ML18052B260

Application for Amend to License DPR-20,changing Tech Specs to Permit Movement of Heavy Loads Into Cask Laydown Area of Spent Fuel Pool for Compliance w/NUREG-0612.Fee Paid

ML18052B260
Person / Time
Site:	Palisades
Issue date:	09/01/1987
From:	Berry K, Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18052B261	List: ML18052B260 ML18052B263
References
RTR-NUREG-0612, RTR-NUREG-612 GL-81-07, GL-81-7, GL-85-11, NUDOCS 8709100114
Download: ML18052B260 (6)

Text

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consumers Power Kenneth W Berry

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. . . . .Ill"' - POWERINli Director MICHlliAN'S PllOliRESS Nuclear Licensing General Offices: 1945 West Parnell Road, Jackson, Ml 49201 * (517) 788-1636 September 1, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

TECHNICAL SPECIFICATIONS CHANGE REQUEST - MOVEMENT OF HEAVY LOADS This change to the Palisades Technical Specifications is necessary to permit removal of radioactive waste from the Palisades spent fuel pool and to align*

the requirements of the Palisades Technical Specifications with the guidelines of NUREG-0612.

Specifically this proposed Technical Specification Change permits movement of heavy loads into the cask laydown area of the spent fuel pool and consolidates Technical Specification requirements regarding heavy loads in one section which requires compliance with the intent of the guidelines of NUREG-0612.

Attachment 1 contains a description of the proposed Technical Specification Changes and an evaluation which finds that this proposed change does not involve a significant hazard. Attachment 2 contains the proposed Technical Specification page changes. Attachment 3 contains alternate interim Technical Specification page changes. 1 If approval of the Technical Specification page changes as proposed in Attachment 2 cannot be approved before October 15, 1987, we request Attachment 3 be reviewed and approved in an expedited manner to permit movement of a 12-ton shielded cask into the cask laydown area of the spent fuel pool for the removal of non-fuel bearing radioactive waste.

A check for $150.00 as required by 10CFR170.21 is included. The proposed Technical Specification will become effective upon issuance.

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• I Kenneth W Berry P * ** * *PDR L_\

Director, Nuclear Licensing_

CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachment OC0287-0223-NL04

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CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I and, if necessary as an Interim Alternative,Section III of this request.

I. Changes Proposed in Attachment 2 The proposed changes to Technical Specifications described in this section are necessary to update Technical Specifications which, for the most part, have been in existence since before implementation of the guidelines of NUREG-0612. In addition, the proposed changes also allow more efficient use of the existing storage pool by permitting movement of heavy loads into the cask loading area. The proposed changes are briefly described below and are identified in Attachment 2 by a vertical line in the right hand margin.

A. Specification 3.13 - is deleted in its entirety.

B. Specification 3.21 - is replaced in its entirety - refer to page changes.

C. Specification 5.4.2.h - is deleted.

II. Discussion Regarding Changes Prepared in Attachment 2 The July 1980 publication of NUREG-0612 "Control of Heavy Loads at Nuclear Power Plants" and implementation of its guidelines as requested by NRC letters dated December 22, 1980, February 3, 1981 (Generic Letter 81-07), and June 28, 1985 (Generic Letter 85-11) have standardized the methods and requirements for moving heavy loads at nuclear power plants.

Standardization has increased the margin of safety associated with the movement of heavy loads. The Technical Specification changes proposed in this request delete pre-NUREG-0612 technical specifications limitations regarding movement of heavy loads and replace them with widely applicable limitations which comply with the intent of NUREG-0612 and ensure that the potential for a load drop is extremely small or require proof by analysis that the intent of the criteria of Section 5.1 of NUREG-0612 are satisfied.

Because of the Palisades physical layo~t, it is necessary to carry heavy loads over fuel stored in the north tilt pit zone of the spent fuel pool. Analysis shows that a certain amount of decay time must elapse before it is permissible to move heavy loads over fuel stored in the TSOP0287-0223-NL04

TSCR - Movement of Heavy Loads 2 Palisades Plant north tilt pit zone of the spent fuel pool without decreasing the margin

~-=-~~~~~of. safety_.~Those decay time requirements have been incorporated into heavy load procedures.

In accordance with reference 2 which states that area type load paths inside containment are not likely to be consistent with the intent of the Guidelines of NUREG-0612 and because the existing 19-foot radius area restriction causes some loads to be lifted to otherwise unnecessary heights in order to clear obstructions whereas if those loads could move within 19 feet of the reactor center (but not over the reactor) the margin of safety would be increased, the 19-foot radius exclusion area around the centerline of the reactor has been deleted.

The prohibition of moving spent fuel casks into the fuel storage building until the NRC has approved the 1974 cask drop analysis has been deleted because approval of this Technical Specification Change Request will require the NRC to review that cask drop analysis or to rule that in view of information contained in Generic Letter 85-11, such review and approval is unnecessary.

The existing maximum 6 inches of clearance requirement between heavy loads and the floor or other obstructions has been deleted because that requirement has been included in Palisades Plant Heavy Load Procedures.

Other changes to the existing limitations in Technical Specifications 3.13, 3.21 and 5.4.2.h, as they are incorporated into proposed Technical.

Specification 3.21, are enveloped by the required compliance with the objectives of the guidelines of NUREG-0612.

Analysis of No Significant Hazards Consideration in Regard to Changes Proposed in Attachment 2 Consumers Power Company finds that activities associated with this change request involve no significant hazards and, accordingly, a no significant hazards determination per 10CFR50.92(c) is justified. The following evaluation supports that finding.

Evaluation (1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The only accident involved is that of a load drop. Since the load drops postulated in accidents previously evaluated have not changed, the consequences of a previously evaluated accident have not increased. The probability of a load drop is decreased when the guidelines of NUREG-0612 are followed.

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

The changes proposed in this change request do not introduce the use of different load handling equipment than previously evaluated.

The only types of accident involved are those of heavy load drops.

TSOP0287-0223-NL04

TSCR - Movement of Heavy Loads 3 Palisades Plant They have been evaluated against applicable existing criteria.

Thus,__the possibility of a new or different kind of accident is not created.

(3) Involve a significant reduction in a margin of safety.

The proposed changes decrease the probability of an accident by requiring compliance with the intent of the guidelines of NUREG-0612 and by prohibiting the movement of heavy loads over fuel stored in the main pool zone. Thus, the margin of safety would not be reduced.

III. Changes Proposed as Alternate Interim Changes in Attachment 3 The alternate interim changes proposed in this section may be necessary to permit the timely removal of non-fuel bearing (NFB) radioactive waste from the Palisades spent fuel pool. The proposed changes briefly described below are identified in Attachment 3 by a vertical line in the right hand margin. This alternative should not be selected if the preferred change described in Attachment 2 is approved prior to October 15, 1987.

A. Specification 3.21 - The spent fuel pool is more clearly defined.

B. Specification 3.21.1 - - Permits movement of a shielded cask over the cask laydown area and deletes area type exclusions inside containment.

IV. Discussion Regarding Changes Proposed in Attachment 3 The proposed alternate interim changes described in this section only affect existing Technical Specification 3.21 and are necessary for removal of non-fuel bearing (NFB) radioactive waste from the main pool zone of the spent fuel pool by permitting movement of a 12-ton cask over the cask laydown area. The changes proposed in this section will be deleted when the changes proposed in Attachment 2 are approved.

Reasonably expedited approval of this alternate proposal is requested_ to allow removal of NFB radioactive waste from the spent fuel pool before the classification of low level waste is changed and to eliminate conditions which require the storage of NFB radioactive waste in canisters placed in areas of the main pool zone where they could interfere with the.movement of fuel assemblies. Under existing classification, the NFB radioactive waste in the Palisades SFP can be buried at existing sites. A change in NFB radioactive waste classification may cause this waste to be disposed of in a different, more expensive, and time consuming manner.

In addition, this proposed change deletes the 19-foot radius area restriction around the reactor vessel. The existing 19-foot restriction causes the shielded cask to be lifted to otherwise unnecessary heights TSOP0287-0223-NL04

TSCR - Movement of Heavy Loads 4 Palisades Plant in order to clear obstructions whereas if the cask could move within

--'--________ 19 feet-Of-the reactor center (but not over the reactor) the margin of safety would be increased. As stated in Reference 2, area type restrictions in containment are not likely to be consistent with the intent of the guidelines of NUREG-0612. Movement of a shielded shipping cask inside containment is restricted by load paths contained in Palisades Plant permanent maintenance procedures.

The weight of the affected cask has been increased from 10 to 12 tons to more accurately reflect actual cask weight.

• The same cask is involved and actually weighs 12 tons when the cover and liner weights are included. It is generically referred to as a 10-ton cask. The applicability statement has been changed to increase the area of coverage to include all 12-ton shielded cask movement in the fuel pool building. Existing technical specifications apply only to 10-ton cask movement through the fuel pool building.

V. No Significant Hazards Consideration in Regard to Changes Proposed in Attachment 3 (1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The only accident involved is that of a load drop. Since the load drops postulated in accidents previously evaluated have not changed, the consequences of a previously evaluated accident have not increased. The probability of a load drop is decreased when the guidelines of NUREG~0612 are followed.

The only type of accident involved is that of a cask drop. The cask involved by this change weighs less than the cask postulated in a previously evaluated accident (Reference 1) although it could strike the pool floor at a sharper angle than the previously evaluated 25-ton cask. Since the time when the 25-ton cask drop was evaluated, a 104-inch square concrete and stainless steel pad, 8-1/2 inches thick, has been installed over the impact area. It is reasonable to assume that the consequences of dropping a 12-ton cask at an angular impact area on the pad described above are less than the consequences from the impact postulated in the 25-ton cask drop directly on the pool floor. Thus, there is no increase in the consequences of an accident previously evaluated. The probability of dropping a cask does not increase since compliance with the intent of NUREG-0612 makes the probability of a cask drop extremely small.

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

The changes proposed in this change request do not introduce the use of different load handling equipment than that previously evaluated. The only type of accident involved is that of a cask drop and that has been previously evaluated. Thus, the possibility of a new or different kind of accident is not created.

TSOP0287~0223-NL04

TSCR - Movement of Heavy Loads 5 Palisades Plant (3) Involve a significant reduction in a margin of safety.

Reference 1 shows that if a 25-ton cask, 50 inches in diameter, were to directly strike the pool floor in the cask laydown area and impact that floor throughout a 50-irtch diameter impact area, the

.3/16-inch stainless steel pool liner plate would be punctured so as to cause leakage less than the borated water makeup capability and that the pool structure would not be damaged. As previously stated above, after that analysis was completed, a 104-inch square impact pad (8~ inches thick and made up of 7~ inches of concrete sandwiched between two 1/2-inch stainless steel plates) was installed on top of the pool floor in the cask laydown area. It is reasonable to assume that a 12-ton cask impacting that pad, even with initial point contact located directly below the cask center of gravity, would not cause as much damage to the pool liner as would the previously evaluated 25-ton cask drop. Therefore, the margin of safety is not reduced.

VI. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specification Change Request and has determined that this change does not involve an unreviewed safety question and therefore involves no significant hazards consideration. This change has also been reviewed under the cognizance of the Nuclear Safety Board. A copy of this Technical Specification Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

References:

1. August 1974 Bechtel Evaluation of Postulated Cask Drop Accident.

2. NRC letter dated May 4, 1983 from L S Rub~nstein to G C Lainas, subject - "Control of Heavy Loads - Phase I" CONSUMERS POWER COMPANY Buckman, Vice P Nuclear Operations Sworn and subscribed to before me this 1st day of September 1987.

~0~Elaine E Buehrer, Notary Public Jackson County, Michigan My commission expires October 31, 1989 TSOP0287-0223-NL04