ML15261A603

Biweekly Notice - Propose Crystal River Emergency Plan Change in Support of ISFSI

ML15261A603
Person / Time
Site:	Crystal River
Issue date:	09/23/2015
From:	John Hickman Reactor Decommissioning Branch
To:	Office of Nuclear Material Safety and Safeguards
John B. Hickman
References
TAC L53072
Download: ML15261A603 (7)

Text

September 23, 2015

MEMORANDUM TO: Biweekly Notice Coordinator FROM: John B. Hickman, Project Manager /RA/ Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards

SUBJECT:

REQUEST FOR PUBLICATION IN BIWEEKLY FR NOTICE - NOTICE OF CONSIDERATION OF ISSUANCE OF AMENDMENT TO FACILITY OPERATING LICENSE, PROPOSED NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION, AND OPPORTUNITY FOR A HEARING (TAC NO. L53072)

Duke Energy Florida, Inc. (DEF), et al., Docket No. 50-302, Crystal River Unit 3 Nuclear Generating Plant (CR-3), Citrus County, Florida Date of amendment request: August 27, 2015. A publicly available version is in ADAMS under Accession No. ML15246A231. Description of amendment request: The amendment would approve changes to the Permanently Defueled Emergency Plan (PDEP) to reflect the planned use of an Independent Spent Fuel Storage Installation (ISFSI) located in the Crystal River Unit 3 Nuclear Plant (CR-3) Protected Area while the spent fuel pool contains spent fuel assemblies. Basis for proposed no significant hazards consideration determination: As required by 10 CFR 50.91(a), the licensee has provided its analysis of the issue of no significant hazards consideration, which is presented below:

Biweekly Notice Coordinator 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

The proposed site PDEP and PD EAL Bases Manual revisions are commensurate with the on-going and anticipated reduction in radiological source term at the CR-3 site and reflects the addition of spent fuel being transferred to the ISFSI facility. These changes add the responsibility for responding to ISFSI emergencies to the CR-3 PDEP Shift Supervisor/Certified Fuel Handler, and accompanying changes to the PD EAL Bases Manual due to the creation of a potential or actual release path to the environment, degradation of one or more storage canisters or fuel assemblies due to environmental factors, and configuration changes that could cause challenges in removing the canister or fuel from storage.

There are no longer design basis accidents or postulated beyond design basis accidents that could result in doses to the public and the environment beyond the exclusion area boundary that would exceed the EPA PAGs. CR-3 was shut down on September 26, 2009, and will not be restarted. With the reactor permanently defueled, the spent fuel pool and its support systems are dedicated to spent fuel storage only. With the spent fuel in wet storage for some time, the spectrum of postulated accidents is much smaller than for an operational plant, with the majority of design basis accidents no longer possible. The only remaining credible design basis accident is the fuel handling accident, which does not result in exceeding the EPA Protective Action Guidelines at the exclusion area boundary. Spent fuel located in the spent fuel pools will be transferred to the ISFSI facility. Emergency Planning Zones beyond the exclusion area boundary and the associated protective actions are no longer required. No corporate personnel, personnel involved in off-site dose projections, or personnel with special qualifications are required to augment the ERO.

The credible events for the ISFSI facility remain unchanged. The indications of damage to a loaded Dry Shielded Canister CONFINEMENT BOUNDARY have been revised to be twice the design basis dose rate as described in Draft Amendment 14 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Modular Storage System, Sections 5.2.4 'Radiation Protection Program' and 5.4.2 HSM or HSM-H Dose Rate Evaluation Program (Reference 7), while in transit or HSM storage.

Damage to Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by the following on-contact radiation readings at some prescribed distance from the transfer cask or HSM: 1300 mrem/hr (gamma + neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI horizontal storage module (HSM)

Biweekly Notice Coordinator OR 1050 mrem/hr (gamma + neutron) - HSM Front Bird Screen 4 mrem/hr (gamma + neutron) - HSM Outside Door 40 mrem/hr (gamma + neutron) - HSM End Shield Wall Exterior while in HSM storage. This change is consistent with industry practices previously approved by the U.S. Nuclear Regulatory Commission (NRC) to distinguish whether a degraded containment barrier condition exists.

The probability of occurrence of previously evaluated accidents is not increased, since most previously analyzed accidents can no longer occur and the probability of the remaining credible design basis accident is unaffected by the proposed amendment.

The deletion of the Communicator position does not impact Emergency Notifications from the plant since the Emergency Coordinator has shown the capability to perform this function. This function is not involved in operations or evolutions that could cause an accident since it is not performed until after the emergency is declared, and has no effect on accident mitigation. Therefore, the proposed changes do not affect any plant system, the operation and maintenance of CR-3 and the ISFSI facility, or increase the probability or consequences of an accident previously evaluated.

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

Response: No

The proposed changes have no impact on facility structures, systems, or components (SSCs) affecting the safe storage of irradiated fuel, or on the methods of operation of such SSCs, or on the handling and storage of irradiated fuel itself. Additionally, the proposed changes have no impact on a Fuel Handling Accident, which is the remaining credible design basis accident evaluated. The CR-3 PDEP is applicable for the plant's defueled condition. There is no impact on the prevention, diagnosis, or mitigation of reactor-related transients as there are no longer any reactor-related accidents. Accidents cannot result in different or more adverse failure modes or accidents than previously evaluated because the reactor is permanently shut down and defueled, and CR-3 is no longer authorized to operate the reactor. There are no longer credible events that would result in doses to the public beyond the exclusion area boundary that would exceed the EPA PAGs. Spent fuel waste will be transferred to the ISFSI facility.

Emergency Planning Zones beyond the site boundary and the associated Biweekly Notice Coordinator protective actions are no longer required. No corporate personnel, personnel involved in offsite dose projections, or personnel with special qualifications are required to augment the ERO.

The credible events for the ISFSI facility remain unchanged. The indications of damage to a loaded Dry Shielded Canister CONFINEMENT BOUNDARY have been revised to be twice the design basis dose rate as described in Draft Amendment 14 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Modular Storage System, Sections 5.2.4 'Radiation Protection Program' and 5.4.2 HSM or HSM-H Dose Rate Evaluation Program (Reference 7), while in transit or HSM storage. Damage to Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by the following on-contact radiation readings at some prescribed distance from the transfer cask or HSM: 1300 mrem/hr (gamma + neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI horizontal storage module (HSM)

OR

1050 mrem/hr (gamma + neutron) - HSM Front Bird Screen 4 mrem/hr (gamma + neutron) - HSM Outside Door 40 mrem/hr (gamma + neutron) - HSM End Shield Wall Exterior while in HSM storage.

This change is consistent with industry practices previously approved by the NRC to distinguish whether a degraded containment barrier condition exists. The proposed amendment does not introduce a new mode of plant operation or new accident pre-cursors, does not involve any physical alterations to plant configurations, or make changes to plant system set points that initiate a new or different kind of accident. The deletion of the Communicator position does not impact Emergency Notifications from the plant since the Emergency Coordinator has shown the capability to perform this function. This function is not involved in operations or evolutions that could cause or create new or different kinds of accidents since the communication of Emergency Notifications is not performed until after the emergency is declared and cannot affect an accident or event already in progress.

Therefore, the proposed changes have no direct effect on any plant system, the operation and maintenance of CR-3 or the ISFSI facility, or create the possibility of a new or different kind of accident.

Biweekly Notice Coordinator 3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No

The proposed changes have no direct effect on any plant system, do not involve any physical plant limit or parameter, License Condition, Technical Specification Limiting Condition of Operability or operating philosophy, and therefore cannot affect any margin of safety. The margin of safety is maintained by conforming to the CR-3 Technical Specifications or the ISFSI Technical Specifications. The proposed CR-3 PDEP and PD EAL Bases Manual revisions are commensurate with the on-going and anticipated reduction in radiological source term at the CR-3 site and reflect spent fuel being transferred to the ISFSI facility. These changes add the responsibility for implementing the emergency plan for the ISFSI facility to the Shift Supervisor/Certified Fuel Handler. The only remaining credible accident for CR-3, while the SFP is operable and prior to the transference of all spent fuel to dry shielded canisters, is a fuel handling accident. The proposed amendment does not adversely affect the inputs or assumptions of any design basis analysis that impact the fuel handling accident. There are no longer credible events that would result in doses to the public beyond the exclusion area boundary that would exceed the EPA PAGs. Emergency Planning Zones beyond the exclusion area boundary and the associated protective actions are no longer required. No corporate personnel, personnel involved in offsite dose projections, or personnel with special qualifications are required to augment the ERO. The credible events for the ISFSI facility remain unchanged. The indications of damage to a loaded Dry Shielded Canister CONFINEMENT BOUNDARY have been revised to be twice the design basis dose rate as described in Draft Amendment 14 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Modular Storage System, Sections 5.2.4 'Radiation Protection Program' and 5.4.2 HSM or HSM-H Dose Rate Evaluation Program (Reference 7), while in transit or HSM storage.

Damage to Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by the following on-contact radiation readings at some prescribed distance from the transfer cask or HSM: 1300 mrem/hr (gamma + neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI horizontal storage module (HSM)

OR 1050 mrem/hr (gamma + neutron) - HSM Front Bird Screen 4 mrem/hr (gamma + neutron) - HSM Outside Door 40 mrem/hr (gamma + neutron) - HSM End Shield Wall Exterior while in HSM storage.

Biweekly Notice Coordinator This change is consistent with industry practices previously approved by the NRC to distinguish whether a degraded containment barrier condition exists. The proposed changes are limited to the CR-3 PDEP and PD EAL Bases Manual and do not impact the safe storage of irradiated fuel. The proposed revisions do not affect any requirements for SSCs credited in the remaining analyses of applicable postulated accidents, and as such, do not affect the margin of safety associated with these accident analyses.

The deletion of the Communicator position does not impact Emergency Notifications from the plant since the Emergency Coordinator has shown the capability to perform this function. This function is not involved in design basis analyses or operations that could cause any decrease in any previously analyzed safety margin.

Therefore, the proposed changes do not create the possibility of reduction in any safety margin.

The NRC staff has reviewed the licensee's analysis and, based on this review, it appears that the three standards of 50.92(c) are satisfied. Therefore, the NRC staff proposes to determine that the amendment request involves no significant hazards consideration. Attorney for licensee: Lara S. Nichols, 550 South Tryon Street, Charlotte NC 28202. NRC Branch Chief: Bruce A. Watson, CHP.

ML15261A603 OFFICE NMSS/DUWP/RDB/PM NMSS/DUWP/LA NMSS/DUWP/RDB/BC NMSS/DUWP/RDB/PM NAME J. Hickman C. Holston B. Watson J. Hickman DATE 9/23/2015 9/23/2015 9/23/2015 9/23/2015