ML20236Q630

Application for Amend to License DPR-45,revising Administrative Section of Tech Specs Due to Permanent Shutdown of Plant on 870430.Fee Paid

ML20236Q630
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	11/12/1987
From:	Taylor J DAIRYLAND POWER COOPERATIVE
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20236Q633	List: ML20236Q630 ML20236Q644
References
LAC-12434, NUDOCS 8711200195
Download: ML20236Q630 (6)

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D DA/RYLAND -

L-hh/a/[ COOPERATIVE .:e O box 8i7 2615 EAST AVE.SO(608)

• LA CROS 788-4000

' JAMES W. TAYLOR -

Grneral Manager November 12, 1987 In reply .please refer to LAC-12434 DOCKET NO. 50-409 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Gentlement

SUBJECT:

Dairyland Power Cooperative La Crosse Boiling Water Reactor (LACBWR)

Provisional Operating License DPR-45 Application for Amendment to License

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REFERENCES:

(1) 10 CFR 50, Section 50.90 (2) 10 CFR 170.12 (3) DPC Letter, Taylor to Docket Control Desk, LAC-12234, dated May 22, 1987.

(4) NRC Letter, Berkow to Taylor, dated August 4, 1987.

(5) DPC Letter, Taylor to Document Control Desk, LAC-12383, dated September 30, 1987.

(6) DPC Letter, Taylor to Document Control Desk, LAC-12331, dated August 18, 1987.

Dairyland Power Cooperative requests revisions to the administrative section of LACBWR' Technical Specifications. Therefore, in accordance with the provisions of Reference 1, an application to amend Provisional Operating License No. DPR-45 for the La Crosse Boiling Water Reactor is hereby filed.

Reference 3 contained a request to amend the plant's license to a possession-only license. LACBWR was permanently shut down on April 30, 1987.

Reactor defueling was completed June 11, 1987. The NRC issued the possession-only license in Reference 4.

Due to the permanent shutdown, the staffing needs have changed. Fewer activities are required to safely monitor the plant now than were required to start up, shut down.and operate the reactor. The accident response needs have also changed. No longer do the operators have to be ready to respond to a recirculation line break while the reactor is operating at 100% power.

8711200195 871112 PDR ADOCK 05000409 P PDR 2

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. Document Control Desk LAC-12434

Page 2 November 12, 1987 To determine current staffing needs, a task analysis was conducted of response actions required during potential accidents that can still occur.

The original design basis accidents have been reassessed. Eight types of accidents have been postulated for the period of time the fuel remains stored on site. These accidents will be discussed in the Decommissioning Plan.

Each of the postulated accidents was analyzed to determine the number and type of people who are needed onsite to respond. Additionally, a fire was considered. In no case, is a prompt (less than 1 shift) response necessary for nuclear safety. However, the minimum number of operations people considered desirable for response was determined. In determining the number of people, the locations of the tasks to be performed and whether they could be done sequentially or if they should be conducted simultaneously were considered.

Attachment 2 documents the evaluation. The maximum number of operations personnel identified as the minimum required for any of the postulated accidents is 2, with the exception of a Shipping Cask or Heavy Load Drop into the Fuel Element Storage Well (FESW) accident. Therefore, DPC is proposing a 2 person crew, with an additional operator required when a spent fuel shipping cask or spent fuel is being handled. DPC is also proposing that a health physics technician be onsite when spent fuel or a shipping cask is being handled, since these are the only postulated accidents for which site releases should be assessed in a timely manner. The presence of the health physics technician would relieve the Shift Supervisor of this responsibility.

Other than a shipping cask and other specified refueling type and FESW items, the only loads allowed to be handled over the Fuel Element Storage Well (FESW) are those no heavier than a fuel assembly, per Technical Specification j Section 4.2.8.5. Therefore, a shipping cask will be the only heavy load {

handled over the FESW and the proposed requirement for an extra operator to be onsite during shipping cask handling fulfills this staffing need. DPC is also proposing that the extra operator and a health physics technician be onsite when non-routine evolutions are being conducted in the Fuel Element Storage Well.

The analysis also considered the qualifications of personnel performing the response actions. The 3 levels of qualifications considered were auxiliary operator qualified, Control Room watchstander qualified, and l Certified Fuel Handler or Senior Reactor Operator qualified. (Following l Decommissioning Plan approval, a certification training program is expected to replace the operator licensing program and the Shift Supervisors will become Certified Fuel Handlers instead of Senior Reactor Operators.) In all cases, a l I

person qualified to a higher level is capable of performing the duties l requiring lesser qualifications. Based on the needs of each postulated accident, it was concluded that the minimum shift staffing should be 1 Shift Supervisor, who is a Senior Reactor Operator or Certified Fuel Handler and 1 Therefore, at operator, who is qualified as a Control Room watchstander.

this time, DPC is proposing a crew composition of 1 Shift Supervisor with a Senior Reactor Operator License and 1 operator who is a qualified Control Room f

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• - Documrnt Control Dask LAC-12434.

Page 3 November' 12, 1987 watchstander, at.this time. This will replace the current Section 6.2.2.a and Table 6.2.2-1 of Technical Specifications, including the wording following the.

table'on page 6-4.

The current footnote to Table 6.2.2-1 allowing crew composition to be less than the minimum requirements for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will be retained as a.

footnote to section 6.2.2.a. .It will be restricted to allowing crew composition to be one less than the minimum and a statement not allowing this provision to be used at shift turnover will be added. This wording ties together the, current conflicting requirements on page 6-4. As discussed earlier, the analysis determined that'in no case is prompt response necessary for nuclear safety. Therefore, allowing the staffing to be one less than required'for a short period is acceptable,

~Section 6.2.2.b currently requires that at least one licensed operator be f'

l- in the Control Room when fuel is in the reactor. Since the reactor is defueled, this requirement no longer applies. The analysis performed showed that it would be beneficial for a Control Room qualified individual to know when an accident occurs. The' initial information is provided by one or more Control Room alarms. Therefore, DPC proposes that Section 6.2.2.b be revised 1

to require that at least one qualified Control Room operator be within visual and/or audio distance of the Control Room annunciators. This will assure that a knowledgeable individual is aware when an alarm occurs.

Section 6.2.2.c specifies staffing during reactor startups, shutdowns and recovery from trips. It no longer applies. Reference 5 requested that Section 6.2.2.c be deleted. If this request is processed first, it would be fitting to delete this non-applicable section along with the other changes to section 6.2.2.

Section 6.2.2.d currently requires that an individual qualified in . I radiation protection procedures be onsite when fuel is in the reactor. This section also no longer applies. It can be replaced by the proposed section j discussed earlier requiring that a health physics technician and an additional operator be onsite when spent fuel or a shipping cask is being handled.

Section 6.2.2.e currently requires that all core alterations be directly supervised by a licensed SRO or SRO Limited to Fuel Handling who has no other

. concurrent responsibilities. Section 4.0.1 defines core alteration as the i addition, removal, relocation or movement of fuel sources, incore instrumentation or reactivity controls within the reactor pressure vessel with the vessel head removed and fuel in the vessel. Since the reactor has been defueled, no core alterations will be conducted and this specification is not applicable. DPC proposes a replace it with a requirement that all spent fuel handling be directly superviced by a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling. Due to the relative dearth of other activities being conducted in a permanently shutdown plant, DPC does not feel that this must be an additional SRO, separate from the Shift Supervisor.

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'. iDocument'Conthol Desk' A ; LAC-12434

,, Pagn .4 November 212,,1987:

As discussed earlier, DPC expects the propos'ed specifications which

-require an individual with a Senior Reactor Operator license'to be changed to require.the person to be a Certified Fuel Handler following approval of the Decommissioning Plan. . The analysis performed is valid for current conditions and during'the SAFSTOR periodLwhile spent fuel is stored in the Fuel Element Storage Well.

The evaluation of a potential fire determined that.2 additional people would be needed to serve on the fire brigade. Either the Shift Supervisor or operator.would be.the fire brigade . leader,.while the other monitored instrumentation and operated equipment, as necessary. The analysis results and proposed operations staffing level are consistent with the previously proposed 3 member fire brigade (Reference 6).

.1 An editorial change is also proposed to Section 6.1.2, which is on one of the affected.pages. An unnecessary set of parentheses is being removed.

Attachment I contcins the proposed revised Technical Specification pages. I Reference'S submitted proposed Technical Specification changes which affected l both pages, but has not yet been approved.

Finding of No Significant Hazards k '

We have reviewed the hazards considerations referenced in 10'CFR 50 Sections 91 and 92 and have determined that with these criteria, no '

significant hazards considerations result from this proposed amendment.

1.. Operations of LACBWR in accordance with the proposed amendment will not  !

involve a significant increase in the probability or consequences of an -)

accident previously evaluated. j i

No method of operation is being affected. This is strictly an administrative change that affects staffing levels. The proposed staffing levels were selected based on an analysis of remaining potential accident' response needs, now that the plant is permanently shut down.

Therefore, the proposed amendment will not result in a significant increase in the probability or consequences of an accident previously evaluated.

2. Operations of LACBWR in accordance with the pro'osed p amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.

No method or limits of operation are being changed, so a new kind of 1 accident cannot be created by this change. Therefore, the proposed ]

amendment will not create the possibility of a new or different kind of accident from any previously evaluated.

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Document Control Desk LAC-12434

". Pegs 5 November 12,u1987..

'3. _. Operation of LACBWR in accordance with the proposed amendment will not involve a significant reduction in the margin of safety.

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No method or limits of operation are being changed, therefore, the margin l of safety won't be reduced. This is an' administrative change only, affecting only staffing' levels. The proposed staffing levels were

1. . ' selected' based on an evaluation of remaining potential accidents. The evaluation concluded'that in'no case is a' prompt response.necessary for nuclear safety. .However, the. minimum number.of operations people

. considered desirable for response was determined and is now proposed for minimum staffing levels. Therefore, the proposed amendment will not-Linvolve a. sign.ificant reduction'in the margin of safety.

As determined by the analysis ab'ove, this amendment has no significant hazards consideration.

~The-license amendment has been reviewed by the appropriate review committees.

The application fee required by Reference 2 for processing a license amendment or exemption ruquest is enclosed.

.If there are any questions, please contact us.

Sincerely, DAIRYLAND POWER COOPERATIVE James W. Taylor General Manager JWT:LSG:sks-Enclosures cc: Mr. A. Bert Davis, Regional Administrator U. S. Nuclear Regulatory Commission, Region III Glen Ellyn, IL 60137 Mr. Peter B. Erickson, LACBWR Project Manager Division of Nuclear Reactor Regulations U. S. Nuclear Regulatory Commission Mr. Ken Ridgway, NRC Resident Inspector Mr. L. L. Smith, Director Electric and Water Bureau Wisconsin Public Service Commission Madison, WI 53707 PCl-39

Document Control Desk LAC-12434

.. ;Page 6 November 12, 1987 STATE OF WISCONSIN )

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COUNTY OF LA CROSSE )

Personally came before me this /d day of , 1987, the above named, James W. Taylor, to me known to be the person who executed the foregoing instrument and acknowledge the same, w .

Notary Publi Q a Crosse County Wisconsin My commission expires February, 21, 1988.

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