SNRC-1883, Application for Conforming Amend to License NPF-82, Authorizing Implementation of Util Decommissioning Plan Presently Pending Before NRC

Application for Conforming Amend to License NPF-82, Authorizing Implementation of Util Decommissioning Plan Presently Pending Before NRC

ML20087D275
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	01/13/1992
From:	Leslie Hill LONG ISLAND POWER AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LSNRC-1883, NUDOCS 9201160032
Download: ML20087D275 (6)

Text

Long Shorc; ham Nuclear Power Station -

istand P.O. Box 628 Power North Country Road Authcoty Wading River, N.Y.11792 LSNRC-1883 UANJB 1992

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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Applicat.on for an Amendment-to Facility Operating License NPF-82 Shoreham Nuclear Power Station - Unit 1 Docket No. 50-322-l Ref: (1) Long Island Power Authority, Shoreham Nuclear Power.

Station Decommissioning Plan (December 29, 1990)

I. Introduction Pursuant 1to 10 CFR 550.90,.Long Island: Power Authority: ("LIPA"), j with the support of the _ Long _ Island Lighting - Company -("LILCO") , .

hereby requests a conforming amendment to License =No. NPF-82, the Possession _Only License for the Shoreham NuclearfPower Station

("Shoreham"), to become effective as soon as possible after l Nuclear Regulatory. Commission-("NRC") _ approval of theLpending l Joint Application to Transfer the Shoreham Nuclear Power Station license from LILCO to LIPA, to reflect the NRC's approval of the Shoreham Decommissioning Plan (Ref. 1). The amendment would authorize implementation of the shoreham Decommissioning' Plan

! presently pending before.the NRC.

t By separate application dated June 28,[1990, LIPA1and LILCO.have d jointly sought approval of a license amendment authorizing .

l L transfer of License No. NPF-82 from LILCO-to LIPA. -In1 addition, l on December:29, 1990, LIPA submitted-_its Shoreham; Decommissioning l Plan, which LILCO-requested the NRC to review and approve by L . letter dated. January.2, 1991. After-nearly a-year of review, on-December 23,_1991, the NRC published notice;of-;itsf intent to-approve the Shoreham Decommissioning Plan. See-56 Fed. Reg.

l 66459' (1991). The requested amendment.would. allow LIPA, after'it L has become the licensee', to implement _that Shoreham '

Decommissioning; Plan.

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LSNRC-1883 Page 2 i LIPA further requests that this license amendment be effective upon issuance pursuant to 10 CFR S50.91(a) (4) , and that it be processed expeditiously in light of-the Commission's previous notice of intent to approve the. Decommissioning-Plan and the cost increases and other harm outlined below that would occur if decommissioning is delayed.

II. Description of the Proposed Amendment The proposed amendment would add a new provision to Section 2.C of License No. NPF-82, stating as follows:

"(4) Decommissioning Authorization The licensee is authorized to decommission Shoreham in accordance with (a) the Shoreham Decommissioning Plan submitted on December-29, 1990, as supplemented by letters dated August 26, 1991, November 27, 1991 and December 6, 1991, and (b) the Commission's rules and regulations."

III. No Significant Hazards Determination LIPA has performed a "no significant hazards consideration" analysis, assessing the proposed amendment using the standards set forth in 10 CFR $50.92 (c) . This analysis, as-presented in an attachment hereto, demonstrates that the proposed amendment does not involve a significant hazards consideration.

IV. Request for Expedited Processing LIPA requests that the Commission review and arrange for publication of the amendment at the earliest possible date. . The Decommissioning Plan has been on file with the Commission for over a year. The public interest requires that LIPA be free to commence decommissioning as soon as possible for the following reasons:

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1) Decommissioning activities are prioritized to. maximize-the  ;

ability to dispose of radioactive waste materials in 1992 because of the potential for denial-of access to licensed radioactive waste burial-facilities as of January 1,-1993.

This prioritization minimizes the quantity offradioactive waste that could be required to be stored at-the Shoreham site on an interim basis after 1992, as well aF the higher costs to.ratepayers which would likely be associated with offsite disposal after 1992.

LSNRC-1883 a

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2) Prolonged delay in the initiation of decommissioning, and hence, in the completion of decommissioning, will increase the costs to ratepayers because of the need to maintain station staffing levels over a longer period of time. Also, a prolonged delay in the start of decommissioning could result in additional costs from contractots who are now preparing to mobilize at the Shoreham site, as well as in the potential loss of availability of selected contractor personnel and/or equipment to other projects.

3) The project schedule currently takes advantage of the near-term availability of the Reactor Building Polar Crane for activities other than f'ael disposition. Once fuel disposition is underway (possibly as early as July 1992) the availability of the Polar Crane for other activities will be greatly reduced. Thus, the decommissioning project schedule would likely be extended.

Therefore, LIPA respectfully requests that this matter be processed as expeditiously as possible and noticed promptly in ,

the Federal Register, to avoid further delay in decommissioning.

Long Island Power Authority By LFM. 11111 Resident Manager Shoreham Nuclear Power' Station Subscribed and sworn to me this /J d day of January, 1992.

s k M Notary Public of New York My Commission Expires: Ma t/ /8, /N3

/

cc: D. Ross MMES A UTTLE S. Brown NOTARY PUBUC State of New York No. 4886267, Suffolk Coun T. T. Martin u 8,1 -

L. Doerflein J. D. Leonard, Jr.

L. Bel.1 B. Norris

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s Page 1 of 3 APPENDIX ANALYSIS OF NO SIGNIFICANT HAZARDS CONSIDERATION LIPA has performed a "no sigaificant hazards consideration" analysis, assessing the proposed-amendment using the standards set forth in 10 CFR 550.92(c). This analysis demonstrates that the proposed amendment does not involve a significant hazards consideration.

A. Requirements of 10 C.F.R. S 50.92.

Section 50.92 provides that the NRC may make a determination "that a proposed amendment to an operating license.. .. involves no significant hazards consideration" if " operation of the -

facility in accordance with the proposed amendment" would 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 previously evaluated; or (3) Involve a significant reduction ~in a margin of safety."

Decommissioning activities at Shoreham would_not involve a significant hazards consideration, as shown below.

B. Condition of Shoreham' Confirms No Significant- Hazards Given the limited operating history of-Shoreham-(less than'two effective full-power. days), the levels of-radioactivity-and amounts of contamination at Shoreham~are much lowerJthan at a plant that has operated for.a significant timeaat full power.

This greatly reduces the scope and. complexity of decommissioning.

activities. The Shoreham Decommissioning Plan contains an-Accident-Analysis for. decommissioning activities and for Spent.

Fuel' Storage and-Handling. .This analysis. establishes'that, given.

the defueled and non-operating. status of the plant-and 1 the limitations in the Technical Specifications applicable'to the plant, continued maintenance and decommissioning of Shoreham pose.-

minimal radiological risk.

The radiologically bounding accident -- a fuelL damage accident -- 3 is described _in Section 3.4.1.8 of the-Decommissioning Plan. l This.same postulated event wac~ analyzed-by LILCO-in its Defueled i Safety-Analysis Report-and reviewed'and approved by the NRC Staff in itsl Safety Evaluation Related to Amendment No'. 7 To Facility.

Operating License NPF-82 dated June 14, 1991._ Because this-

- postulated event is-still the applicablefradiologically_ bounding. i accident, the previous findings'of no significant hazard 1

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. Page 2 of 3 consideration remain valid. (See Section 4.0 of NRC Staff Safety Evaluation referenced above.) As further evidence.of the minimal-radiological risk associated with this bounding-postulated event, it is noted that the same bounding event also formed the basis r for NRC aut' 'ization to cease offsite emergency preparedness activities Shoreham, again, with a determination of no significant hazards consideration.

C. The Requirements of 10 CPR 550.92'Are Meb The following discussion-provides a specific analysis of the proposed change against-the three standards 1 delineated in 10 CFR-50.92. It confirms that-the proposed license amendment is administrative in nature, designed to achieve consistency _with the Commission's Decommissioning-Order to be issued in accordance r with 10 CFR 550.82(e), and therefore involves no matters that would' pose a signifi' cant ~ hazards consideration.

1. The Proposed Changes Does Not Involve a Significant Increase in the Probability _or' Consequences of an Accident Previously-Evaluated The proposed amendment will do-nothing more than authorize decommissioning of Shoreham in accordance_with the NRC approved Shoreham Decommissioning-Plan.- The Decommissioning Plan contains-accident analyses which already have been reviewed by=the NRC.

The amendment will in<no way alter the probability or consequences of the accidents previously analyzed in-the Decommissioning Plan, but will simply authorize-that those decommissioning activities be performed'according to the Plan.

The fuel will not.be further irradiated.- Theinon-operating,= ,

defueled_ condition of the reactor.further reduces the-probability of an operational accident. The~ potential accident consequences for the low burn-up fuel in the spent = fuel ~ pool 4have been analyzed assuming a fuel damage accident.- Further,'the analysis.

conservatively assumed maximum fission. product release (release '

of all fuel gap activity). All of the postulated-decommissioning accident analyses demonstrate that accident; consequences would be substantially lower than1the previous Updated SafetyfAnalysis Report (USAR) accident analyses results=and-well within-regulatory limits.

The fuel, radioactive waste and material will not_be' handled or.

treated in.a-different manner than assumed in previous safety analyses and evaluations. The small:nmounts of radioactive 1 waste and materials at Shoreham'are contained in systems-and components specifically_ designed for their control. Fuel handling'will.bef j performeu'by certified personnel,-with approved equipment and ,

approved procedures. The low burn-up fuel'is stored in the spent H fuel pool. Storage of the fuel in_any on-site' location other -

than the spent fuel pool would require a further-license amendment, i

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, Page 3 of 3 Therefore, the proposed amendment to NPF-82 does not involve a significant increase in the. probability or consequences of an accident previously evaluated.

? The Proposed Changec ','ll Not Create The Possibility of a New Different Kind of Accident from Any Accident r '~. Evaluated The proposed amendment ask i serntwaion to conduct activities in accordance wl: ' decommissioning plan.

Therefore, the amendment-by d<' , 't create the possibility of a new or dif fe vide;t from any previously evaluated.

Because the reactor will not be op _4ted, re is no possibility.

of any operation related accident. The only remaining potential accidents would involve fuel handling and radioactive material storage activities. The fuel and radioactive waste'and material will be handled or treated in the manner described in the Decommissioning Plan, and the amendment involves no modification to spent fuel pool. storage or handling systems. Licensee activities will include maintenance and decommissioning of certain systems according to the Shoreham' Decommissioning Ple.4 as approved by the NRC.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated by the NRC.

3. The Proposed Changes Do-Not Involve a Significant Reduction in a Margin of Safety The proposed amendmentLdoes not involve.a reduction-in-any margin of safety. As noted, the license amendment will permit.

decommissioning to_ occur as planned and approved and will be consistent with the Commission's regulations and orders. The margin of. safety reflected in the analyses presented in-the Decommissioning Plan are unaltered by this proposed' amendment.

The fuel handl4ng-and-radioactive' waste storage accidents'were reanalyzed-for the low-burn-up, decay ~ heat, and radioactive inventory conditions of Shoreham in,the Decommissioning. Plan.

These analyses confirmedia significant increase in~-the margin of-safety from those analyzed for long-term, full power operations-in the USAR.. Further, the Defueled Technical Specifications;and' Environmental Protection Plan provide acceptable assurance to protect the public health and' safety for the defueled condition.

As . indicated in the Decommissioning Plan, decommi ioning "

activities will be conducted-in accordance.with-the requirements of these documents..

Therefore, the proposed. amendment does not involve a significant' reduction-in the margin of safety.

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