ML061010421
| ML061010421 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/11/2006 |
| From: | Ruland W NRC/NMSS/SFPO |
| To: | Mckinney B Susquehanna |
| Sebrosky J, NRC/NMSS 301-415-1132 | |
| References | |
| TAC L23943 | |
| Download: ML061010421 (12) | |
Text
April 11, 2006 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467
SUBJECT:
EXEMPTION FROM 10 CFR 72.212 AND 72.214 FOR DRY SPENT FUEL STORAGE ACTIVITIES - SUSQUEHANNA STEAM ELECTRIC STATION (TAC NO. L23943)
Dear. Mr. McKinney:
This is in response to your letter dated January 31, 2006, as supplemented on March 6, 2006, requesting an exemption from 10 CFR 72.212(a)(2), 72.212(b)(2)(i)(A), 72.212(b)(7), and 10 CFR 72.214, pursuant to 10 CFR 72.7. These regulations specifically require storage in casks approved under the provisions of 10 CFR Part 72 and compliance with the conditions set forth in the Certificate of Compliance (CoC) for each dry spent fuel storage cask used by an independent spent fuel storage installation (ISFSI) general licensee.
The Transnuclear, Inc. (TN) NUHOMS CoC No. 1004 provides requirements, conditions, and operating limits in Attachment A, Technical Specifications. In your January 31, 2006, letter PPL Susquehanna, LLC (PPL or licensee) requested an exemption from the requirements of 10 CFR 72.212(a)(2), 10 CFR 72.212(b)(2)(i)(A), 10 CFR 72.212(b)(7) and 10 CFR 72.214 from a condition in Amendment 8 to CoC No. 1004 so that Framatome ANP 9x9-2 fuel assemblies can be loaded in a NUHOMS -61BT dry shielded canister (DSC). Specifically, the exemption would be from CoC No. 1004 Attachment A, Technical Specification, Table 1-1d, BWR Fuel Assembly Design Characteristics for the NUHOMS - 61BT DSC, which allows for the storage of General Electric (or equivalent) 9x9-2 fuel assemblies that contain 66 full and 8 partial fuel rods. The exemption would allow PPL to store Framatome ANP 9x9 -2 fuel assemblies that contain 79 full fuel rods and no partial fuel rods in the NUHOMS -61BT DSC.
In your letter of January 31, 2006, PPL committed to loading Framatome ANP 9x9-2 fuel assemblies with a maximum decay heat load per assembly of 210 watts. This is less than the CoC No. 1004 Attachment A, Technical Specification, Table 1-1c maximum decay heat limit of 300 watts per assembly. In addition, in your March 6, 2006, submittal PPL provided the parameters found in Table 1 below associated with the Framatome ANP 9x9-2 fuel assembly.
B. McKinney Table 1 Parameters for Framatome ANP 9x9-2 Fuel Assembly Manufacturer: Framatome ANP Array: 9x9 Version: FANP9 Active Fuel Length 150 (inches):
Number of Fuel Rods 79 full Pitch (inches): 0.572 per Assembly:
Fuel Pellet Outside 0.3565 Clad Thickness 0.030 Diameter (inches): (inches):
Clad Outside 0.424 Water Rod Outside 0.425 Diameter (inches): Diameter (inches):
Water Rod Inside 0.364 Diameter (inches):
We understand that PPL requested this exemption to begin the transfer of the PPL Susquehanna Steam Electric Station (SSES) spent fuel pool contents to the ISFSI in May 2006.
PPL stated that the exemption is necessary because SSES will lose full core offload capability in December 2006 following the receipt and storage of new fuel for the scheduled 2007 Unit 2 refueling outage. PPL has determined that it is necessary to start the dry fuel storage (DFS) campaign in May 2006 to ensure full core offload capability. PPL had originally scheduled a DFS campaign to begin in October 2006. However, because of recent SSES Unit 1 fuel channel performance problems, 54 fuel channels were replaced and stored in the spent fuel pool. Due to this fuel channel problem, a possible Unit 2 mid-cycle maintenance outage may be necessary to inspect and replace, if necessary, any affected fuel channels. This mid-cycle outage is tentatively scheduled for Fall 2006 and access to the spent fuel pool is needed to store fuel channels that are replaced. This activity would conflict with loading dry fuel storage casks. There is also a conflict with performing the DFS campaign in Summer 2006.
Specifically, PPL has contracted to perform a spent fuel pool cleanout beginning in June 2006 so adequate pool space is restored to support the Unit 2 2007 refueling outage. The DFS campaign and the spent fuel pool cleanout campaign cannot occur simultaneously.
Rescheduling the spent fuel cleanout campaign for later in the year is difficult. In summary, space available in the spent fuel pool has become limited much sooner than anticipated, and PPL is requesting the exemption to support a DFS campaign in May 2006. A DFS campaign in May 2006 will also allow PPL flexibility for fuel storage options related to managing decay heat loads within the spent fuel pool.
PPL indicated in its January 31, 2006, letter, that TN is preparing a proposed Amendment No. 9 to CoC No. 1004, which would include the Framatome ANP 9x9-2 fuel assemblies as part of the authorized contents for the NUHOMS-61BT storage system. PPL further indicated that proposed Amendment No. 9 is scheduled to be submitted to the NRC in March - April 2006.
The exemption is necessary because the NRC has not yet received an amendment to CoC No. 1004 to allow loading of a Framatome ANP 9x9-2 in a NUHOMS 61BT DSC. The staff
B. McKinney would have to review such an amendment request and only after making the appropriate findings would the staff initiate 10 CFR 72.214 rulemaking to implement the change. This process typically takes at least 10 months from the receipt of the amendment request for focused license amendments. Complex license amendments can take over 30 months.
Therefore, an amendment to allow loading of Framatome ANP 9x9-2 fuel assemblies in the NUHOMS -61BT DSC can not be completed in time to support PPLs stated needs.
PPL requested in its January 31, 2006, letter that the exemption be in effect until the completion of PPLs 2008 DFS campaign or 60 days after Amendment 9 is issued. The staff does not agree with this proposed term of the exemption. The staff believes that the use of exemptions in regulatory activities should be minimized. The staff also believes that the normal process for approving changes to an issued Certificate of Compliance (CoC) which is through a rulemaking process based on an application received from the CoC holder should be used whenever possible. In this case, Transnuclear, Inc. (TN) has not yet submitted an amendment request for CoC No. 1004 in order to allow storage of the Framatome ANP 9x9 fuel assemblies in the Standardized NUHOMS 61BT dry shielded canister (DSC).
Although an amendment has not yet been submitted, the staff believes that a focused amendment can be submitted in the short term to for loading of Framatome ANP 9x9-2 fuel assemblies in the TN NUHOMS -61BT DSC. The staff would review such an amendment request in accordance with its normal process. PPL has indicated that if five TN NUHOMS -
61BT DSCs were loaded in Spring 2006, this would prevent the loss of full core offload capability in December 2006. It is the staffs understanding that full core offload capability would not be in jeopardy again until the Summer 2007. Therefore, the staff is limiting the exemption to loading of five TN NUHOMS -61BT DSCs.
The U.S. Nuclear Regulatory Commission (NRC) staff performed a safety evaluation of the proposed exemption and commitments. The enclosed safety evaluation concludes that the staff has reasonable assurance that allowing PPL to load Framatome ANP 9x9-2 fuel assemblies in the TN NUHOMS -61BT DSC will not pose an increased risk to public health and safety. For this action, an Environmental Assessment and Finding of No Significant Impact has been prepared and published in the Federal Register ( 71 FR 18367, dated April 11, 2006). A copy of the Federal Register Notice was provided to you by letter dated March 31, 2006.
Based on the foregoing considerations, the NRC has determined that granting the proposed exemption from the provisions of 10 CFR 72.212(a)(2), 72.212(b)(2)(i)(A), 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. Accordingly, the NRC hereby grants this exemption effective immediately. This exemption is subject to the following conditions:
- 2) PPL shall limit the decay heat level per fuel assembly to 210 watts to ensure cask loadings are bounded by the analyses supporting TN CoC No. 1004, Amendment No. 8.
- 3) This exemption pertains only to Framatome ANP 9x9 -2 fuel assemblies that meet the nominal un-irradiated design parameters contained in Table 1 above.
B. McKinney If you have any questions, please contact me or Joseph Sebrosky of my staff at 301-415-8500.
Any future correspondence related to this action should reference Docket No. 72-28 and TAC No. L23934.
Sincerely,
/RA/
William H. Ruland, Deputy Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Docket Nos. 72-28 (50-387, 50-388)
Enclosure:
Safety Evaluation cc: Service List
B. McKinney If you have any questions, please contact me or Joseph Sebrosky of my staff at 301-415-8500.
Any future correspondence related to this action should reference Docket No. 72-28 and TAC No. L23934.
Sincerely,
/RA/
William H. Ruland, Deputy Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Docket Nos. 72-28 (50-387, 50-388)
Enclosure:
Safety Evaluation cc: Service List Distribution: (Closes TAC No. L23943)
NMSS r/f SBaggett RGuzman, NRR MMiller, RI E:\Filenet\ML061010421.wpd OFC SFPO E SFPO E SFPO E SFPO E SFPO E SFPO NAME JSebrosky EZiegler BWilson AHansen LCampbell GBjorkman DATE 3/31/06 3/8/06 3/8/06 3/9/06 3/9/06 3/21/06 OFC SFPO E SFPO E SFPO E NAME STreby(NLO) RNelson WRuland DATE 3/22/06 3/24/06 4/11/06 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:
Robert A. Saccone Steven M. Cook Vice President - Nuclear Operations Manager - Quality Assurance PPL Susquehanna, LLC PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Berwick, PA 18603-0467 Aloysius J. Wrape, III Luis A. Ramos General Manager - Performance Community Relations Manager, Improvement and Oversight Susquehanna PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 634 Salem Blvd., SSO Allentown, PA 18101-1179 Berwick, PA 18603-0467 Terry L. Harpster Bryan A. Snapp, Esq General Manager - Plant Support Assoc. General Counsel PPL Susquehanna, LLC PPL Services Corporation 769 Salem Blvd., NUCSA4 Two North Ninth Street, GENTW3 Berwick, PA 18603-0467 Allentown, PA 18101-1179 Richard D. Pagodin Supervisor - Document Control Services General Manager - Nuclear Engineering PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 769 Salem Blvd., NUCSB3 Allentown, PA 18101-1179 Berwick, PA 18603-0467 Richard W. Osborne Rocco R. Sgarro Allegheny Electric Cooperative, Inc.
Manager - Nuclear Regulatory Affairs 212 Locust Street PPL Susquehanna, LLC P.O. Box 1266 Two North Ninth Street, GENPL4 Harrisburg, PA 17108-1266 Allentown, PA 18101-1179 Director, Bureau of Radiation Protection Walter E. Morrissey Pennsylvania Department of Supervising Engineer Environmental Protection Nuclear Regulatory Affairs Rachel Carson State Office Building PPL Susquehanna, LLC P.O. Box 8469 769 Salem Blvd., NUCSA4 Harrisburg, PA 17105-8469 Berwick, PA 18603-0467 Senior Resident Inspector Michael H. Crowthers U.S. Nuclear Regulatory Commission Supervising Engineer P.O. Box 35, NUCSA4 Nuclear Regulatory Affairs Berwick, PA 18603-0035 PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Regional Administrator, Region 1 Allentown, PA 18101-1179 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:
Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803
SAFETY EVALUATION REPORT EXEMPTION FOR PPL SUSQUEHANNA LLC SUSQUEHANNA STEAM ELECTRIC STATION INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NO. 72-28 1.0
SUMMARY
By letter letter dated January 31, 2006, as supplemented on March 6, 2006, PPL Susquehanna, LLC (PPL or licensee) requested an exemption from 10 CFR 72.212(a)(2), 72.212(b)(2)(i)(A),
72.212(b)(7), and 10 CFR 72.214, pursuant to 10 CFR 72.7. These regulations specifically require storage in casks approved under the provisions of 10 CFR Part 72 and compliance with the conditions set forth in the Certificate of Compliance (CoC) for each dry spent fuel storage cask used by an independent spent fuel storage installation (ISFSI) general licensee.
The Transnuclear, Inc. (TN) NUHOMS CoC No. 1004 provides requirements, conditions, and operating limits in Attachment A, Technical Specifications. In its January 31, 2006, letter PPL requested an exemption from the requirements of 10 CFR 72.212(a)(2),
10 CFR 72.212(b)(2)(i)(A), 10 CFR 72.212(b)(7) and 10 CFR 72.214 from a condition in Amendment 8 to CoC No. 1004 so that Framatome ANP 9x9-2 fuel assemblies can be loaded in a NUHOMS -61BT dry shielded canister (DSC). Specifically, the exemption would be from CoC No. 1004 Attachment A, Technical Specification, Table 1-1d, BWR Fuel Assembly Design Characteristics for the NUHOMS - 61BT DSC, which allows for the storage of General Electric (or equivalent) 9x9-2 fuel assemblies that contain 66 full and 8 partial fuel rods. The exemption would allow PPL to store Framatome ANP 9x9 -2 fuel assemblies that contain 79 full fuel rods and no partial fuel rods in the NUHOMS -61BT DSC.
The licensee requested this exemption to begin the transfer of the PPL Susquehanna Steam Electric Station (SSES) spent fuel pool contents to the independent spent fuel storage installation (ISFSI) in May 2006. The licensees justification for the exemption is that it is necessary because SSES will lose full core offload capability in December 2006 following the receipt and storage of new fuel for the scheduled 2007 Unit 2 refueling outage. PPL has determined that it is necessary to start the dry fuel storage (DFS) campaign in May 2006 to ensure full core offload capability. PPL had originally scheduled a DFS campaign to begin in October of 2006. However, because of recent SSES Unit 1 fuel channel performance problems, 54 fuel channels were replaced and stored in the spent fuel pool. As a result of this fuel channel problem, a possible Unit 2 mid-cycle maintenance outage may be necessary to inspect and replace, if necessary, any affected fuel channels. This mid-cycle outage is tentatively scheduled for the Fall of 2006 and access to the spent fuel pool is needed to store fuel channels that are replaced. This activity would conflict with loading dry fuel storage casks.
ENCLOSURE
There is also a conflict with performing the DFS campaign in the Summer of 2006. Specifically, PPL has contracted to perform a spent fuel pool cleanout beginning in June 2006 so adequate pool space is restored to support the Unit 2 2007 refueling outage. The DFS campaign and the spent fuel pool cleanout campaign cannot occur simultaneously. Rescheduling the spent fuel cleanout campaign for later in the year is difficult. In summary space available in the spent fuel pool has become limited much sooner than anticipated, and PPL is requesting the exemption to support a DFS campaign in May of 2006. A DFS campaign in May of 2006 will also allow PPL flexibility for fuel storage options related to managing decay heat loads within the spent fuel pool.
PPL indicated in its January 31, 2006, letter, that TN is preparing a proposed Amendment No. 9 to CoC No. 1004, which would include the Framatome ANP 9x9-2 fuel assemblies as part of the authorized contents for the NUHOMS-61BT storage system. PPL further indicated that proposed Amendment No. 9 is scheduled to be submitted to the NRC in March - April 2006.
The exemption is necessary because the NRC has not yet received an amendment to CoC No. 1004 to allow loading of a Framatome ANP 9x9-2 in a NUHOMS 61BT DSC. The staff would have to review such an amendment request and only after making the appropriate findings would the staff initiate 10 CFR 72.214 rulemaking to implement the change. This process typically takes at least 10 months from the receipt of the amendment request for focused license amendments. Complex license amendments can take over 30 months.
Therefore, an amendment to allow loading of Framatome ANP 9x9-2 fuel assemblies in the NUHOMS -61BT DSC can not be completed in time to support PPLs stated needs.
PPL requested in its January 31, 2006, letter that the exemption be in effect until the completion of PPLs 2008 DFS campaign or 60 days after Amendment 9 is issued. The staff does not agree with this proposed term of the exemption. The staff believes that the use of exemptions in regulatory activities should be minimized. The staff also believes that the normal process for approving changes to an issued Certificate of Compliance (CoC) which is through a rulemaking process based on an application received from the CoC holder should be used whenever possible. In this case, Transnuclear, Inc. (TN) has not yet submitted an amendment request for CoC No. 1004 in order to allow storage of the Framatome ANP 9x9 fuel assemblies in the Standardized NUHOMS 61BT dry shielded canister (DSC).
Although an amendment has not yet been submitted the staff believes that a focused amendment can be submitted in the short term to allow loading of Framatome ANP 9x9-2 fuel assemblies in the TN NUHOMS -61BT DSC. The staff would review such an amendment request in accordance with its normal process. PPL has indicated that if five TN NUHOMS -
61BT DSCs were loaded in Spring of 2006 this would prevent the loss of full core offload capability in December 2006. It is the staffs understanding that full core offload capability would not be in jeopardy again until the Summer of 2007. Therefore, the staff is limiting the exemption to loading of five TN NUHOMS -61BT DSCs.
The NRC has evaluated the technical issues associated with this exemption request and proposed commitments and concludes in the discussion below that the proposed additions and revisions do not pose any increased risk to public health and safety.
2.0 DISCUSSION TN NUHOMS-61BT System The licensees exemption request includes a request to allow storage of spent fuel from SSES under its 10 CFR Part 72 general license in the TN NUHOMS-61BT DSC. Specifically, the licensee requests storage of Framatome ANP 9x9-2 fuel assemblies that are not currently authorized to be loaded in a NUHOMS- 61BT DSC.
The NUHOMS-61BT DSC provides confinement and criticality control for the storage and transfer of irradiated fuel. The two digits refer to the number of fuel assemblies stored in the DSC, the character B for boiling water reactor (BWR) is to designate the type of fuel stored, and T is to designate that the DSC is intended for transportation in a 10 CFR Part 71 approved package. The principal component subassemblies of the DSC are the shell with integral bottom cover plate, bottom shield plug or shield plug assemblies, ram/grapple ring, top shield plug or shield plug assemblies, top cover plate, and basket assembly. The shell length is fuel-specific.
The internal basket assembly for the NUHOMS -61BT DSC consists of assemblies of stainless steel fuel compartments held in place by basket rails and a holddown ring, and is designed to hold 61 BWR assemblies. The basket assembly aids in the insertion of the fuel assemblies, enhances subcriticality during loading operations, and provides structural support during a hypothetical drop accident.
The staff has determined that the Framatome ANP 9x9-2 fuel assembly is bounded by other fuel types allowed to be loaded in the NUHOMS -61BT DSC. The staffs thermal, criticality and other evaluations are documented below.
Thermal Evaluation The staff evaluated the applicants thermal analyses for normal conditions of storage and transfer following the requirements stated in 10 CFR Part 72.
PPL compared the key parameters of the different fuel assembly (Framatome ANP 9x9-2) with the NUHOMS -61BT design basis fuel parameters, including maximum decay heat load, total decay heat load, and maximum assembly average burnup. In addition, comparisons of density, heat capacity and thermal conductivity were summarized.
PPL concluded that the design parameters for the design basis fuel assembly used in Chapter K.4 of the Final Safety Analysis Report (FSAR) for the Standardized NUHOMS Horizontal Modular Storage System bound the Framatome ANP 9x9-2 fuel assembly. PPL also committed to only loading Framatome ANP 9x9-2 fuel assemblies with a maximum decay heat load per assembly of 210 watts. This is less than the CoC No. 1004 Attachment A, Technical Specification, Table 1-1c maximum decay heat limit of 300 watts per assembly.
The staff reviewed the comparisons and found that there is reasonable assurance that the Framatome ANP 9x9-2 fuel meets the thermal requirements of 10 CFR Part 72.
Criticality Evaluation Other Evaluation In its January 31, 2006, letter, PPL states that the structural evaluation, shielding evaluation, and confinement evaluation, for the Framatome ANP 9x9-2 fuel assembly are bounded by the
evaluations contained in Section K.3, K.5, and K.7, respectively, of the FSAR for the Standardized NUHOMS Horizontal Modular Storage System.
Regarding the structural evaluation, the applicant states that all of the design parameters for the design basis fuel assembly used in Chapter K.3 of the FSAR for the NUHOMS 61BT DSC (e.g., total fuel assembly weight, temperatures, and pressures) bound the Framatome ANP 9x9-2 fuel assembly. As a result, the applicant maintains that all of the structural evaluation results in Chapter K.3 of the FSAR are bounding for the Framatome ANP 9x9-2 fuel assembly.
Based on the staff's review of the licensees submittal, and their general knowledge of the Framatome ANP 9x9-2 fuel assembly and the structural behavior of the assemblies, the staff concludes there is reasonable assurance that the Framatome ANP 9x9-2 fuel assembly is bounded by other assemblies already approved for the NUHOMS 61BT DCS. The staff therefore, finds that the Framatome ANP 9x9-2 fuel meets the structural requirements of 10 CFR Part 72.
Regarding the shielding evaluation, the applicant stated that the heavy metal loading (uranium) of the Framatome ANP 9x9-2 fuel assembly is lower than the design basis fuel assembly (GE 7x7) therefore, for the same burnup and cool time, the source term from the Framatome ANP 9x9-2 fuel assembly will be lower than for the GE 7x7. Additionally, the applicant stated that the cobalt content of each fuel assembly region (i.e. bottom, incore, gas plenum and top) are lower than for the design basis fuel assembly, yielding lower cobalt source term. Based on its review of the representations and information supplied by the applicant, the staff concludes that loading Framatome ANP 9x9-2 fuel assemblies in a NUHOMS 61BT DSC meets the shielding requirements of 10 CFR Part 72.
Regarding the confinement analysis, the applicant states that this evaluation is not affected by the authorized contents and therefore remains applicable when the Framatome ANP 9x9-2 fuel assembly is added to the authorized contents. The staff agrees with this statement, therefore, the staff concludes that loading Framatome ANP 9x9-2 fuel assemblies in a NUHOMS 61BT DSC meets the confinement requirements of 10 CFR Part 72.
3.0 CONCLUSION
The staff reviewed the analyses provided by PPL in the exemption request, as supplemented, to allow use of the Framatome ANP 9x9-2 fuel assembly in TN NUHOMS-61BT DSC. 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)(A), 72.212(b)(7), and 10 CFR 214 is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest. Accordingly, the requested exemption does not pose an increased risk to public health and safety and is acceptable subject to the following conditions:
- 2) PPL shall limit the decay heat level per fuel assembly to 210 watts to ensure cask loadings are bounded by the analyses supporting TN CoC No. 1004, Amendment No. 8.
- 3) This exemption pertains only to Framatome ANP 9x9 -2 fuel assemblies that meet the nominal un-irradiated design parameters contained in Table 1 above.