ML20245F844

Proposed License Conditions D & H,Reflecting Changes,Per Rev 10 to Physical Security Plan

ML20245F844
Person / Time
Site:	Indian Point
Issue date:	07/25/1989
From:	CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:
Shared Package
ML19064A018	List: ML20245F841 ML20245F844
References
NUDOCS 8908150096
Download: ML20245F844 (7)

Text

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Attachment A License Condition Changes Consolidated Edison Company of New York, Inc.

Indian Point Unito Nos. 1 and 2 Docket Nos. 50-03 and 50-247 July, 1989 PDR 890725 P 89081500hO500000 ADO PNV 3 ;;'

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7.n addition to th'osa.'otherwiis requ' ired undar this license and applicable regulations {. consolidated shall keep the following

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.(1)~ Esaccor. operating:recordsd including' power levels o and pcriod

, of . operation at, sach power:, level. .- ,

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.{2)/ Racorda,'s, showing.fET. ': @ . l' +:' . b..' . . .:.,tha radioactivity *raleased: or diacharged inco.

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.l* the. 'ais;jr .wa'taryiyondFehe effective contrar of Consolidac'ed

as mecsured.acM.pitor'.to[tha; point o'f. such ' release or ' dis-

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,., (3) .Racords'?of'acrams e including' reasons therefor.' .

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_c (4), ' Records of principal maintensuca operations involving sub- .

.. , . stitucion'orr,eplaceanc. of' facility equipment or.' 'components -

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u.... a J/ : . i (5).. 24 cords, of, radioactivity .E.asurements at on-site and, dff-site

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(6) Records of facility.csstacand' measurements performed pursuant

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to tho._ reg iremen,ts.of the Technical. Specifications., , ' , ;,, ,, ,

D. Consolidated Edison shall fully implement and maintain in effect all provisions of the Comission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions.to 10 CFR 73.55 (51 FR 27817 and 27822) and-to the au'thority. of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR -

73.21, are entitled: " Indian Point Station Units 1 and 2 Physica1 _ _ .

Security Plan," with revisions su,bmitted through January 24, 1989;' .

" Indian Point Station Unit 1 and 2 Security Training and Qualification Plan " with revisions submitted through December 8, 1986; and " Indian Point Station Unit 1 and 2 Safeguards Contingency Plan " with revisions submitted through Huv wber 7, 1986. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein. -

i E Deleted by Amendment No. 39. .

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s F Deleted by Amendment No. 37.

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E. This amendment deletes paragraph 2.E from the license.

This license amendment became effective May 14, 1981.

v F. This amended license is also subject to appropriate conditions imposed by the New York State Department of Environmental Conservation in its letter of September 24, 1973, to Consolidated Edison Company of New York, Inc., granting a Section 401 certification under the Federal Water Pollution Control Act amendments of 1972.

C. Pursuant to Section 50.60 of 10 CFR Part 50, paragraph 4 of Provisional Construction Permit No. CPPR-21 allocating quantities {

of special nuclear material, together with the related estimated schedules contained in Appendix A attached to said provisional construction permit, shall remain in effect.  !

H. Consolidated Edison shall fully implement and maintain in effect all provisions of the Commission-approved physical security, guard training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10

, CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR

,_, 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: " Indian Point Station Units 1 and 2 Physical Security Plan," with revisions submitted through January 24,1989;" Indian Point Station j Unit 1 and 2 Security Training and Qualification Plan," with revisions submitted through December 8, 1986; and " Indian Point Station Unit 1 and 2 Safeguards Contingency Plan," with revisions o

submitted through November 7, 1986. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the j schedule set forth therein.  !

I. Deleted by Amendment No.133. .

I J. Deleted by Amendment No.133.

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4 Attachment B. .j Safety Assessment l

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r Consolidated T.dison Company of New York, Inc.

.. Indian Point Units Nos. 1 and 2 Docket Nos. 50-03 and 50-247 j July, 1989 I

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SAFETY REVIEW ,

The proposed revision to' the~ Indian Point' Unit Nos.1 and 2 Physical Security Plan is based on the results of. a study completed in October,1987 entitled " Vital Area Assessment of Indian Point Station Unit No. 2." The results of this study were contained in our January 24, 1989 submittal and it was conducted in ' order to enhance both plant security and operating flexibility by utilizing the methodology currently used by the NRC in making such vital area evaluations.

Several vital' areas at Indian Point 2 have been redefined as Type I rather than Type II and vice versa, and several changes are being made in the interest of clarification . and standardization of termi nology. An additional proposed change .is to remove the Boric Acid Storage Tanks, Pipe Support Structure, M.G. sets and D.C.

Inverters, Tank Pit, Primary Water Storage Tank and the City Water Tank from the list of vital equipment although all but the. City Water Tank will remain in vital areas.

There are no security plan degradations associated with the reclassification of vital area Types . since the level of security afforded each Type at Indian Point No. 2 is identical . Such nomenclature changes, as well as changes made for purposes of clarification or terminology standardization, result in no functional alterations and thereby do not affect the level of safety maintained at the plant.

The Boric Acid Storage Tanks, the Pipe Support Structure, the M.G.

sets and D.C. Inverters, the Tank Pit and the Primary Water. Storage Tank are being deleted from Table 3.2 per the recommendations of the Vital Area Assessment, but they will remain in vital areas and therefore not be functionally altered.

The 1.5 million gallon City Water Storage Tank serves as a source of )

water for the Fire Protection System and as a backup water source to )

the Condensate Storage' Tank, and as a backup to certain equipment cooling syt i. ems. It does not directly mitigate any postulated sabotage scenario and its failure cannot initiate any accident that could adversely affect the health and safety of the general public.

The City Water Tank, therefore, does not constitute vital equipment as defined in 10 CFR 73.2 and it is therefore not necessary to be located in a Vital Area. Its deletion as a Vital Area does not decrease its capability to function in all its intended uses. Were it to be severely damaged or destroyed, the plant would be required by Technical Specifications to proceed to an orderly shutdown.

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i h BASIS FOR DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided guidance concerning the application of the ' standards for determining whether "significant hazards '

considerations" exist by providing certain examples at 51FR 7744 (March 6 1986). Example (i) of 51 FR 7744 which applies ~ to editorial changes, states:

"(i) a purely admini strative change to technical spc'cificatione r for exampl e. a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature."

Although the : example cited in 51 FR 7744 refers specifically to i proposed change to technical specifications, it is understood that the ' intent of the guidance is that it apply to license amendment changes, in general, including Physical Security Plan changes such as  !

proposed herein. With the exception of the proposed change to delete 1 the City Water Tank from table 3.2, the changes to the Physical Security Plan proposed in this application are shown not to involve a significant hazards consideration by reason of the guidance in example (1) above since they amount to merely administrative. changes i such that there are no functional alternatives being made. Note that the level of security afforded Type I and Type II vital areas at Indian Point is identical and this policy will not change without another amendment request. Likewise, the deletion of items, other than the City Water Tank,. from the list of vital equipment will not alter their physical location within vital areas.

Concerning the remaining proposed change, the Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating i license for a facility involves no significant hazards consideration I if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the l probability or consequences of an accident previously evaluated; (2) {

create the possibility of a new or different kind of accident from '

any accident previously evaluated; or (3) invol ve a significant reduction in a margin of safety. The proposed amendments have been evaluated below and determined not to involve a Significant Hazards Consideration.

1 (1) Do the croposed changes involve a significant increase in the probability or consequence of an accident previously evaluated? ]

No. The City Water Tank is utilized for normal plant operation and may be used as a backup to safety equipment cooling. Its damage or destruction woul d not cause or increase the probability or consequences of an accident since safety-related vital equipment would not be affected by such sabotage and would, therefore, remain operable. Therefore, since sabotage in a non-vital area can be assumed to be successful but safety-related equipment in vital areas is assumed to operate as required, the deletion of thi s item from the list of vital equipment would not invol ve a significant increase in the j probability or consequences of an accident previously evaluated.  !

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i (2) ' Do the proposed changes create the possibility of a new or

! different kind of accident from any accident previously l evaluated?

No. Deletion of this item from the vital equipment list implies that we must assume its inoperability in the event of successful sabotage. Such inoperability, caused by damage or destruction, would be serious enough to cause reactor shutdown as required by Technical Specifications but would not result in any previously unanalyzed accident. Overall plant design is such that adequate safety-related equipment and cooling to that equipment exists to bring the plant to a safe shutdown and assure that escalation of an accident beyond the damage to thi s non-vital piece of equipment would not occur. Successful sabotage of the item deleted from the list of vital equipment with this proposed revision would, therefore, not create the possibility of a new or different kind of accident from any accident previously evaluated.

(3) Do the proposed changes involve a significant reduction in the margin of safety?

No. Deletion of this item from the vital equipment list and its subsequent inoperability or destruction due to successful sabotage could yield a forced pl ant shutdown as required by Technical Specifications. The other consequences of such sabotage would be the elimination of certain backup systems which are not required or relied upon for accident prevention or mitigation purposes. This effect would not be a significant one since the functionally equivalent safety-related vital equipment would not be adversely affected. Therefore, the overall margin of safety would not be significantly reduced.

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