CY-15-002, and Independent Spent Fuel Storage Installation, Submittal of Report of 10 CFR 72.48 Changes, Tests, and Experiments
| ML15022A061 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/06/2015 |
| From: | Buerger B Connecticut Yankee Atomic Power Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| CY-15-002 | |
| Download: ML15022A061 (7) | |
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- CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT CT 06424-3099 ROAD - EAST HAMPTON, 362 INJUN HOLLOW January 6, 2015 CY-15-002 10 CFR 72.4 and 10 CFR 72.48 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 - 0001 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRC License Nos. DPR-61 and SFGL-21 (NRC Docket Nos. 50-213 and 72-39)
Subject:
Report of 10 CFR 72.48 Changes, Tests, and Experiments In accordance with 10 CFR 72.48(d)(2), Connecticut Yankee Atomic Power Company is required to submit to the NRC a brief description of any changes, tests or experiments made pursuant to 10 CFR 72.48(c), including a summary of the evaluation of each. This report covers the period from January 1, 2013 through December 31, 2014. The attachment to this letter provides the summary of the changes and the evaluations made during that time period pursuant to paragraph (c) of 10 CFR 72.48.
This letter contains no regulatory commitments.
If you have any questions regarding this submittal, please do not hesitate to contact me at (860) 267-6426 ext. 303.
Respectfully, Brantsey uerger, PE ISFSI Makger
Attachment:
Summary of Changes and Evaluations Made in Accordance with 10 CFR 72.48(c) cc: D. Dorman, Acting NRC Region I Administrator M. S. Ferdas, Chief, Decommissioning Branch, NRC, Region 1 J. Goshen, NRC Project Manager, Haddam Neck Plant J. Semancik, Director, CT DEEP, Radiation Division 50 S2
A4 Attachment to CY-15-002 Summary of Changes and Evaluations Made in Accordance with 10 CFR 72.48(c) 10 CFR 72.48 Evaluation Number 13 Revision 0 Summary of Changes Section(s) Description of Change Reason for Change 1.1, 4.0, 9.0, Corrected references to the Technical This change is an administrative change to 10.3, 11.6, Specifications contained in Appendix properly reference Appendix A of the NAC-15.3, 15.4, A to the NAC-MPC Certificate of MPC CoC.
Attachment Compliance (CoC).
C 1.1, 4.0, 9.0, The description regarding the adoption The current description regarding the adoption 15.3 of Amendment No. 5 of the NAC- of Amendment No. 5 of the NAC-MPC CoC MPC CoC was modified to accurately did not accurately describe the purpose of the describe the exemption issued by the exemption dated July 15, 2010 or the NRC on July 15, 2010 and the CYAPCO notification dated November 29, CYAPCO notification dated 2011.
November 29, 2011.
1.1 The description of the Vertical The revised description is consistent with Concrete Cask functions was modified Section 1.2.1.2 of the NAC-MPC Final Safety to include structural support and Analysis Report.
protection from environmental conditions.
1.1 Corrected a reference to the NAC The revised reference matches the NAC-STC Storage Transport Cask (NAC-STC) Safety Analysis Report.
Safety Analysis Report.
2.0, 4.0, 8.0, Modified the 72.212 report to reflect The 10 CFR 72.212 Report contains 10.3, 11.2, the current status regarding the information regarding the HN-P that is now 11.7, 14.0, decommissioning of the Haddam Neck historical.
15.1, 15.4, Plant (HNP) and HNP ISFSI.
18.0, 20.0, Attachment B,
Attachment C
2.0, 6.0, 7.0 Modified references to 10 CFR 72 The NRC has modified 10 CFR 72. Thus, subsections and quotes of 10 CFR 72 some of the references to and quotes from 10 subsection language to reflect current CFR 72 were no longer accurate.
code or eliminate unnecessary references 7.0 Section 7.0 contains a table that The revised dates match the ISFSI Loading defines the dates the Vertical Concrete Data Sheets.
Cask was placed in storage. The dates placed in storage for CY-TSC-414-03,
-14, -26, and 0-27 were corrected to match the ISFSI Loading Data Sheets.
8.0 Corrected references to the NAC-MPC The text included references to the NAC FSAR. FSAR. These were modified to identify that the references were to the NAC-MPC FSAR versus the NAC-STC SAR.
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Attachment to CY-15-002 Summary of Changes and Evaluations Made in Accordance with 10 CFR 72.48(c)
Section(s) Description of Change Reason for Change 10.2 Corrected the discussion regarding the Section 10.2 stated that the ISFSI pad was location of the HNP ISFSI pad. The maintained in a separate controlled area of the ISFSI Pad is in a restricted area and a plant. The term "controlled area" is protected area. specifically defined in 10 CFR 20 and 10 CFR 72, and was not properly utilized in this case.
The area is a "restricted area" as defined in 10 CFR 20.
10.2 A discussion was added to address the The discussion was provided to define that the surface spalling of the ISFSI storage spalling of the ISFSI storage pad is being pad, and the plans to rework the addressed, and to define that it does not impact surface. the structural integrity of the ISFSI storage pad.
10.3 Corrected the discussion regarding the This discussion reflects the release of land that property boundary and controlled area. occurred in 2007. The revised discussion is consistent with the discussion provided in the Emergency Plan.
10.3 Eliminated the reference to the This discussion is no longer relevant.
minimum distance from the nearest Following the release of lands in 2007, the site site boundary. boundary was no longer equivalent to the property boundary. Thus, the controlled area is the area that is appropriately addressed.
10.3 Added a discussion to establish The discussion is consistent with the NRC's compliance with 10 CFR 72.106(b) as Safety Evaluation Report for Amendment 199 established in the NRC's Safety dated January 30, 2003.
Evaluation Report for Amendment 199 dated January 30, 2003.
10.3 Added a discussion to define that the The term "exclusion area boundary" is no term "exclusion area boundary" is no longer applicable to the HNP ISFSI, because longer applicable to the site. the NRC defined in their SER dated November 26, 2007 (Reference 24.7) that "the criteria of 10 CFR Part 100 no longer apply to this site and need not be addressed."
10.3 Modified the discussion regarding the The revised description is provided from the total annual dose to person at the CYAPCO letter dated July 31, 2007. It states:
Controlled Area Boundary "...However, actual measurements at locations at the boundary of the 300 m controlled area have been determined to be indistinguishable from background. Doses associated with the uranium fuel cycle operations at HNP no longer exist, and the areas to be released meet the criteria for unrestricted release in 10 CFR 20.1402. Thus this satisfies, with considerable margin, the limit of 25 mrem/year stipulated in 10 CFR 72.104 and 40 CFR 190."
13.0 Added a reference to Amendment 199 The text referenced a letter, but it did not dated January 30, 2003. include a reference to Amendment 199 dated January 30, 2003.
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Attachment to CY-15-002 Summary of Changes and Evaluations Made in Accordance with 10 CFR 72.48(c)
Section(s) Description of Change Reason for Change 14.0 Corrected reference to the HNP ISFSI The changes were made to ensure that the Physical Security Plan. proper document title is referenced.
14.0 Clarified the discussion regarding the Security officers and all armed response use of force. personnel are trained in accordance with state laws to use sufficient to counter the force directed at him including the use of deadly force when the security officer or other armed response person has a reasonable belief it is necessary in self-defense or in the defense of others.
14.7 Modified the discussion regarding the On May 23, 2012, the NRC staff granted the exemptions granted by the NRC requested exemptions or determined that the regarding the HNP ISFSI Physical regulations were either not applicable to the Security Plan HNP ISFSI or met by the HNP ISFSI Physical Security Plan.
14.7 Modified the discussion to clarify that The change is consistent with the HNP ISFSI the HNP ISFSI Physical Security Plan Physical Security Plan.
controls access and patrols of the ISFSI protected area.
24.0 References were added and modified The added references were added to address to address the other changes. the other changes.
24.0 Updated to reflect the consolidation of This update reflects the current procedures Attachment EO-2, EO-3, and EO-4 into a single that address the specific topics.
A procedure (i.e., EO-2, Response to Off-site, Accident, and Natural Phenomena Events), reflect the proper title of RP-1, change references to OP-8 to OP-5 or FP-5, and eliminate a reference to OP-8.
Attachment Eliminated the reference to the specific The revision number for the Quality A revision of the Quality Assurance Assurance Program is an unnecessary detail.
Program.
Attachment Discussions were added to define how The discussion defines that CYAPCO C CYAPCO complies with the changes complies with the revised NAC-MPC to the NAC-MPC Technical Technical Specifications, with the exception Specification implemented in of NAC-MPC TS A.5. 1. The NRC granted Amendment No. 5 to the NAC-MPC CYAPCO an exemption from the training CoC. requirement in that Technical Specification.
Throughout Various editorial and administrative Correct various editorial and administrative changes were made throughout the errors.
document.
Summary of 10 CFR 72.48 Evaluation The changes update the 10 CFR 72.212 Report to reflect the current status of the decommissioning of the HNP and operation of the HNP ISFSI. The changes do not impact the capability of any of the ISFSI structures, systems, or components to fulfill their functions. The Page 3 of 6
Attachment to CY-15-002 Summary of Changes and Evaluations Made in Accordance with 10 CFR 72.48(c) spalling of the ISFSI storage pad was determined to not have a structural impact via a separate evaluation. The changes are consistent with the Haddam Neck Emergency Plan and the Haddam Neck Plant ISFSI Physical Security Plan. In addition, several of the changes include updates to reflect the NRC approved release of land in 2007, an exemption granted by the NRC on July 15, 2010 regarding training requirements in Technical Specification A.5.1 of Amendment No. 5 of the NAC-MPC Certificate of Compliance and an exemption to 10 CFR 73.55 granted by the NRC on May 23, 2012.
The changes do not:
" Affect any evaluations of accidents or malfunctions made in the NAC International (NAC) -
Multi-Purpose Canister System (MPC) Final Safety Analysis Report (FSAR) (NAC-MPC FSAR).
- Creation of a new type of event not previously evaluated in the NAC-MPC FSAR.
" Affect any Fission Product Barriers as described in the NAC-MPC FSAR.
" Affect any Evaluation Methodologies described in the NAC-MPC FSAR.
10 CFR 72.48 Evaluation Number 14 Revision 0 Summary of Change The 72.212 Evaluation Report is revised to: 1) Adopt NAC 10 CFR 72.48 Determination ID No.
NAC-13-MPC-001; 2) Replace the extensive procedure listing in Attachment A with a generic listing of categories; 3) Revise the discussions regarding the contents of Attachment A in numerous sections;4) Revise Section 10 to identify that radiation doses are monitored via periodic surveys in accordance with RP-2 to ensure that they remain consistent; and 5) Revise Section 17 to replace the phrase "maintenance work authorization" with "work order."
The Technical Specification (TS) Bases for Surveillance Requirement (SR) 3.1.6.1 is being revised to clarify an inconsistency between the NAC-MPC TSs, NAC-MPC TS Bases and NAC-MPC Final Safety Analysis Report (FSAR) accident analysis. Specifically, the bases for NAC-MPC TS SR 3.1.6.1 currently describes the system as being inoperable when two or more inlet or outlet vents are blocked. This is being revised to state that the system is inoperable when more than two inlet or outlet vents are fully blocked or the equivalent effective screen area of more than two inlet or outlet vents is fully blocked.
Historically, the detailed listing of procedures provided in Attachment A established the method for complying with requirements of the NAC-MPC CoC. The historical revisions of Attachment A will be available in Records for review. Given the current state of ISFSI Operations (i.e., long term storage of spent fuel and Greater than Class C waste), the maintenance of this list of procedures is no longer essential. The Master Document Index maintains a spreadsheet that identifies the existing procedures. The procedures will continue to be managed and maintained in accordance with the various requirements, including the QAP if applicable, to ensure that the ISFSI continues to satisfy the requirements of the NAC-MPC CoC.
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Attachment to CY-15-002 Summary of Changes and Evaluations Made in Accordance with 10 CFR 72.48(c)
Section 10 states that radiation doses are monitored using Procedure OP-2, "ISFSI Routine Surveillances." The only discussion in OP-2 regarding radiation related devises is related to the Area Radiation Monitors, which are dose rate monitors. Doses are monitored using periodic quarterly surveys in accordance with RP-2, thermo-luminescent detectors (TLDs) under the REMP Program and the Area TLD Program. Section 10 is revised to denote that radiation doses are monitored on a periodic basis in accordance with RP-2 to ensure that they remain consistent.
The revision to Section 17 to replace the phrase "maintenance work authorization" with "work order" is to match the language that is utilized in AD-5.
Summary of 10 CFR 72.48 Evaluation Per NAC 10 CFR 72.48 Determination ID No. NAC-13-MPC-001, the TS bases for SR 3.1.6.1 is not consistent with what is described in the FSAR accident analysis or administrative TS A 5.3.
The accident analysis, as presented in NAC-MPC FSAR Sections 11.1.1 and 11 .A. 1, demonstrates that when half of the air inlets are fully blocked the system remains within the allowable temperature limits for all components and is therefore operable. This is also reflected in administrative TS A 5.3 where at least one-half of the inlets and outlets on each concrete cask must be cleared of blockage or debris within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore air circulation.
In addition as stated in the NAC 10 CFR 72.48 Determination ID No. NAC-13-MPC-001, the thermal evaluation of the system utilizes an axisymmetric model. When performing the thermal evaluation for half of the inlets blocked, the axisysmmetric model assumes an effective screen area being blocked that is equivalent to two vents being blocked in their entirety if the entire system was being modeled. In other words, the thermal model evaluates an effective screen area reduction that is equivalent to the area of two air inlets being fully blocked.
Replacing the extensive procedure listing in Attachment A with a generic listing of procedure categories, and revising the discussions regarding the contents of Attachment A in numerous sections are essentially administrative changes. The procedures will continue to be managed and maintained in accordance with the various requirements, including the QAP if applicable, to ensure that the ISFSI continues to satisfy the requirements of the NAC-MPC CoC.
The change to Section 10 defines the current method for monitoring radiation doses is by performing periodic surveys in accordance with RP-2 to ensure that the doses remain consistent.
This method is not addressed in OP-2.
The revision to Section 17 to replace the phrase "maintenance work authorization" with "work order" is to match the language that is utilized in AD-5.
The changes do not:
Affect any evaluations of accidents or malfunctions made in the NAC International (NAC) -
Multi-Purpose Canister System (MPC) Final Safety Analysis Report (FSAR) (NAC-MPC FSAR).
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Attachment to CY-15-002 Summary of Changes and Evaluations Made in Accordance with 10 CFR 72.48(c)
- Creation of a new type of event not previously evaluated in the NAC-MPC FSAR.
- Affect any Fission Product Barriers as described in the NAC-MPC FSAR.
- Affect any Evaluation Methodologies described in the NAC-MPC FSAR.
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