ML20310A279
| ML20310A279 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/05/2020 |
| From: | Welsch J Pacific Gas & Electric Co |
| To: | Samson Lee NRC/NRR/DORL/LPL4 |
| Lee S, 301-415-3158 | |
| References | |
| L-2020-LRM-0101 | |
| Download: ML20310A279 (22) | |
Text
Diablo Canyon Power Plant Pre-Application Meeting License Amendment Request to Revise License Conditions and Technical Specifications to Reflect the Permanently Defueled Condition Presented by:
Philippe Soenen - Decommissioning Environmental and Licensing Manager
Meeting Purpose / Goals
- Provide preliminary information regarding a proposed License Amendment Request (LAR) to revise the Diablo Canyon Power Plant (DCPP) Units 1 and 2 Licenses and Technical Specifications to reflect a permanently defueled condition.
- Walkthrough the changes to the Licenses and Technical Specifications resulting from the reduction in risk in a permanently defueled condition.
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DCPP Decommissioning Planning
- On November 27, 2018, PG&E notified the NRC of the intent to permanently cease operations at DCPP Units 1 and 2 upon expiration of the operating licenses.
- DCPP Unit 1 license expires November 2, 2024
- DCPP Unit 2 license expires August 26, 2025
- PG&E is currently working on decommissioning planning activities necessary to support direct transition to decommissioning upon permanent cessation of operations.
- Including submittal of LARs to support Decommissioning.
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Background
- Once PG&E certifies the fuel is permanently removed from the reactors, the licenses for DCPP Units 1 and 2 will no longer authorize operation of the reactors or placement of fuel in the reactor vessels.
- The licenses and Technical Specifications are proposed for revision to reflect this permanently defueled condition.
- The majority of the existing Technical Specifications and associated testing requirements are only applicable with the reactor in an operational mode and therefore are proposed for deletion.
- The spent nuclear fuel (SNF) will be stored in the Independent Spent Fuel Storage Installation (ISFSI) and the spent fuel pools until all SNF is transferred 4
to the ISFSI.
Conditions for Implementation
- The proposed changes will not be applicable until permanent cessation of operations and once the following conditions have been met for DCPP Units 1 and 2:
- Docketing of the certifications required by 10 CFR 50.82(a)(1)
(i and ii) for DCPP Units 1 and 2
- DCPP Units 1 and 2 have both been shutdown for at least 45 days
- A Certified Fuel Handler training and retraining program has been implemented in accordance with 10 CFR 50.2 5
Evaluation of Potential Design Basis Accidents
- Evaluates all of the Updated Final Safety Analysis Report, Chapter 15 and Chapter 11 tank rupture accidents
- Detailed Discussion of the remaining potential design basis accidents
- Tank ruptures - current evaluations are bounding for decommissioning
- Fuel Handling Accident (FHA) in the Fuel Handling Building
- Does not rely on any active systems as part of the initial conditions of the analysis or as part of the primary success path for mitigation of the accident
- PG&E can implement the revised FHA and the PDTS 45 days after both Units have been shutdown and is requesting up to 180 days to implement 6
Review of General Design Criteria
- Detailed Review of the General Design Criteria (GDC)
- Includes a review of commitments to the 1967 GDCs (plus later commitments) and conformance to the intent of the 1971 GDCs
- Categorizes the GDCs into the following four categories; A. No Longer Applies B. Unchanged C. Minor Change D. Major Change 7
Proposed Changes to the Operating Licenses
- Updates language to reflect permanently shutdown and defueled condition
- Deletes historical license conditions that were previously satisfied 8
Proposed Changes to the Operating Licenses
- New License Conditions
- If all spent fuel has not been removed from the Unit 1 spent fuel pool prior to November 2, 2028, an aging management program shall be submitted prior to this date for NRC approval.
- If all spent fuel has not been removed from the Unit 2 spent fuel pool prior to August 26, 2029, an aging management program shall be submitted prior to this date for NRC approval.
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Appendix D, Additional Conditions
- Appendix D, Additional Conditions includes complex implementation activities for LARs
- Proposed for deletion in its entirety because all implementation activities were previously completed 10
Proposed Changes to Technical Specifications TS Section Summary of Changes 1.0 Use and Application Updates definitions (added Certified Fuel Handler and Non-Certified Operator), removes descriptions, examples, and terms no longer applicable in the permanently defueled condition. Revises examples in Section 1.4, Frequency to align with the remaining TSs.
2.0 Safety Limits Proposed for deletion.
3.0 Limiting Condition for Operation Revises LCO 3.0.1 and 3.0.2 to remove terms, references Applicability and descriptions no longer applicable in the permanently defueled condition. LCOs 3.0.3 through 3.0.8 are proposed for deletion.
3.0 Surveillance Requirement Revises SR 3.0.1 through 3.0.4 to remove terms, Applicability references and descriptions no longer applicable in the permanently defueled condition.
3.1 Reactivity Control Systems Proposed for deletion 3.2 Power Distribution Limits Proposed for deletion 11
Proposed Changes to Technical Specifications TS Section Summary of Changes 3.3 Instrumentation Proposed for deletion 3.4 Reactor Coolant Proposed for deletion System 3.5 Emergency Core Proposed for deletion Cooling Systems 3.6 Containment Systems Proposed for deletion 3.7 Plant Systems TS 3.7.15, Spent Fuel Pool Water Level - Deletes note associated with LCO 3.0.3 and added SR frequency.
TS 3.7.16, Spent Fuel Pool Boron Concentration - Deletes note associated with LCO 3.0.3 and added SR frequency.
TS 3.7.17, Spent Fuel Assembly Storage - Revises LCO to remove reference to historical conditions only applicable for Cycles 14-16, including associated Figure and deletes note associated with LCO 3.0.3.
All other 3.7 TS are proposed for deletion. 12
Proposed Changes to Technical Specifications TS Section Summary of Changes TS 3.8 Electrical Power Proposed for deletion Systems TS 3.9 Refueling Proposed for deletion Operations TS 4.0 Design Features 4.2 Reactor Core - proposed for deletion 4.3 Fuel Storage - deletes design information associated with the new fuel storage racks and deletes historical design information only applicable for Cycles 14-16.
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Proposed Changes to Administrative Technical Specifications TS Section Summary of Changes 5.1 Responsibility Updates terminology, removes Shift Foreman responsibilities and adds Shift Supervisor 5.2 Organization Updates terminology, adds minimum on duty shift requirements, deletes requirements no longer applicable in the permanently defueled condition, and adds responsibilities for the Certified Fuel Handlers 5.3 Unit Staff Qualifications Updates terminology, removes reference to the updated FSAR and adds a requirement for maintaining a training and retraining program for Certified Fuel Handlers 5.4 Procedures Specifies the applicability of the TS to the safe storage of spent nuclear fuel and deletes the requirement for emergency operating procedures required to implement the requirements of NUREG-0737 and NUREG-0737, Supplement 1 14
Proposed Changes to Administrative Technical Specifications TS Section Summary of Changes 5.5 Programs and Manuals 5.5.2 Primary Coolant Sources Outside Proposed for deletion Containment 5.5.4 Radioactive Effluent Controls Program Updates terminology 5.5.5 Component Cyclic or Transient Limit Proposed for deletion 5.5.7 Reactor Coolant Pump Flywheel Proposed for deletion Inspection Program 5.5.8 Inservice Testing Program Proposed for deletion 5.5.9 Steam Generator (SG) Tube Inspection Proposed for deletion Program 5.5.10 Secondary Water Chemistry Program Proposed for deletion 5.5.11 Ventilation Filter Testing Program Proposed for deletion 15
Proposed Changes to Administrative Technical Specifications TS Section Summary of Changes 5.5 Programs and Manuals (continued) 5.5.13 Diesel Fuel Oil Testing Program Proposed for deletion 5.5.15 Safety Function Determination Proposed for deletion Program (SFDP) 5.5.16 Containment Leakage Rate Testing Proposed for deletion Program 5.5.17 Battery Monitoring and Maintenance Proposed for deletion Program 5.5.18 Surveillance Frequency Control Proposed for deletion Program 5.5.19 Control Room Envelop Habitability Proposed for deletion Program 16
Proposed Changes to Administrative Technical Specifications TS Section Summary of Changes 5.6 Reporting Requirements 5.6.2 Annual Radiological Environmental Updates terminology Operating Report 5.6.3 Radioactive Effluent Release Report Updates terminology 5.6.5 Core Operating Limits Report (COLR) Proposed for deletion 5.6.6 Reactor Coolant System (RCS) Pressure Proposed for deletion and Temperature Limits Report (PTLR) 5.6.8 PAM Report Proposed for deletion 5.6.10 Steam Generator (SG) Tube Inspection Proposed for deletion Report 17
Regulatory Analysis
- Applicable Regulatory Requirements/Criteria
- 10 CFR 50.82, Termination of license
- 10 CFR 50.36, Technical Specifications
- 10 CFR 50.48, Fire Protection
- PG&E is evaluating the guidance included in proposed Regulatory Guide 1.191, Revision 1, for licensees with approved NFPA 805 programs to transition the program to meet the requirements of 10 CFR 50.48(f)
- DCPP Units 1 and 2 Design Basis Accidents
- 10 CFR 50.51, Continuation of Licenses 18
Regulatory Analysis Continued
- Applicable Regulatory Requirements/Criteria
- 10 CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Reactors
- 10 CFR 50.62, Requirements for Reduction of Risk from Anticipated Transients Without Scram (ATWS) Events for Light-Water-Cooled Nuclear Power Plants
- 10 CFR 50.54(m), Minimum Requirements Per Shift for On-Site Staffing of Nuclear Power Units by Operators and Senior Operators Licensed Under 10 CFR Part 55 19
Regulatory Analysis
- Precedent
- Davis-Besse Nuclear Power Station- Submittal and request for additional information, however license amendment request was withdrawn prior to NRC approval
- Three Mile Island Nuclear Station
- Oyster Creek Nuclear Generating Station
- Fort Calhoun Station
- Crystal River Nuclear Power Plant (License Condition for Aging Management) 20
Attachments Attachments Proposed Facility Operating License Changes (DPR-80 and DPR-82) - Markup Proposed Changes to Additional Conditions - Markup Proposed Technical Specification Changes - Markup Proposed Technical Specification Bases Changes - Markup (for information only)
Proposed Facility Operating License Changes (DPR-80 and DPR-82) - Clean Proposed Technical Specifications - Clean Proposed Technical Specification Bases - Clean (for information only)
- Additional Conditions - appendix deleted in its entirety, no clean version provided
- Technical Specifications in Section 3.1 through 3.9 that are completely deleted are shown only in the markup of the Table of Contents
- Technical Specifications are intentionally not renumbered
- Technical Specification bases completely deleted are shown only in the markup of the Table of Contents 21
Thank You