ML20217F519
| ML20217F519 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/28/1998 |
| From: | Hice D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20217F511 | List: |
| References | |
| NUDOCS 9804010033 | |
| Download: ML20217F519 (5) | |
Text
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i Consumers Energy Big Rock Point Plant i
APPLICATION FOR AMENDMENT OF LICENSE PURSUANT TO 10 CFR 50.90 -
SECURITY PLAN f
i l
Docket No. 50-155 License No. DPR-6 l
At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Energy Company submits the APPLICATION FOR AMENDMENT OF LICENSE PURSUANT TO 10 CFR 50.90 - SCCURITY PLAN. Consumers Energy's response is dated l
1 March 25,1998.
I Consumers Energy l
To the best of my knowledge, information and belief, the contents of this submittal are truthful and l
complete.
i By u ~
Donald D. Hic'e l
Plant Manager Sworn and subscribed to before me this.21th day ofMarch 1998.
t 0cmaL An..%lb(k
[Charlevoix County, Michiganennif/r Lynfi Helms, Notary Public My commission expires August 29,1999.
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9804010033 990325 PDR ADOCK 05000155 F
ATTACHMENT 1 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 PROPOSED APPLICATION FOR AMENDMENT OF LICENSE AND SIGNIFICANT HAZARDS DETERhUNATION Submitted March 25,1998 l
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CONSUMERS ENERGY COMPANY DOCKET 50-155 Application for Amendment to License License DPR-6 For the reasons hereinafter set forth, it is requested that the Facility Operating License DPR-6, Docket 50-155, issued to Consumers Energy Company on May 1,1964, for the Big Rock Point Plant be amended as described in Section I below:
- 1. DEFUELED SECURITY PLAN JUSTIFICATION FOR CHANGE See Attachment 2.
II. DISCUSSION Consumers Energy Company notified the ' Nuclear Regulatory Commission (NRC) by letters dated June 18, and June 26,1997, ofits intentions to permanently cease operations of the Big Rock Point Nuclear Plant by August 30,1997; and as certified, the plant was shutdown on August 29,1997. On September 22,1997, a letter pursuant to 10 CFR 50.82(a)(1)(ii) was forwarded to the Commission, certifying that the fuel has been removed from the reactor vessel and placed in the spent fuel pool for storage. In accordance with 10 CFR 50.82(a)(2), upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, the 10 CFR part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.
In the defueled condition, design basis accidents that were credible during operation are no longer applicabb. The design basis accidents relative to a defueled reactor (fuel handling accident, cask drop in the spent fuel pool), are a small subset of those considered for an operating reactor. Therefore, the
" Big Rock Point Restoration Project Defueled Security Plan" describes a physical protection system with the objective of providing high assurance that activities invoMng radiological sabotage and special nuclear material do not constitute an unreasonable risk to the public health and safety.
III. ANALYSIS OF NO SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10 CFR 50.92, Consumers Energy Company has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Consumers Energy Company has established that decommissioning in accordance with the proposed amendment will 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.
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The proposed change does not:
1)
Involve a significant increase in the probability or consequences of an accident previously evaluated.
)
Since the reactor has permanently ceased operation and will be maintained in a defuend condition until dismantled, the range of credible operating accidents for which the security plan is designed to mitigate have been significantly reduced. The purpose of the plan is to provide reasonable assurance that adequate security measures can be taken in the event of an act ofradiological sabotage (Consumers Energy Company has calculated the offsite doses for accidents involving fuel, and has determined that the resulting offsite doses at the site area boundary, assuming a free release path without containment isolation, are well below the Environmental Protection Agency's (EPA's) 400 Protective Action Guides 68 days post shutdown (November 5,1997)) and to prevent the theft of special nuclear material. However, since the remaining source of public risk is associated with the spent fuel pool, complete spent fuel pool drainage is an accident of potential concern. Certain combinations of spent fuel storage configurations and decay times, could cause freshly discharged fuel assemblies to self heat to a temperature where the self sustained oxidation of the zircaloy fuel cladding could cause cladding failure. Therefore, Consumers Energy Company will forward an analysis to the NRC that determines the point in time after permanent shutdown when the spent fuel decay heat is low enough such that no zircaloy oxidation takes place, and the spent fuel cladding remains intact upon extended exposure to air. The proposed Defueled Security Plan will only be implemented after that point in time. Therefore, there will be no increase in the probability of these events occurring or in the consequences of these events because the fuel cooling period is well beyond November 5,1997, the plan will not be implemented until the q
spent fuel decay time is such that a zircaloy oxidation reaction is not possible, and the i
appropriate elements for the protection of special nuclear material remain in place. The proposed changes are admmistrative and do not affect plant equipment or the procedures for equipment operation, or response to abnormal events / accidents.
2)
Create the possibility of a new or different kind of accident from any accident previously evaluated.
The purpose of the proposed change is to describe an appropriate physical protection system with the objective of providing high assurance that activities involving radiological sabotage and special nuclear material do not constitute an unreasonable risk to the public health and safety. Since the reactor has permanently ceased operation and will be maintained in a defueled condition until dismantled, the range of credibic operating accidents for which the security plan is designed to mitigate have been significantly reduced. Therefore, the possibility of a new or different kind of accident from any accident previously evaluated is not created.
The proposed changes are administrative, and do not affect plant equipment or the procedures for equipment operation.
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3)
Involve a significant reduction in a margin of safety.
The purpose of the proposed change is to describe an appropriate physical protection system with the objective of providing high assurance that activities involving radiological sabotage and special nuclear material do not constitute an unreasonable risk to the public health and safety. Since the reactor has permanently ceased operation and will be maintained in a defueled condition until dismantled, the range of credible operating accidents for which the security plan is designed to mitigate have been significantly reduced. In addition, the plan will not be implemented until the threat ofoxidation and failure of the zircaloy spent fuel cladding is eliminated. The proposed changes are administrative and do not affect any margin of safety.
IV. ENVIRONMENTAL IMPACT DETERMINATION An Environmental Assessment is not required for the proposed changes because these proposed changes meet the criteria for " actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The requested changes will have nc impact on the environment because they are administrative in nature. The proposed changes do not involve a significant hazard consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluent that may be released off-site. Further, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure, based on plan implemention after the threat of oxidation and failure of the zircaloy spent fuel cladding is eliminated.
V. CONCLUSION The Big Rock Point Safety Review Committee (SRC) has reviewed this application for amendment oflicense. The SRC has determined this application does not involve an unreviewed safety question based on the premise that since the reactor has permanently ceased operation and will be maintained in a defueled condition until dismantled, the range of credible operating accidents for which the
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security plan is designed to mitigate have been significantly reduced; and the plan will not be implemented until the threat ofoxidation and failure of the zircaloy spent fuel cladding is eliminated.
This proposed application for amendment to the license does not involve a significant increase in the probability or consequences of any accident previously evaluated, create the possibility of a new or l
different kind of accident from any accident previously evaluated, or involve a significant reduction i
in the margin of safety. This application for amendment to the license has also been reviewed by the independent Nuclear Performance Assessment Department. Consumers Energy Company concludes that the Big Rock Point Restoration Project activities, consistent with the proposed change, will not impact the health and safety of the public.
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