperature was found to be 482*C. J The staff finds this analysis and the calculated temperatures acceptable. The staff concludes j i
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that as of June 30,1999, a complete loss of water from the Zion SPF would not result in an l offsite release of fission products exeeding the EPA early-phase PAGs.
i 3.2 Assignment of Responsibility (Organizational Control)
The DSEP describes the on-shift and augmented organizations that are intended to be part of the overall response organization in the event of an emergency at the ZNPS. The plan identifies by title a specific individual who is in charge of emergency response and includes 24-hours-a-day coverage. In support of the normal shift organization, Comed maintains the capability to provide corporate support, including senior personnel, facilities, equipment, and financial resources. Local agency and support services are identified, as well as copies of letters of agreement listing support organization responsibilities and arrangements.
The staff has reviewed the ZNPS DSEP and concludes that the planning standards pertaining to responsibilities for emergency response are addressed in an acceptable manner in the DSEP.
3.3 Onsite Emergency Organization The DSEP describes the normal plant organization and the Defueled Emergency Response Organization (DERO). The licensee has provided a description for each of the emergency response positions. The plan identifies the emergency director's (ED's) responsibilities, including emergency classification, offsite notifications, command and control, and authorization of onsite protective actions. The DERO ED and the radiation protection director have a !
response goal of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Two additional DERO positions, technical director and communicator,
' have a 2-hour response goal from the time of an ' alert" classification.
The planning standard regarding on-shift facility licensee responsibilities for emergency response is addressed in an acceptable manner in the DSEP, considering the status of the facility. 4 3.4 Emergency Response Support and Resources Comed has arrangements, documented in letters of agreement, with local support agencies for radiological laboratories, hospital facilities, ambulance services, fire-fighting assistance, and police services.
The planning standard regarding emergency response support and resources for emergency response is addressed in an acceptable manner in the DSEP, considering the status of the facility.
3.5 Emergency Classification System Section 5.0 of the DSEP provides an emergency classification and emergency action level (EAL) scheme, including initiating conditions associated with possible events at the ZNPS that would result in the declaration of a notification of unusual event or an alert. Comed has '
discussed and reached agreement with appropriate State and local govemment authorities on the EALs. The staff has reviewed the EALs and determined that they are acceptable when l
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compared to the applicable standards, considering the defueled condition and shutdown status of the facility.
The DSEP addresses, in an acceptable manner, the planning standard for emergency classification and action levels for the ZNPS at this time, considering the defueled condition and shutdown status of the facility.
3.6 Notification Methods and Procedures The DSEP specifies that the States of Illinois and Wisconsin will be notified within 30 minutes of an emergency classification. Site personnel are notified by public address announcement, or off-hours by callout initiated by the Shift Supervisor. The NRC is notified immediately after State notifications and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of event classification. The content of notification messages is specified, and provisions are made for verification of notifications.
The DSEP addresses, in an acceptable manner, the methods and procedures for notification of emergency response personnel, the State, and local organizations, considering the status of the facility.
3.7 _ Emergency Communications The DSEP specifies that a dedicated telephone system, the Nuclear Accident Reporting System, will be used for notification of offsite authorities. Backup communications are available using commercial telephone lines. Two-way radios are available for in-plant communications between the control room and in-plant teams. A public address system is also available in-plant to link the Technical Support Center (TSC), the control room, and in-plant teams. The NRC will be notifiexi by way of the emergency notification system.
The planning standard for prompt communications among response organizations is addressed in an acceptable mannerin the DSEP.
3.8 Public Education and information Under the DSEP, the Nuclear Duty Officer and Communication Services are responsible for media relations and press releases.
The planning standard for public education and information is addressed in an acceptable manner in the DSEP.
3.9 Emergency Facilities and Equipment The DSEP identifies the control room and the TSC as the onsite emergency response facilities.
The station has various appropriate monitoring systems as needed for the evaluation of the condition of plant systems, meteorological conditions, seismic activity, and radioactive materials. The responsibility for and the maintenance of emergency equipment and supplies are established by the DSEP.
v s k The planning standard for emergency facilities and equipment to support an emergency '
response effort is addressed in an acceptable manner in the DSEP.
3.10 Accident Assessment The DSEP calls for onsite systems and equipment to perform radiological accident monitoring, assessment of radiological conditions, and of dose projections.
The planning standard for methods, systems, and equipment to be used in accident assessment and radiological monitoring is addressed in an acceptable manner in the DSEP.
3.11 Protective Response The DSEP outlines protective actions to be taken on site to protect personnel from hazardous conditions, calls for the relocation of onsite staff when necessary, maintains accountability for emergency responders, and limits site access when necessary. The DSEP has a goal to complete accountability for onsite personnel within 60 minutes.
The planning standard for protective actions is addressed in an acceptable manner in the DSEP, considering the current plant condition.
. 3.12 Radiological Exposure Control in the DSEP, the radiation protection director is responsible for onsite emergency radiological protection activities for plant staff and support personnel. Exposure limits and authorization authority for exceeding limits are defined. Contamination control measures and provision for decontamination are established.
The planning standard requiring means to control the radiological exposure of emergency workers is addressed in an acceptable manner in the DSEP.
-3.13 Medical and First Aid Support First aid supplies are provided for at the plant. Shift personnel trained in first aid are available on a 24 hour-a-day basis. The DSEP specifies arrangements for transportation of potentially contaminated injured individuals to an offsite medical facility for the treatment.
The planning standard for medical services is addressed in an acceptable manner in the DSEP.
3.14 Recovery and Reentry Planning The DSEP contains general criteria for determining when to establish recovery operations. The plan identifies the appropriate authority by position and title for initiating recovery actions.
The planning standard for general plans for recovery and reentry is addressed in an acceptable manner in the DSEA.
3.15 Exercises and Drills The DSEP specifies that biennial exercises of the DSEP will be conducted. The scope of these exercises will not need to extend beyond the site boundary, as discussed in Section 3.18. The DSEP also calls for an annual medical drill and an annual health physics drill. Communication links to the States of Illinois and Wisconsin and the NRC are tested monthly. A quarterly review
! and update of names and phone numbers of emergency response organizations and support
, personnel is specdied A full test of the emergency communication system will be conducted annually.
The planning standard for periodic exercises is addressed in an acceptable manner in the DSEP, considering the current condition of the ZNPS.
3.16 Radiological Emergency Response Training -
l The DSEP provides a training matrix to ensure that personnel assigned to the emergency response organizations are trained before they assume any emergency plan responsibilities and that they are retrained annually. The program covers basic as well as specialized training l for those emergency response personnel with specific assignments. Training for participating offsite agency personnel involved in emergency response is made available annually.
The standard for radiological response training is addressed in an acceptable manner in the DSEP.
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! 3.17 Plan Development and Review
' The requirement for an annual review of the DSEP is specified. Emergency plan implementing procedures and associated lesson plans are reviewed and updated every 2 years. An annual independent audit of the DSEP is also to be conducted. Responsibilities for maintaining the emergency response facilities, plans 1 procedures, and letters of agreement; staffing the emergency response organization; ar.J training of responders are specified in the DSEP.
The planning standard for plan development and review is addressed in an acceptable manner in the DSEP.
3.18 Emergency Planning Zones The licensee's submittal provides a determination that credible accident scenarios in the station's permanently shutdown and defueled condition can no longer exceed the early-phase PAGs specified by the EPA beyond the EAB. Classification of events above the alert level is no longer necessary since no offsite protective actions are anticipated. Consequently, the need
. no longer exists to have preesta%shed emergency planning zones as previously required by 10 CFR 50.47(c)(2).
The staff found this determination acceptable considering the current condition of ZNPS.
3.19 Requirements of 10 CFR Part 50, Appendix E With the plant in a permanently shutdown and defueled condition and a determination having been made that accident scenarios can no longer exceed the EPA PAGs off site, the need for L
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many previous'offsite emergency planning requirements is greatly reduced. The licensee's submittal identified the requirements of 10 CFR Part 50, Appendix E, Section IV, " Content of Emergency Plans," that would no longer be applicable in ZNPS's permanently shutdown and defueled condition.~ Generally, these requirements were specifically focused on offsite emergency planning activities that are no longer needed. The requirements that have been identified for relaxation include the following items:
- 1. An analysis provided by the licensee of the time required to evacuate or take other protective actions off site.
- 2. Identification of offsite officials responsible for offsite protective actions.
- 3. Making offsite protective action recommendations.
- 4. - A system to promptly notify the public of protective actions.
- 5. Dissemination of information to the public annually conceming emergency planning.
- 6. Identification, by position and function, of personnel from the licensee's headquarters, or others with special qualifications, that would be sent to the site to assist with emergencies.
- 7. A near-site emergency operations facility, operations support center, and associated communication links.
- 8. The participation of offsite. officials in exercises. Offsite response organizations that
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' provide emergency support services to the site will still be given an opportunity to participate in exercises.
The staff found acceptable the requirements in Appendix E of 10 CFR Part 50 that remain applicable to the site, in consideration of the station's current condition.
4.0 . CONCLUSIONS The staff concludes that the licensee's request for an exemption from certain requirements of 10 CFR 50.47(b) and 10 CFR 50.47(c)(2) as specified in the its submittal are acceptable in view of the greatly reduced offsite radiological consequences associated with the current plant status as permanently shutdown and defueled.
The licensee's proposed DSEP h'as been reviewed by the staff against the planning standards in 10 CFR 50.47(b) and 10 CFR 50.47(d); the requirements of Appendix E to 10 CFR Part 50, as well as the requirements in 10 CFR 72.32(a); the acceptance criteria in
!' NUREG-0654/ FEMA-REP-1, Revision 1, and the guidance contained in NUMARC/NESP-007, Revision 2. The staff concludes that the ZNPS DSEP provides an acceptable level of emergency preparedness at the ZNPS in its shutdown and defueled condition and also provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at ZNPS.-
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'The staff also concludes that with the approval of the exemption from the specified
! . requirements of 10 CFR 50.47(b) and 10 CFR 50.47(c)(2) for offsite emergency planning at l ZNPS, Comed may implement the DSEP.
l Principal Contributors: Daniel M. Barss Michelle Hart Diane Jackson Joseph Staudenmeier Date: August 31, 1999
DISTRIBUTION Docket PD4-3 r/f DScaletti EPeyton August 31, 1999 MEMORANDUM TO: Rules and Directives Branch Division of Administrative Services Office of Administration FROM: Office of Nuclear Reactor Regulation
SUBJECT:
Request for Approval of Defueled Station P- i s .c Plan and Exemptionfromcertainrequirementsof10CFR50.k7*
Zion MPS, Unit Nos.1&2 (TAC NOS. MA5253 AND MA5254, Baw:PMCY PLUIS"-
One signed original of the FederalRegister Notice identified below is attached for your transmittal to the Office of the Federal Register for publication. Additional conformed copies I 5 ) of the Notice are enclosed for your use.
Notice of Receipt of Application for Construction Permit (p) and Operating License (s).
Notice of Receipt of Partial Application for Construction Permit (s) and Facility License (s):
Time for submission of Views on Antitrust matters.
Notice of Consideration of issuance of Amendment to Facility Operating Licerise. (Call with 30-day insert date).
Notice of Receipt of Application for Facility License (s); Notice of Availability of Applicant's Environmental Report; and Notice of Consideration of issuance of Facility License (s) and Notice of Opportunity for Hearing.
[ Notice of Availability of NRC Draft / Final Environmental Statement.
Notice of Limited Work Authorization.
Notice of Availability of Safety Evalua' ion Report.
Notice of issuance of Construction Permit (s).
Notice of Issuance of Facility Operating License (s) or Amendment (s).
Order.
[ Exemption.
Notice of Granting Exemption.
Environmental Assessment.
Notice of Preparation of Enviroi mental Assessment. l
}
Receipt of Petition for Director's Decision Under 10 CFR 2.206.
l Issuance of Final Director's Decision Under 10 CFR 2.206.
Other: PLEASE t'lTJ. MITVT.RY PnnNAT fBf Ale-1*M UTTri ANY (mmp_: j 1
)
DOCKET NO. 50-295 and 50-304 Attachment (s): As stated (7 U1b
Contact:
Telephone:
Dino Scaletti 415-1104 DOCUMENT NAME:
Ts recuve a copy of this document, indkat b r: C = kyw ioNa cYment okure *
= Copy with attachment / enclosure *N' = No copy OFFICE 11TV 1/r Al l l l l l l NAME devron 9M DATE q/j /gg j OFFICIAL RECORD COPY L