ML062010042

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Memorandum to W. Ruland from J. Sebrosky Re Concerns Regarding Exemption from 10 CFR 72.48, 10 CFR 72.212 and 72.214 for Dry Spent Fuel Storage Activities - Fort Calhoun Station
ML062010042
Person / Time
Site: Fort Calhoun  Omaha Public Power District icon.png
Issue date: 07/19/2006
From: Joseph Sebrosky
NRC/NMSS/SFPO
To: Ruland W
NRC/NMSS/SFPO
Sebrosky J, NRC/NMSS 301-415-1132
References
Download: ML062010042 (5)


Text

July 19, 2006 NOTE TO: William H. Ruland, Deputy Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards THROUGH: Christopher M. Regan, Acting Chief /RA/

Licensing Section Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards FROM: Joseph M. Sebrosky, Senior Project Manager /RA/ by Stewart Brown for/

Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards

SUBJECT:

CONCERNS REGARDING EXEMPTION FROM 10 CFR 72.48, 10 CFR 72.212 AND 72.214 FOR DRY SPENT FUEL STORAGE ACTIVITIES - FORT CALHOUN STATION The purpose of this note is to respond to the concerns identified in an anonymous letter dated June 20, 2006, regarding Omaha Public Power Districts (OPPDs) exemption request dated June 9, 2006. The anonymous letter is publicly available in the records component of NRCs Agencywide Documents Access and Management System (ADAMS). The ADAMS accession number for the anonymous letter is ML061800438. OPPD requested in its June 9, 2006, letter an exemption from NRC regulations to enable the use of a light-weight transfer cask (TC) and allow an earlier start time for vacuum drying. The June 20, 2006, anonymous letter requests that the NRC deny OPPDs exemption request, because in general: 1) there is no valid basis for OPPD to file the exemption request or for the NRC to grant the exemption, 2) it would lead to higher doses for the workers, and 3) the possibility that use of the TC with temporary shielding introduces a new type of accident.

The need for the exemption was identified during an NRC inspection of the licensees preparation for the dry cask storage campaign. Interactions with the NRC led OPPD management to the determination that submittal of an exemption request was the optimum path forward for use of the light weight TC at the Fort Calhoun Station. Regarding the basis for NRC granting the exemption, 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. NRCs basis for granting OPPD an exemption is documented in its safety evaluation report (SER) dated July 19, 2006 (ADAMS accession no. ML062000153).

Regarding doses to the workers, in the SER the staff evaluates the use of the light-weight TC and measures taken to compensate for the removal of the lead shielding in the TC (e.g., use of supplemental shielding, remote operation of the spent fuel pool building crane, and use of fuel with a minimum cooling time of 16.2 years to reduce the dose rate). In the SER the staff evaluated the exemption against the shielding and dose requirements in 10 CFR Part 72 and 10 CFR Part 20 and concludes that these requirements are met. Regarding the possibility of

introducing a new type of accident because of the introduction of the temporary shielding, the staff also evaluated this issue in the SER. The staffs determination is that the temporary shielding does not introduce the possibility of an accident that is not bounded by previously analyzed accidents.

The staff placed four conditions on the exemption which are:

1) OPPD will be limited to loading a total of four 32PT DSCs.
2) OPPD shall limit the decay heat level per DSC to 11 kW to ensure cask loadings are bounded by the analyses supporting the TN CoC No. 1004, Amendment No. 8.
3) OPPD shall limit the cooling time of the fuel that it intends to load to a minimum of 16.2 years to ensure that the radiological source term for fuel that is loaded in the light weight TC is kept as low as reasonably achievable.
4) The TS 1.2.11 dose rate limit/specification are substituted with the limit of 170 mrem/hr in the axial direction and 110 mrem/hr in the radial direction. The axial dose rate limit of 170 mrem/hr is to be taken under the conditions in Table 1 below. The radial dose rate limit of 110 mrem/hr is to be taken under the conditions in Table 2 below.

Table 1 Axial Dose Rate Measurement Configuration 32PT DSC inside the OS197L inside the decon sleeve/bell water drained from the DSC TC/DSC annulus full (within approximately 1 foot of the top)

TC neutron shield full top shield plug in place and included in axial shielding inner top cover plate in place and included in axial shielding automated welding system (AWS) with integral shield in place and included in axial shielding measurement taken at vertical centerline of DSC, 3 feet from AWS shield

Table 2 Radial Dose Rate Measurement Configuration 32PT DSC inside OS197L inside decon sleeve/bell water drained from the DSC TC/DSC annulus full (within approximately 1 foot of the top)

TC neutron shield full 6 inch nominal thickness carbon steel decon sleeve/bell in place and included in radial shielding measurement taken at outside surface (contact) of decon sleeve/bell Given the staffs safety determination and the limited nature of the exemption, the staff believes that the issuance of the exemption is warranted. The NRC considers public involvement in our activities to be a cornerstone of strong, effective, and fair regulation of the nuclear industry.

The staff appreciates the concern regarding OPPDs exemption request being identified to us.

If there are questions regarding this issue please contact Joe Sebrosky at (301) 415-8500.

Docket Nos. 72-54, 50-285 cc: Service List

Table 2 Radial Dose Rate Measurement Configuration 32PT DSC inside OS197L inside decon sleeve/bell water drained from the DSC TC/DSC annulus full (within approximately 1 foot of the top)

TC neutron shield full 6 inch nominal thickness carbon steel decon sleeve/bell in place and included in radial shielding measurement taken at outside surface (contact) of decon sleeve/bell Given the staffs safety determination and the limited nature of the exemption, the staff believes that the issuance of the exemption is warranted. The NRC considers public involvement in our activities to be a cornerstone of strong, effective, and fair regulation of the nuclear industry.

The staff appreciates the concern regarding OPPDs exemption request being identified to us.

If there are questions regarding this issue please contact Joe Sebrosky at (301) 415-8500.

Docket Nos. 72-54, 50-285 cc: Service List Distribution:

AWang, NRR BSpitzberg, RIV E:\Filenet\ML062010042.wpd OFC SFP E SFPO E OGC E SFPO E SFPO E O

NAME JSebrosky EZiegler STreby(NLO) CRegan WRuland DATE 7/12/06 7/3/06 7/13/06 7/19/06 7/19/06 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY

Ft. Calhoun Station, Unit 1 Service List cc:

Winston & Strawn Mr. Daniel K. McGhee ATTN: James R. Curtiss, Esq. Bureau of Radiological Health 1700 K Street, N.W. Iowa Department of Public Health Washington, DC 20006-3817 Lucas State Office Building, 5th Floor 321 East 12th Street Chairman Des Moines, IA 50319 Washington County Board of Supervisors P.O. Box 466 Mr. R. T. Ridenoure Blair, NE 68008 Vice President - Chief Nuclear Officer Omaha Public Power District Mr. John Hanna, Resident Inspector Fort Calhoun Station FC-2-4 Adm.

U.S. Nuclear Regulatory Commission Post Office Box 550 P.O. Box 310 Fort Calhoun, Nebraska 68023-0550 Fort Calhoun, NE 68023 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Mr. David J. Bannister, Manager Fort Calhoun Station Omaha Public Power District Fort Calhoun Station FC-1-1 Plant P.O. Box 550 Fort Calhoun, NE 68023-0550 Mr. Joe L. McManis Manager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.

P.O. Box 550 Fort Calhoun, NE 68023-0550