ML061020461

Ltr. to E. Epstein, TMI-Alert, Concerns Regarding Exemption from 10 CFR 72.212 and 72.214 for Dry Spent Fuel Storage Activities - Susquehanna Steam Electric Station

ML061020461
Person / Time
Site:	Susquehanna
Issue date:	04/12/2006
From:	Ruland W NRC/NMSS/SFPO
To:	Epstein E Three Mile Island Alert
Sebrosky J, NRC/NMSS 301-415-1132
References
Download: ML061020461 (5)

Text

April 12, 2006 Mr. Eric J. Epstein TMI-Alert Chairman 4100 Hillsdale Road Harrisburg, PA 17112

SUBJECT:

CONCERNS REGARDING EXEMPTION FROM 10 CFR 72.212 AND 72.214 FOR DRY SPENT FUEL STORAGE ACTIVITIES - SUSQUEHANNA STEAM ELECTRIC STATION

Dear Mr. Epstein:

This letter is in response to your concerns regarding PPL Susquehanna, LLCs (PPLs) spent fuel exemption request for the Susquehanna Steam Electric Station (SSES) dated January 31, 2006. We discussed your issues during a March 14, 2006, phone call and you subsequently sent us a facsimile that documented your concerns. A summary of the phone call and the subsequent facsimile are publicly available in the records component of NRCs Agencywide Documents Access and Management System (ADAMS). The ADAMS accession numbers for the phone call summary and the facsimile are ML060760021, and ML060750103, respectively.

In your facsimile, you ask the NRC to deny the exemption because, in general, we would not be using our normal review process.

NRCs regulations permit licensees to seek exemptions in special circumstances which NRC may grant if it determines that the exemption is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest. The NRC staff acknowledges that by granting this exemption request, we will not use 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. 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).

PPLs need for an exemption is due to its potential loss of full-core offload capability. The NRC staff performed a safety evaluation of the request and issued a Safety Evaluation Report documenting its finding that there is no safety reason for denying the exemption request.

Further, the staff limited the use of the exemption it has granted to PPL to the loading of five canisters (see NRCs letter of April 11, 2006, ADAMS accession number ML061010421). The staff placed this limit in the exemption to prevent the loss of full-core offload capability to the SSES spent fuel pool in the near term while at the same time providing TN time to request a focused amendment that will allow loading of Framatome ANP 9x9-2 fuel assemblies in the TN NUHOMS 61BT DSC. This is expected to enable PPL to avoid the need for any further exemptions in utilizing dry storage casks. Given the staffs safety determination and the limited nature of the exemption, we believe issuance of the exemption is warranted.

E. Epstein The NRC considers public involvement in our activities to be a cornerstone of strong, effective, and fair regulation of the nuclear industry. We appreciate you sharing your concerns about PPLs exemption with us. If you have any additional questions, please contact me or Joseph Sebrosky at (301) 415-8500.

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) cc: Service List

E. Epstein The NRC considers public involvement in our activities to be a cornerstone of strong, effective, and fair regulation of the nuclear industry. We appreciate you sharing your concerns about PPLs exemption with us. If you have any additional questions, please contact me or Joseph Sebrosky at (301) 415-8500.

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) cc: Service List Distribution:

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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