ML030440372
| ML030440372 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee, 07201015 |
| Issue date: | 02/13/2003 |
| From: | Chris Miller NRC/NMSS/SFPO |
| To: | Williamson T Maine Yankee Atomic Power Co |
| References | |
| +sispjld120050505, -RFPFR | |
| Download: ML030440372 (8) | |
Text
February 13, 2003 Thomas L. Williamson Director, Nuclear Safety and Regulatory Affairs Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922
SUBJECT:
EXEMPTION FROM 10 CFR 72.212 AND 72.214 FOR DRY SPENT FUEL STORAGE ACTIVITIES
Dear Mr. Williamson:
This is in response to your letter dated November 7, 2002, as supplemented December 19, 2002, requesting an exemption from 10 CFR 72.212(a)(2), 72.212(b)(2)(i), 72.212(b)(7) and 10 CFR 72.214, pursuant to 10 CFR 72.7. In your letter you requested an exemption from the requirements in Certificate of Compliance (CoC) No. 1015, Appendix A, Limiting Conditions for Operation (LCO) Items 3.1.1.1, 3.1.1.2, 3.1.4.1, and 3.1.4.2 for the NAC-UMS dry spent fuel storage system. This exemption would allow Maine Yankee Atomic Power Company (MYAPC) to increase: (1) vacuum drying time limits based on canister heat load; (2) vacuum drying time limits after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of in-pool or forced air cooling; (3) time duration limit from completion of canister helium backfill through completion of canister transfer to the concrete cask; and (4) time duration limit from completion of in-pool or forced air cooling through completion of the canister transfer to the concrete cask.
We understand that you requested the increased vacuum drying time limits in order to reduce overall processing times and occupational dose to workers. MYAPC calculated that the reduction in radiological exposure to the operators, fuel handlers, and security personnel involved in handling, preparing and transferring the canisters would be approximately 5 rem during the remainder of the spent fuel loading campaign.
The U.S. Nuclear Regulatory Commission (NRC) staff performed a safety evaluation of the proposed exemption. The enclosed safety evaluation concludes that the requested changes will not compromise the thermal performance of the NAC-UMS system nor increase the potential for dose to members of the public.
In a letter dated January 15, 2002, the designer of the NAC-UMS system, NAC International, requested an amendment to CoC No. 1015, that requested, among several other changes, to increase the vacuum drying time limits. That request was supplemented on November 27, 2002. The information provided in the amendment request, as supplemented, is relevant to the exemption request by MYAPC and provides the safety basis for the time limits increase. This information has been determined to be an adequate basis to grant the exemption. Accordingly, the exemption will be effective immediately.
However, staff identified a discrepancy between the vacuum drying time limits proposed in the exemption request and the NAC-UMS amendment application. In particular, the time limits
T. Williamson February 13, 2003 proposed in the exemption request for LCO 3.1.1.2 should be revised to be consistent with the NAC-UMS amendment application and the supporting analyzed design basis:
Heat Load (L) (kW) Time Limit (hours) 14 < L # 17.6 9 (requested 11 in the exemption request) 11 < L # 14 16 (requested 18 in the exemption request) 8 < L # 11 27 (requested 29 in the exemption request)
L#8 78 (requested 80 in the exemption request)
The exemption request values were 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> more than those analyzed in the amendment application. Please be advised that MYAPC must use the values contained in the NAC-UMS amendment application, as presented above.
The NRC staff evaluated the public health and safety and environmental impacts of the proposed exemption and determined that granting the exemption would not result in any significant impacts. For this action, an Environmental Assessment and Finding of No Significant Impact have been prepared and published in the Federal Register (68 FR 6784, February 10, 2003). A copy of the Federal Register Notice was provided to you by letter dated January 31, 2003. Based on the foregoing considerations, the staff has determined that granting the proposed exemption from the provisions of 10 CFR 72.212(a)(2), 72.212(b)(2)(i),
72.212(b)(7), and 10 CFR 72.214 is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest. Specifically, this exemption permits MYAPC to increase the vacuum drying time limits as delineated in the attached Safety Evaluation Report. The increased time limits for these vacuum drying operations will not significantly impact the quality of the human environment. Therefore, the NRC staff has concluded that the proposed changes will not pose an increased risk to public health and safety.
If you have any questions, please contact me or Stephen OConnor of my staff at 301-415-8500. Any future correspondence related to this action should reference Docket 72-30 and TAC No. L23528.
Sincerely,
/RA/
Charles L. Miller, Deputy Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Docket Nos.: 72-30, 72-1015, and 50-309
Enclosure:
Safety Evaluation cc: Mailing List
T. Williamson February 13, 2003 proposed in the exemption request for LCO 3.1.1.2 should be revised to be consistent with the NAC-UMS amendment application and the supporting analyzed design basis:
Heat Load (L) (kW) Time Limit (hours) 14 < L # 17.6 9 (requested 11 in the exemption request) 11 < L # 14 16 (requested 18 in the exemption request) 8 < L # 11 27 (requested 29 in the exemption request)
L#8 78 (requested 80 in the exemption request)
The exemption request values were 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> more than those analyzed in the amendment application. Please be advised that MYAPC must use the values contained in the NAC-UMS amendment application, as presented above.
The NRC staff evaluated the public health and safety and environmental impacts of the proposed exemption and determined that granting the exemption would not result in any significant impacts. For this action, an Environmental Assessment and Finding of No Significant Impact have been prepared and published in the Federal Register (68 FR 6784, February 10, 2003). A copy of the Federal Register Notice was provided to you by letter dated January 31, 2003. Based on the foregoing considerations, the staff has determined that granting the proposed exemption from the provisions of 10 CFR 72.212(a)(2), 72.212(b)(2)(i),
72.212(b)(7), and 10 CFR 72.214 is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest. Specifically, this exemption permits MYAPC to increase the vacuum drying time limits as delineated in the attached Safety Evaluation Report. The increased time limits for these vacuum drying operations will not significantly impact the quality of the human environment. Therefore, the NRC staff has concluded that the proposed changes will not pose an increased risk to public health and safety.
If you have any questions, please contact me or Stephen OConnor of my staff at 301-415-8500. Any future correspondence related to this action should reference Docket 72-30 and TAC No. L23528.
Sincerely,
/RA/
Charles L. Miller, Deputy Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Docket Nos.: 72-30, 72-1015, and 50-309
Enclosure:
Safety Evaluation cc: Mailing List DISTRIBUTION:
Dockets NRC File Center PUBLIC NMSS r/f SFPO r/f RBellamy, R-I MWebb, NRR FLyon, NRR NJensen, OGC EWBrach C:\ORPCheckout\FileNET\ML030440372.wpd ML030440372 OFC SFPO SFPO SFPO SFPO SFPO NAME SOConnor
- EZiegler
- RParkhill
- EEaston
- JMonninger
- DATE 01/24/03 01/24/03 01/30/03 01/30/03 01/30/03 OFC OGC SFPO SFPO NAME STreby (NLO)* WHodges CMiller DATE 01/24/03 02/10/03 02/13/03
- - see previous concurrence OFFICIAL RECORD COPY
cc:
Mr. Charles B. Brinkman Edgecomb, ME 04556 Manager - Washington Nuclear Operations Mr. James Garvey ABB Combustion Engineering Operations Director 12300 Twinbrook Parkway, Suite 330 Maine Yankee Atomic Power Company Rockville, MD 20852 321 Old Ferry Road Wiscasset, ME 04578-4922 Ernest L. Blake, Jr., Esquire Shaw Pittman 2300 North Street, NW Washington, DC 20037 Ms. Paula Craighead, Esquire State Nuclear Safety Advisor State Planning Office State House Station #38 Augusta, ME 04333 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 First Selectman of Wiscasset Municipal Building U.S. Route 1 Wiscasset, ME 04578 Joseph Fay, Esquire Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922 Friends of the Coast P.O. Box 98
Mr. Jonathan M. Block Attorney at Law P.O. Box 566 Putney, VT 05346-0566 Mr. William Henries, Director Engineering Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922 Mr. Patrick J. Dostie State of Maine Nuclear Safety Inspector Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922 Mr. Ted C. Feigenbaum, President Maine Yankee Atomic Power Company 321 Old Ferry Road Wiscasset, ME 04578-4922 Randall L. Speck, Esq.
Kaye, Scholer, Fierman, Hays & Handler, LLP McPherson Building 901 Fifteenth Street, N.W., Suite 1100 Washington, DC 20005-2327
ENCLOSURE SAFETY EVALUATION REPORT Docket No. 72-30 Maine Yankee Atomic Power Station Independent Spent Fuel Storage Installation In a letter dated November 7, 2002, as supplemented on December 19, 2002, Maine Yankee Atomic Power Company (MYAPC or the licensee) requested the U.S. Nuclear Regulatory Commissions approval for an exemption from certain 10 CFR 72.212 and 72.214 requirements.
Specifically, MYAPC requested an exemption from the requirements in Certificate of Compliance (CoC) No. 1015, Appendix A, Limiting Condition for Operation (LCO) Items 3.1.1.1, 3.1.1.2, 3.1.4.1, and 3.1.4.2 for the NAC-UMS storage system. The licensees basis for the request was to reduce occupational exposure resulting from repeated vacuum drying cycles of the NAC-UMS system. There is no increase in potential dose to members of the public resulting from this exemption request.
The exemption would allow MYAPC to increase: (1) vacuum drying time limits based on canister heat load; (2) vacuum drying time limits after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of in-pool or forced air cooling; (3) time duration limit from completion of canister helium backfill through completion of canister transfer to the concrete cask; and (4) time duration limit from completion of in-pool or forced air cooling through completion of the canister transfer to the concrete cask On January 15, 2002, NAC International submitted an application for an amendment to CoC No. 1015 for the NAC-UMS to, among other things, increase the times limits for certain loading operations to allow more time to complete these operations before entering the CoC technical specification required actions. This amendment is currently in the NRC licensing review process and will be noticed shortly in the Federal Register for proposed incorporation into 10 CFR 72.214 as an approved amendment to the NAC-UMS. Since the licensee is currently loading NAC-UMS systems and would likely reduce occupational dose with the extended vacuum drying time limits, MYAPC requested this exemption to allow it to use the amended time limits prior to issuance of the amendment.
The staff issued Interim Staff Guidance No. 11 (ISG-11), Revision 2, Cladding Considerations for the Transportation and Storage of Spent Fuel, on July 30, 2002. This revision to ISG-11 increased the cladding temperature limit to 400 0C (752 0F) for normal conditions, which is less restrictive than the previous ISG-11 guidance limiting temperatures between approximately 330 0C and 380 0C depending principally on cooling time and burn-up. Furthermore, ISG-11, Revision 2, also changed the cladding temperature limit to 400 0C for short term operations including cask drying. The NAC-UMS amendment application demonstrated that the cladding remains below 400 0C for normal conditions including all loading and transfer operations.
The staff reviewed and performed confirmatory analysis for the decay heat loads and associated cooling times for MYAPC fuel assemblies. The staff also reviewed the NACs proprietary calculation governing the time restrictions for fuel during loading and transfer operations.
Safety Evaluation Report Based on the information presented in the NAC-UMS amendment application, MYAPCs exemption request, and the staffs independent calculations, the staff has reasonable assurance that extending the vacuum drying time limits for the NAC-UMS system does not cause the fuel cladding to exceed its thermal limits and is acceptable.
However, staff found a slight discrepancy between the vacuum drying time limits proposed in the exemption request and the NAC-UMS amendment application. In particular, the time limits proposed in the exemption request for LCO 3.1.1.2 should be revised to be consistent with the NAC-UMS amendment application and the supporting analyzed design basis:
Heat Load (L) (kW) Time Limit (hours) 14 < L # 17.6 9 (requested 11 in the exemption request) 11 < L # 14 16 (requested 18 in the exemption request) 8 < L # 11 27 (requested 29 in the exemption request)
L#8 78 (requested 80 in the exemption request)
The exemption request values were 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> more than those analyzed in the amendment application. The licensee must use the values contained in the NAC-UMS amendment application, as presented above.