ML20236U633

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Safety Evaluation Supporting Amends 179 & 166 to Licenses DPR-39 & DPR-48,respectively
ML20236U633
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 07/24/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236U618 List:
References
NUDOCS 9807300355
Download: ML20236U633 (4)


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UNITED STATES g

j NUCLEAR REGULATORY COMMISSION

't WASHINGTON, D.C. 30666-0001 O

3AFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 179 TO FACILITY OPERATING LICENSE NO. DPR-39 AND AMENDMENT NO.166 TO FACILITY OPERATING LICENSE NO. DPR-48 COMMONWEALTH EDISON COMPANY ZION NUCLEAR POWER STATION. UNITS 1 AND 2 QQCKET NOS. 50-295 AND 50-304

1.0 INTRODUCTION

By letter dated March 30,1998, Commonwealth Edison Company (Comed, the licensee) submitted a request for sa amendment to the Zion Nuclear Power Station (Zion) Technical Specifications (TS). Comed's application to amend the Zion TSs (1) requests restoration of Custom Technical Specifications (CTS) and the associated license conditions that had been replaced by improved Technical Specifications (ITS), (2) would chcnge certain management titles and responsibilities to re0act the permanently shut down condition of the plant, (3) would allow use of Certified Fuel HHdlers (CFH) in lieu of licensed operators, (4) would modify shift crew composition, and (5) w d eliminate verbiage that implies the units are operational. This request was submitted as a result of Comed's decision to permanently cease operation of the Zion Nuclear Power Station.

2.0 EVALUATION The ITS were approved and issued by Amendment Nos.178 and 165 on December 19,1997, but were neverimplemented at Zion. Therefore, Comed has continued to conduct activities at Zion in accordance with CTS. The proposed TS amendments would revoke the ITS and maintain CTS as the specifications goveming activities at Zion. The amendments would also restore the five license conditions that were deleted from CTS based on (1) approval and implementation of ITS, (2) relocation of four of the license conditions to ITS, and (3) relocation of one license condition to the Updated Final Safety Analysis Report (UFSAR). Comed intends to submit, at a later date, a new set of Permanently Defueled TSs.

The proposed amendments to the CTS would modify the responsibilities and titles of the Chief Nuclear Officer, the site Vice President, and the Station Manager. As currently described in Section 6 of CTS, the responsibilities and titles of these individuals are associated with an operational nuclear power generating facility. Comed intends to transfer responsibility for Zion to the Comed Decommissioning Projects organization and proposes to change the titles and responsibilities to reflect the permanently shut down condition of the facility. These changes include: transferring corporate responsibility for safe handling and storage of the fuel from the Chief Nuclear Officer to a Corporate Vice-President; eliminating the Site Vice President's position, and changing the Station Manager's title to the Decommissioning Plant Manager. Other changes include: replacing the Shift Operation Supervisor, Shift Engineer, and Shift Foreman 9807300355 990724 5

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i with the Shift Supervisor who would be a Certified Fuel Handler; eliminating the Fuel Handling Foreman's position, and changing the Operating Engineer's title to Decommissioning Operations

Manager, in its permanently defueled condition, licensed operators trained in accordance with the requirements of 10 CFR Part 55 are no longer required at Zion Station. The proposed CTS amendments describe the training and qualification requirements that are appropriate for personnel at a permanently defueled facility. The amendments to the CTS will also allow the use of CFH in lieu oflicensed operators.

In its permanently defueled condition, there are fewer tasks to be performed by the operating crews at Zion Station. As such, fewer personnel will be needed to operate the facility. T',h.

proposed amendments change the shift crew composition to allow the use of a Shift Supervisor and two non-certified operators rather than 10 CFR Part 55 licensed operators to reflect the permanently shutdown and defueled condition of the facility. The Shift Supervisor would be qualified as a CFH.

There are several areas in Section 6 of CTS which could imply that Zion Station is still operational. Typically, these occur when the term " operating" or " operation" is applied to the terms " unit" or " plant." Rewording of this type of verbiage would avert confusion or l

misunderstanding.

3.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

Zion, Units 1 and 2, are permanently shut down and defueled. All of the fuelis stored in the spent fuel pool. Credible operating accidents are significantly reduced in this mode. Major nuclear activities that may significantly affect public safety are storage and handling of nuclear fuel. Accidents related to these activities have been previously evaluated. The proposed j

j changes do not increase the probability or consequences of an accident previously evaluated for l

a permanently shut down plant.

On December 19,1997, the NRC approved Zion's improved Technical Specifications (ITS). The licensee had 30 days from that date to implement the ITS. However, because comed decided to shut down Zion on January 15,1998, the iTS were never implemented. Zion has continued to l

comply with the requirements of the CTS without any interruption. The proposed amendment i

revokes the ITS and allows continued use of CTS. Therefore, reinstating the CTS and five License Conditions which were removed by ITS, will not increase the probability or consequences of an accident previously evaluated.

Because Zion is permanent ly shut down, the scope of work has decreased at the station.

Therefore, a change in the management organization was requested to reflect this reduced work scope. For example, there will be no need for shift engineers and licensed operators because the reactors will not be operating. The major nuclear activities would be storage and handling of spent fuel bundles in the pool. The qualification needed for this function can be found in Certified Fuel Handlers. Changing the management organization and utilizing Certified Fuel Handlers will not increase the probability or consequences of an accident previously evaluated.

l In tne CTS and ITS there are no requirements to have a Shift Control Room Engineer (SCRE) when both units are not operating. Therefore, the elimination of SCRE does not increase the i

probability or consequences of an accident previously evaluated. Finally, the NRC, in the ITS

. amendment, had approved the elimination of the Radiation Protection Person (RPP) from the shift when both units were shut down. Elimination of the on shift RPP will not result in an increase in the probability of an accident nor will it increase the consequences of an accident previously evaluated. RPP personnel will remain available to support radiological work activities during decommissioning.

Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

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No new activities will be conducted that were not previously evaluated. The scope of the work has significantly been reduced at Zion because it will not operate again. In addition, the proposed changes do not involve the addition of new components or structures that could create a new or different kind of accident. Restoration of the CTS and the five License Conditions do not introduce a new or different kind of accident because Zion has continued to comply with the requirements of the CTS and the License Conditions even though they were abolished in the ITS.

Management changes, shift staffing reductions and the utilization of Certified Fuel Handlers are requested to meet the needs of the current state of the plant, which is permanently shut down.

These changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Does the change involve a significant reduction in a margin of safety?

Because Zion is shut down and the scope of work has been reduced and most of the work that will be conducted at Zion has been evaluated previously, there is no reduction in the margin of safety. The proposed changes do not introduce any new work that will reduce the margin of l

safety. The CTS and License Conditions were continuously in effect since prior to issuance of the ITS, therefore, restoration of the CTS and the License Conditions will not reduce the margin of safety. The requested management changes, shift staffing reductions and the utilization of Certified Fuel Handlers are commensurate with the current defueled status of Zion. Therefore, these changes do not reduce the margin of safety.

Based on the analysis above, in accordance with the standards of 10 CFR 50.92(c), the NRC l

staff has made a final determination that the requested amendments involve no significant hazards consideration.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no i

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significant increase in individual or cumulative occupational radiation exposure. The Commission has made a final no significant hazards finding with respect to the amendments. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

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6.0 CONCLUSION

The staff has completed its review of the requested amendments to the Zion Nuclear Power Station TSs. The request for amendments is consistent with current licensing practice. The requested amendments ensure that Zion is maintained in a safe, stable condition. Accordingly, the requested license amendments to the Zion Nuclear Power Station TSs are acceptable.

l The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the l

Commission's regulations, and (3) the issuance of the amendments will not be inimical to the l

common defense and security or to the health and safety of the public.

l Principal Contributor: Richard Pelton Ramin R. Assa l

l Date: July 24,1998 l

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