ML20215E182
| ML20215E182 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/06/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20215E172 | List: |
| References | |
| NUDOCS 8610150098 | |
| Download: ML20215E182 (4) | |
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UNITED STATES iVbd' $i waswiscrow, o c. 20sss NUCLEAR REGULATORY COMMISSION' 5*o,M2@lE/ /
g-g SAFETY EVAlllATION PY THE OFFICE OF NilCLEAP REACTOR REGlti_ATION SUPP0PTING AMENDMENT NO. 29 TO FACILITY OPERATING LICENSE NO. NPF-22 PENNSYLVANIA POPER & LIGHT COMPANY SUSOVEHANNA STEAM ELECTRIC STATION, UNIT ?
DOCKET NO. 50-388
1.0 INTRODUCTION
In its letters (PLA-2719 and PLA-2720) dated September 12, 1986, (H. Keiser, PP&L to E. Adensam, NRC) the licensee requested that Technical Specification 3/4.9.11, ' Pefueling Operations - Residual Heat Removal and Coolant Circula-tion", be amended to indicate that the provisions of Technical Specification 3.0.4 are not applicable for the purpose of entering Operational Condition 5 from a defueled condition during the first refueling outage and inspection outage.
2.0 EVAlt!ATION Susouehanna Unit 2, currently in its first refueling outage, is in a defueled (" undefined") condition. The core was offloaded to minimize restrictions on olanned outage activities. In order to proceed into Operatior.:1 Concition 5 (refueling), Technical Specification 3.0.4 requires tnat the facility not rely on any Technical Specification Action Statement. The LCO for Technical Specification (TS) 3/4.9.11 requires that at least one shutdown cooling loop of the RHR be in operation in mode 5.
Due to unforeseen circumstances, the licensee has had to continue both RHR loops inoperable beyond their originally scheduled return to service. Accordingly, in order to enter mode 5 from i
the defueled condition, the licensee would have to rely on an Action Statement contained in TS 3/4.9.11.
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Since fuel loading was scheduled for Sunday, September 14, 1986, unless the emergency Technical Specification amendment is made, the outage will be delayed day for day until the required RHR loop is declared operable.
The licensee's requested amendment to Technical Specification 3/4.9.11 would permit the licensee to enter mode 5, removing the reactor coolant heat via the spent fuel cooling loop, currently in operation. Once in mode 5, the Technical Specification requires that if two RHR cooling loops are, not available, an alternate cooling method is acceptable. Accordingly once in Mode 5, the licensee will remove heat loads with the : cent fuel cooling sostem already in use, in accordance with the current action statement in Technical Specification 3/4.9.11.
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. The licensee has evaluated the safety implications of defueling the reactor without RHR cooling and with reliance on spent fuel pool cooling to cool the -
reactor vessel and spent fuel pool (see attachment to licensee's September 12, 1986, letter PLA-2720). This evaluation shows that in this mode the con-sequences of any potential accidents are bounded by the analyses of these accidents in the FSAR. Both decay heat and isotope inventory are lower now than they were during the defueling. Therefore, the analyses performed by the licensee for defueling in this cooling mode bounds the possibility of significantly increasing the consequences of a previously evaluated accident by refueling while using this same cooling mode.
The staff concludes that the licensee's proposed Technical Specification change is acceptable and determines that safety is not affected since Mode 5, which the licensee is attempting to enter into, enly reouires the use of a heat removal system. As the TS are presently written the licensee is allowed to use an alternate heat removal system and is not restricted to the RHR system. The licensee proposed to enter Mode 5 using spent fuel pool cooling which is already operable and in operation and which was previously used durino defueling. The staff finds this acceptable.
3.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION The Commission's regulations in 10 CFR 50.92 reouire that the Comission make a final determination that a license anendment involves no significant hazards considerations if operation of the facility in accordance with the 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.
The action proposed by the licensee does not involve a significant increase in the probability or consequences of an accident previously evaluated because the change would simply permit the licensee to initiate Core Alterations (i.e., load fuel) under conditions in which it is currently l
l permitted to continue Core Alterations. This should not affect the prob-ability or consequences of the accidents previously analyzed involving Core Alterations. The licensee has analy7ed the conditions for which they are reouesting to operate and has found that these conditions are bounded by accidents previously analyzed and contained in the FSAR. The staff has reviewed the licensee's analysis and agrees with the findings.
The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because accidents involving use of the spent fuel pool cooling system to cool both spent fuel pools and the reactor vessel with much higher heat loadings have been addressed in the licensee's attached Safety Evaluation (See PLA-2720 dated September 12, 1986).
Entry into Mode 5 in the proposed cooling confiouration does not change the spent fuel pool cooling system's capability.
. The licensee is presently allowed to operate in the proposed configuration (fuel in the core with alternate cooling other than RHR) when already in
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Mode 5.
The licensee is presently in another "specified condition" (completely defueled) and requests entering into Mode 5 with RHR cooliac unavailable. The licensee has analyzed operation in Mode 5 without RF:
cooling and finds that all accidents have been previously analyzed.
Therefore, the licensee concludes that this proposed change does not create the possibility of a new or different kind of accident previously analyzed and the staff aarees with this finding.
Accidents involving fuel handling in this configuration have been addressed.
The proposed action does not involve a significant reduction in a margin of safety because an adequate alternate cooling mode is available. The change in configuration does not: 1) reduce the cooling system capability,
- 2) increase the total heat load seen by the system, 3) increase reactivity or 4) increase the isotopic inventory available for accidental release.
In addition, the configuration proposed is the same as that allowed under current specifications the licensee is already in Mode 5.
Based on the above, the Commission has determined thr', the proposed action involves no significant hazards consideration.
4.0 FINDINGS OF AN EMERGENCY WARRANTINr AN AMENDMENT WITHOUT NOTICE The licensee had scheduled maintenance and surveillance of the RHR system to be completed in this outage prior to reload. This schedule was developed based on experience with similar work on Unit 1 RHR valves.
During this maintenance, the licenses experienced problems with the refueling se-1 which delayed commence-ment of the work on the RHR system as it was needed in service until the refuel-ing seal was in place. Once work on the RHR system commenced, problems were encountered with weld filler metal and rework of a weld.
Resolution of these problems and retesting of the system have added approximately 12 days 9to the RHP maintenance schedule. The licensee's submittal shows that a comparable delay in commencing core reload will result in a delay in completion of the outage and consequently a delay in restart of the unit.
Therefore, the staff concludes that failure to act promptly will result in a delay in restart of the unit and that a valid emergency exists.
It should be noted that the staff made a good faith effort to contact the State of Pennsylvania for comment but was unable to reach any appropriate State Representative.
5.0 ENVIR0 MENTAL CONSIDERATION This amendment involves a chance in the installation and use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requirements. The staff has determined that L
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this amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents which may be released offsite, and that there is no significant increase in individual or cumula-tive occupational radiation exposure.
The Commission has reached a finding that this amendment involves no significiant hazards consideration.
Accord-ingly, this amendment meets the elioibility criteria for categorical exclusionsetforthin10CFR51.22(c)(9). Pursuant to 10 CFR 51.22(b),
no environmental impact statement or enviromental assessment need be pre-pared in connection with the issuance of this amendment.
6.0 CONCLUSION
The staff has concluded, based on the considerations discussed above that:
(1) the amendment does not (a) significantly increase the probability or consequences of an accident previously evaluated, (b) create the possibility of a new or different kind of accident from any previously evaluated or (c) significantly reduce a safety margin and, therefore, the amendment does not involve a significant hazards consideration; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; and (3) such activities will be con-ducted in comoliance with the Commission's regulations and the issuance of the amendment will not be inimical to the common defense and the security or to the health and safety of the public.
Principal Contributors:
D. Waoner, Project Manager, PD-3 DBL W. Hodges, Branch Chief, RSB, DBL D. Vassallo, Branch Chief, F0B, DBL Dated:
October 6,1986 l
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