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Category:Exemption from NRC Requirements
MONTHYEARML24102A2572024-04-25025 April 2024 Federal Register Notice - Issuance of Multiple Exemptions Regarding 10 CFR Part 73 - March 2024 ML24044A0492024-03-12012 March 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0064 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML22083A1912022-03-24024 March 2022 Request for Exemption from an Allowable Contents Requirement Contained in the Certificate of Compliance No. 1014 for the HI-STORM 100S Version E Cask ML20336A1832020-12-17017 December 2020 Temporary Exemption from Biennial Emergency Preparedness Exercise Frequency Requirements of 10 CFR Part 50, Appendix E, Sections IV.F.2.B and IV.F.2.C (EPID L-2020-LLE-0173 (COVID-19)) GO2-20-130, Exemption Request from 10 CFR 50 Appendix Due to COVID-19 Pandemic2020-10-29029 October 2020 Exemption Request from 10 CFR 50 Appendix Due to COVID-19 Pandemic ML20303A2862020-10-29029 October 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-On-Force Exercises, Due to COVID-19 Pandemic ML14353A4652014-12-19019 December 2014 Encl (Copy of Exemption) to Ltr s L Pyle, Arkansas Nuclear One, Request for Exemption from Holtec Intl CoC No. 1014 Fuel Specification and Loading Conditions at ANO ISFSI (72-1014, 72-13) TAC L24954 0CAN111405, Response to Request for Additional Information Request for Exemption from Holtec International Certificate of Compliance (CoC) (72-1014) Fuel Specification and Loading Conditions (TAC No. L24954)2014-11-0707 November 2014 Response to Request for Additional Information Request for Exemption from Holtec International Certificate of Compliance (CoC) (72-1014) Fuel Specification and Loading Conditions (TAC No. L24954) ML12128A1732012-04-16016 April 2012 Request for One-Time Exemption from the Requirements of 10 CFR 50.36a(A)(2) Submittal Date for the Radioactive Effluent Release Report GO2-06-119, Request for Exemption from Certain Requirements of 10 CFR 72.212 and 72.214 for Dry Cask Storage2006-09-14014 September 2006 Request for Exemption from Certain Requirements of 10 CFR 72.212 and 72.214 for Dry Cask Storage ML0627200702006-09-14014 September 2006 Request for Exemption from Certain Requirements of 10 CFR 72.212 and 72.214 for Dry Cask Storage NL-04-2181, Joseph M. Farley Nuclear Plant, Request for Exemption from 10 CFR 72.124(c) - Criticality Monitors2005-01-19019 January 2005 Joseph M. Farley Nuclear Plant, Request for Exemption from 10 CFR 72.124(c) - Criticality Monitors 2024-04-25
[Table view] Category:Letter type:GO
MONTHYEARGO2-24-109, Summary of Changes and Analysis for Revision 42 of Plant Procedures Manual 13.8.1, Emergency Dose Projection System Operations2024-11-0404 November 2024 Summary of Changes and Analysis for Revision 42 of Plant Procedures Manual 13.8.1, Emergency Dose Projection System Operations GO2-24-110, Summary of Changes and Analysis for Revision 45 of Plant Procedures Manual 13.4.1, Emergency Notification2024-11-0404 November 2024 Summary of Changes and Analysis for Revision 45 of Plant Procedures Manual 13.4.1, Emergency Notification GO2-24-088, Supplement to Response to Request for Additional Information Regarding License Amendment Request to Revise Columbia Emergency Plan2024-09-24024 September 2024 Supplement to Response to Request for Additional Information Regarding License Amendment Request to Revise Columbia Emergency Plan GO2-24-051, Application to Revise Technical Specifications to Adopt TSTF-592, Revise Automatic Depressurization System (ADS) Instrumentation Requirements2024-09-23023 September 2024 Application to Revise Technical Specifications to Adopt TSTF-592, Revise Automatic Depressurization System (ADS) Instrumentation Requirements GO2-24-082, Response to Request for Additional Information Regarding License Amendment Request to Revise Columbia Emergency Plan2024-09-10010 September 2024 Response to Request for Additional Information Regarding License Amendment Request to Revise Columbia Emergency Plan GO2-24-060, Reply to a Notice of Violation, EA-21-170 and EA-23-0542024-07-30030 July 2024 Reply to a Notice of Violation, EA-21-170 and EA-23-054 GO2-24-070, Response to Request for Additional Information Regarding Fifth Interval Inservice Testing Program2024-07-29029 July 2024 Response to Request for Additional Information Regarding Fifth Interval Inservice Testing Program GO2-24-063, Notification of Extension to Columbias Fourth 10-Year Interval Inservice Testing Program Plan2024-07-15015 July 2024 Notification of Extension to Columbias Fourth 10-Year Interval Inservice Testing Program Plan GO2-24-057, Notice of Readiness for Supplemental Inspection2024-06-19019 June 2024 Notice of Readiness for Supplemental Inspection GO2-24-056, Relief Request for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing2024-06-11011 June 2024 Relief Request for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing GO2-24-049, 2023 Annual Radiological Environmental Operating Report2024-05-13013 May 2024 2023 Annual Radiological Environmental Operating Report GO2-24-050, Annual Environmental Operating Report2024-04-30030 April 2024 Annual Environmental Operating Report GO2-24-042, 2023 Annual Radioactive Effluent Release Report2024-04-22022 April 2024 2023 Annual Radioactive Effluent Release Report GO2-24-044, Voluntary Response to Regulatory Issue Summary 2024-012024-04-11011 April 2024 Voluntary Response to Regulatory Issue Summary 2024-01 GO2-24-034, Supplement to License Amendment Request to Revise Columbia Generating Station Emergency Plan2024-03-20020 March 2024 Supplement to License Amendment Request to Revise Columbia Generating Station Emergency Plan GO2-24-041, Level of Financial Protection - Annual Reporting Requirement2024-03-12012 March 2024 Level of Financial Protection - Annual Reporting Requirement GO2-24-036, Presentation Information for Pre-Application Meeting Regarding Columbia’S Replacement Steam Dryer Evaluation Approach for Extended Power Uprate2024-03-11011 March 2024 Presentation Information for Pre-Application Meeting Regarding Columbia’S Replacement Steam Dryer Evaluation Approach for Extended Power Uprate GO2-24-039, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462024-03-11011 March 2024 Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-24-004, License Amendment Request to Revise Emergency Plan2024-01-30030 January 2024 License Amendment Request to Revise Emergency Plan GO2-24-003, Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing2024-01-29029 January 2024 Relief Requests for the Columbia Generating Station Fifth Ten-Year Interval Inservice Testing GO2-24-014, Independent Spent Fuel Storage Installation, Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2024-01-15015 January 2024 Independent Spent Fuel Storage Installation, Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation GO2-24-005, Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-1702024-01-0808 January 2024 Docket No. 50-397 Supplement to Reply to a Notice of Violation; EA-21-170 GO2-23-136, Guarantee of Payment of Deferred Premium2023-12-20020 December 2023 Guarantee of Payment of Deferred Premium GO2-23-135, Notice of Readiness for Supplemental Inspection2023-12-14014 December 2023 Notice of Readiness for Supplemental Inspection GO2-23-130, Reply to a Notice of Violation; EA-23-0542023-12-14014 December 2023 Reply to a Notice of Violation; EA-23-054 GO2-23-105, Licensing Basis Document Update and Biennial Commitment Change Report2023-12-12012 December 2023 Licensing Basis Document Update and Biennial Commitment Change Report GO2-23-107, Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation2023-12-0505 December 2023 Application to Revise Technical Specifications to Adopt TSTS-584, Eliminate Automatic RWCU System Isolation on SLC Initiation GO2-23-126, Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-012023-11-28028 November 2023 Docket No. 50-397 Voluntary Response to Regulatory Issue Summary 2023-01 GO2-23-121, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-27027 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation GO2-23-097, In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26)2023-09-0606 September 2023 In-Service Inspection Summary Report for the Twenty-Sixth Refueling Outage (R26) GO2-23-100, Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication2023-08-31031 August 2023 Technical Specification Section 5.6.4 Post Accident Monitoring Instrumentation 14-Day Report for Inoperable Suppression Pool Level Indication GO2-23-056, Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling2023-08-29029 August 2023 Application to Revise Technical Specifications to Adopt TSTF-230, Add New Condition B to LCO 3.6.2.3, RHR Suppression Pool Cooling GO2-23-093, Supplement to Reply to a Notice of Violation: EA-21-1702023-07-27027 July 2023 Supplement to Reply to a Notice of Violation: EA-21-170 GO2-23-068, Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation2023-07-19019 July 2023 Notification of Completion of Commitments Required Prior to Entry Into the Period of Extended Operation GO2-23-090, Reply to a Notice of Violation2023-07-12012 July 2023 Reply to a Notice of Violation GO2-23-073, Notification of NPDES Permit Issuance2023-06-26026 June 2023 Notification of NPDES Permit Issuance GO2-23-072, Cycle 27 Core Operating Limits Report2023-06-0505 June 2023 Cycle 27 Core Operating Limits Report GO2-23-055, Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Independent Spent Fuel Storage Installation, 2022 Annual Radiological Environmental Operating Report GO2-23-006, License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications2023-05-0101 May 2023 License Amendment Request to Clean-Up Operating License and Appendix a Technical Specifications GO2-23-053, 2022 Annual Environmental Operating Report2023-04-26026 April 2023 2022 Annual Environmental Operating Report GO2-23-057, 2022 Annual Radioactive Effluent Release Report2023-04-25025 April 2023 2022 Annual Radioactive Effluent Release Report GO2-23-012, Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position2023-03-27027 March 2023 Application to Revise Technical Specifications to Adopt Tstf-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position GO2-23-038, Plant Decommissioning Fund Status Report2023-03-15015 March 2023 Plant Decommissioning Fund Status Report GO2-23-041, Generation Station - Level of Financial Protection - Annual Reporting Requirement2023-03-15015 March 2023 Generation Station - Level of Financial Protection - Annual Reporting Requirement GO2-23-034, Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.462023-03-13013 March 2023 Report of Changes or Errors in Emergency Core Cooling System Loss of Coolant Accident Analysis Models Pursuant to 10 CFR 50.46 GO2-23-035, Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-03-0909 March 2023 Supplement to License Amendment Request to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling GO2-23-019, Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-012023-02-0808 February 2023 Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-01 GO2-22-131, Guarantee of Payment of Deferred Premium2022-12-19019 December 2022 Guarantee of Payment of Deferred Premium GO2-22-122, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2022-11-28028 November 2022 Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b GO2-22-076, Status of License Renewal Commitments2022-10-31031 October 2022 Status of License Renewal Commitments 2024-09-24
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E ENERGY
- NORTHWEST People -Vision- Solutions P.O. Box 968
- 99352-0968 September 14, 2006 GO2-06-119 Attn: Document Control Desk Director, Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NOS. 50-397172-35 REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 72.212 AND 72.214 FOR DRY CASK STORAGE
Reference:
Letter dated June 7, 2005, Robert Lewis (NRC) to K. P. Singh (Holtec),
"Amendment No. 2 to Certificate of Compliance No. 1014 For the Holtec International Hi-Storm 100 Cask System"
Dear Sir or Madam:
Pursuant to 10 CFR 72.7, Energy Northwest requests an exemption from the requirements of 10 CFR 72.212(a), 72.212(b)(2)(i), 72.212(b)(7) and 72.214. These regulations require, in part, compliance to the terms and conditions of the Holtec International (Holtec) Certificate of Compliance (CoC) 72-1014 for the HI-STORM 100 casks currently in use on the Columbia Independent Spent Fuel Storage Installation (ISFSI). Specifically, an exemption is requested to deviate from the HI-STORM 100/ISFSI pad interface coefficient of friction required in Appendix B of Amendment I to CoC 72-1014 under environmental conditions that may degrade the pad/cask interface (such as due to icing).
In lieu of this requirement, Energy Northwest requests to apply guidance already approved by the NRC in Amendment 2 to CoC 72-1014, referenced above, to casks that are fabricated and used at Columbia in accordance with Amendment 1.
Icing conditions on the Columbia ISFSI pad can generally occur between November and March. It is therefore requested that this exemption be granted by October 31, 2006 with an effective date to be within 60 days of approval.
Details of Energy Northwest's need and justification for the issuance of an exemption are included in the attachment to this letter. There are no new commitments being made in this letter.
- . 'e REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 72.212 AND 72.214 FOR DRY CASK STORAGE Page 1 Should you have any questions concerning this submittal, please contact Greg Cullen (509) 377-6105.
Respectfully, DK Atkinson Vice President, Nuclear Generation Mail Drop PE08
Attachment:
Request for Exemption from Certain Requirements of 10 CFR 72.212 and 72.214 for Dry Cask Storage cc: BS Mallett - NRC RIV BJ Benney - NRC NRR NRC Senior Resident Inspector/988C RN Sherman - BPA/1 399 WA Horin -Winston & Strawn
REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 72.212 AND 72.214 FOR DRY CASK STORAGE Attachment Page 1 of 3 1.0 Request for Exemption Pursuant to 10 CFR 72.7, Energy Northwest requests an exemption from the requirements of 10 CFR 72.212(a), 72.212(b)(2)(i), 72.212(b)(7) and 72.214. These regulations require, in part, compliance to the terms and conditions of the Holtec Certificate of Compliance (CoC) 72-1014 which currently supports the casks on the Columbia ISFSI. Specifically, an exemption is requested to deviate from Section 3.4.3.a of Appendix B of CoC 72-1014 (Amendment 1) for the HI-STORM 100/ISFSI pad interface coefficient of friction during environmental conditions that may degrade the pad/cask interface friction (such as due to icing). In lieu of this requirement, Energy Northwest would perform an analysis consistent with that granted by the NRC in Amendment 2 of the CoC (i.e., Appendix B, Section 3.4.3.b). This exemption would apply to all casks fabricated and used in accordance with Amendment I of the Holtec CoC 72-1014 on the Columbia Independent Spent Fuel Storage Installation (ISFSI).
2.0 Background
On October 6, 2003, the NRC issued Information Notice 2003-16, "Icing Conditions Between Bottom of Dry Storage System and Storage Pad." This Information Notice provided details of a condition that was considered outside of the design basis at the Main Yankee ISFSI. Energy Northwest evaluated the condition discussed in the Information Notice and determined the casks utilized at Columbia were susceptible to the same phenomena. Based on this determination, Energy Northwest has developed compensatory measures during cold weather conditions (i.e., monitoring, operator walkdowns, de-icing, clearing a pathway on the ISFSI for draining) to maintain the friction coefficient in accordance with Amendment I to CoC 72-1014.
Currently spent fuel is stored in 15 freestanding casks on the Columbia ISFSI in accordance with Amendment I to CoC 72-1014. Section 3.4.3.a of Appendix B of this CoC requires that the Coulomb friction coefficient for the HI-STORM 100/ISFSI pad interface be at least 0.53 under all conditions.
On June 7, 2005, the NRC approved Amendment 2 to HOLTEC CoC 72-1014 which, among other changes, added the following guidance to Section 3.4.3.b of Appendix B of CoC 72-1014:
For free-standingcasks, underenvironmental conditionsthat may degrade the pad/cask interface friction (such as due to icing) the response of the casks under the site's Design Basis Earthquakeshall be establishedusing the best estimate of the friction coefficient in an appropriateanalysis model. The analysisshould demonstrate that the earthquakewill not result in cask tipover or cause a cask to fall off the pad. In addition, impact between casks should be precluded,orshould be consideredan accident for which the maximum g-load experienced by the stored fuel shallbe limited to 45 g's.
REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 72.212 AND 72.214 FOR DRY CASK STORAGE Attachment Page 2 of 3 3.0 Technical Considerations Energy Northwest requests that the allowance authorized in Amendment 2 to section 3.4.3.b of Appendix B be applied to the casks currently fabricated and used in accordance with Amendment I to CoC 72-1014 on the Columbia ISFSI. Amendment 2 to CoC 72-1014 involves a number of other changes in the design of the HOLTEC HI-STORM 100 casks and therefore, could not be applied in whole to the casks currently licensed under Amendment 1.
Similar to that approved in Amendment 2 of the CoC, Energy Northwest would use the best estimate of the friction coefficient in an appropriate analysis model for establishing the safe response of casks under Design Basis Earthquake (DBE) conditions. This would apply only under environmental conditions that could degrade the pad/cask interface on the Columbia ISFSI (such as icing). Prior to eliminating the need for compensatory measures, Energy Northwest would demonstrate through an appropriate analysis model that the DBE will not result in a cask tipover or cause a cask to fall off the ISFSI pad. In addition, the analysis would determine that either the casks do not impact each other or if an impact does occur, a maximum g-load experienced by the stored fuel will be limited to 45 g's and treated as an accident.
In comparing the differences between the casks and pads designed for each amendment, there are no appreciable differences that would warrant concern regarding the use of this analytical approach for Amendment I casks. In both the Holtec submittal and the subsequent NRC safety evaluation there were no expressed concerns or limitations associated with the HI-STORM cask design that was assumed in development of the added guidance in Section 3.4.3.b of Appendix B of the CoC. In addition, there are no other unique design considerations currently associated with the existing casks fabricated and used under Amendment 1 of the CoC on the Columbia ISFSI that would suggest that the use of the guidance approved in Amendment 2 would be inappropriate. With either cask design, the analysis method to be used would demonstrate the safe use of the casks under DBE conditions.
Since the analysis would demonstrate that a cask would not tip over, fall off the ISFSI pad, or else impact other casks beyond the current design limit of 45 g's under environmental conditions that degrade the pad/cask interface, a comparable level of safety would be maintained by granting this exemption request.
4.0 Regulatory Considerations Columbia is authorized to store spent fuel on an ISFSI per 10 CFR 72.210 which provides a general license to store spent fuel in an ISFSI at reactor sites as long as the Part 50 reactor license remains in effect. Columbia is currently licensed under 10 CFR Part 50 in accordance with Operating License NPF-21, Docket No. 50-397, issued December 20, 1983.
-" REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 72.212 AND 72.214 FOR DRY CASK STORAGE Attachment Page 3 of 3 The specific requirements for granting exemptions to 10 CFR Part 72 licensing requirements are set forth in 10 CFR 72.7, Specific Exemptions, which reads as follows:
The Commission may, upon applicationby any interestedperson or upon its own initiative, grantsuch exemptions from the requirements of the regulationsin this part as it determines are authorizedby law and will not endangerlife or propertyor the common defense and security and are otherwise in the public interest.
As discussed above, and as endorsed by the NRC in Amendment 2 to CoC 72-1014, use of an appropriate analysis model that assumes the best estimate of friction coefficient under the environmental conditions that degrade the cask/pad interface to demonstrate the safe storage of spent fuel during a design basis earthquake in lieu of requiring a friction coefficient of 0.53 will not endanger life or property or the common defense and security.
In addition, eliminating the requirement to implement unnecessary compensatory measures would free Operators to be more responsive to other duties as necessary to ensure continued safe operation of the plant and would therefore, be in the public's best interest.
5.0 Summary In conclusion, because the requested exemption is authorized by law, will not endanger life or property or the common defense and security, and is in the public interest, Energy Northwest respectfully requests that, in accordance with 10 CFR 72.7 requirements, the NRC grant the requested exemption.