ML063450038
| ML063450038 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/08/2006 |
| From: | Ruland W NRC/NMSS/SFST |
| To: | Atkinson D Energy Northwest |
| Christopher Regan 301-415-1179 | |
| References | |
| COC 1014, IN-03-016 | |
| Download: ML063450038 (6) | |
Text
December 8, 2006 Mr. DK Atkinson Vice President, Nuclear Generation Energy Northwest Mail Drop PE08 P.O. Box 968 Richland, WA 99352-0968
SUBJECT:
EXEMPTION FROM 10 CFR 72.212 AND 72.214 FOR DRY SPENT FUEL STORAGE ACTIVITIES
Dear Mr. Atkinson:
This is in response to the Energy Northwest letter dated September 14, 2006, requesting an exemption from 10 CFR 72.212(a), 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 the Holtec International HI-STORM 100 Cask System Certificate of Compliance (CoC) No. 1014 (Amendment 1), Appendix B, Section 3.4.3.a., Site Specific Parameters and Analyses, for the 15 loaded freestanding casks on the Columbia Generating Station (CGS) Independent Spent Fuel Storage Installation (ISFSI). This exemption would relieve Energy Northwest from the requirement to maintain a coefficient of friction on the ISFSI pad surface of at least 0.53.
We understand that, in light of details provided in the U.S. Nuclear Regulatory Commission (NRC) Information Notice (IN) 2003-16, Icing Conditions Between Bottom of Dry Storage System and Storage Pad, and the susceptibility of the casks at the CGS ISFSI to the phenomena described in IN 2003-16, Energy Northwest developed compensatory measures during cold weather conditions to maintain the friction coefficient in accordance with Amendment 1 to CoC No. 1014. Institution of these compensatory measures has placed undue burden on the operational staff at the CGS ISFSI given that alternative methods have been approved by the NRC to ensure a comparable level of safety. As such, in lieu of the current requirement, Energy Northwest requested an exemption to perform an analysis consistent with that granted by the NRC in CoC No. 1014, Amendment 2, Appendix B, Section 3.4.3.b., which would provide CGS with relief from the performance of the compensatory measures necessary to ensure compliance with CoC No. 1014 (Amendment 1).
The NRC staff performed a safety evaluation of the proposed exemption. The staff reviewed the technical considerations provided by Energy Northwest and has reasonable assurance that the provisions of Section 3.4.3.b. of Appendix B of the CoC No. 1014, approved as part of Amendment 2 for Holtec International HI-STORM 100 Cask System, can be appropriately applied to the existing HI-STORM 100 casks constructed, loaded, and utilized at the CGS ISFSI under Amendment 1 of CoC No. 1014. The analyses that are to be completed under the provisions of Section 3.4.3.b. of Appendix B of Amendment 2 of CoC No. 1014 shall meet the requirements of 10 CFR 72.212 (b)(2)(i) and (b)(3). The enclosed safety evaluation report concludes that the requested changes will not pose an increased risk to public health and safety. Accordingly, the exemption will be effective immediately.
DK. Atkinson 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 has been prepared and published in the Federal Register (71 FR 70551, December 5, 2006). A copy of the Federal Register Notice was provided to you by letter dated November 20, 2006. Based on the foregoing considerations, the staff has determined that granting the proposed exemption from specific 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 relieves Energy Northwest of the requirement to maintain a coefficient of friction on the ISFSI pad surface of at least 0.53. The elimination of a required coefficient of friction value 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 Christopher M. Regan of my staff at 301-415-8500. Any future correspondence related to this action should reference Docket 72-35 and TAC No. L24030.
Sincerely,
/RA/
William H. Ruland, Deputy Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket No.: 72-35
Enclosure:
Safety Evaluation Report cc: Mailing List
DK. Atkinson 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 has been prepared and published in the Federal Register (71 FR 70551, December 5, 2006). A copy of the Federal Register Notice was provided to you by letter dated November 20, 2006. Based on the foregoing considerations, the staff has determined that granting the proposed exemption from specific 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 relieves Energy Northwest of the requirement to maintain a coefficient of friction on the ISFSI pad surface of at least 0.53. The elimination of a required coefficient of friction value 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 Christopher M. Regan of my staff at 301-415-8500. Any future correspondence related to this action should reference Docket 72-35 and TAC No. L24030.
Sincerely,
/RA/
William H. Ruland, Deputy Director Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards Docket No.: 72-35
Enclosure:
Safety Evaluation Report cc: Mailing List DISTRIBUTION:
NMSS r/f SFST r/f BWhite SAtwater, RIV RKeller, RIV BJBenney, NRR NJensen, OGC C:\FileNet\ML063450038.wpd OFC SFST E SFST E SFST SFST NAME CRegan EZiegler RShewmaker GBjorkman DATE 11/28 /06 11/ 30 /06 11/30 /06 11/ 30 /06 OFC SFST SFST NAME RNelson WRuland DATE 12/ 04 /06 12/ 08 /06 OFFICIAL RECORD COPY
Columbia Generating Station cc:
Mr. Dale Atkinson (Mail Drop PE08) Mr. Rodney L. Webring (Mail Drop PE04)
Vice President, Technical Services Vice President, Nuclear Generation Energy Northwest Energy Northwest P.O. Box 968 P.O. Box 968 Richland, WA 99352-0968 Richland, WA 99352-0968 Mr. Albert E. Mouncer (Mail Drop PE01) Thomas C. Poindexter, Esq.
Vice President, Corporate Services/ Winston & Strawn General Counsel/CFO 1400 L Street, N.W.
Energy Northwest Washington, DC 20005-3502 P.O. Box 968 Richland, WA 99352-0968 Mr. Bob Nichols Executive Policy Division Chairman Office of the Governor Energy Facility Site Evaluation Council P.O. Box 43113 P.O. Box 43172 Olympia, WA 98504-3113 Olympia, WA 98504-3172 Ms. Lynn Albin Mr. D. W. Coleman (Mail Drop PE20) Washington State Department of Health Manager, Performance Assessment P.O. Box 7827 and Regulatory Programs Olympia, WA 98504-7827 Energy Northwest P.O. Box 968 Mr. J. V. Parrish Richland, WA 99352-0968 Chief Executive Officer Energy Northwest Ms. Christina Perino (Mail Drop PE20) P.O. Box 968 (Mail Drop 1023)
Manager, Licensing Richland, WA 99352-0968 Energy Northwest P.O. Box 968 Richland, WA 99352-0968 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Chairman Benton County Board of Commissioners P.O. Box 190 Prosser, WA 99350-0190 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 69 Richland, WA 99352-0069
ENCLOSURE SAFETY EVALUATION REPORT Docket No. 72-35 Columbia Generating Station Independent Spent Fuel Storage Installation 1.0 Summary By letter dated September 14, 2006, Energy Northwest requested an exemption from the U.S.
Nuclear Regulatory Commission (NRC) requirements to maintain a specific coefficient of friction (COF) on the independent spent fuel storage installation (ISFSI) pad. Specifically, Holtec International HI-STORM 100 Cask System Certificate of Compliance (CoC) No. 1014 (Amendment 1), Appendix B, Section 3.4.3.a., Site Specific Parameters and Analyses, requires that a Coefficient of Friction (COF) of at least 0.53 be maintained on the ISFSI pad surface.
However, in lieu of this requirement Energy Northwest requested an exemption to perform an analysis consistent with that granted by the NRC in CoC No. 1014 Amendment 2, Appendix B, Section 3.4.3.b. which would provide CGS with relief from the performance of compensatory measures necessary to ensure compliance with CoC No. 1014 (Amendment 1) in light of the potential during winter for icing conditions, which may cause a significant reduction in the COF.
The NRC has evaluated the technical issues associated with this exemption and concluded in the discussion below that the proposed exemption does not pose an increased risk to public health and safety.
2.0 Discussion 2.1 Energy Northwest Evaluation Based on Energy Northwests evaluation of the information contained in NRC Information Notice (IN) 2002-16, Icing Conditions Between Bottom of Dry Storage System and Storage Pad, it was determined that the conditions described in the notice could occur at the Columbia Generating Station (CGS) storage pad for spent fuel storage casks. Icing conditions at the site can occur and would generally be confined to the period of time between November and March.
Energy Northwest has, since the notice was issued in October of 2003, instituted compensatory measures to preclude the formation of ice at the cask-to-pad interface. In order to justify suspension of the compensatory measures in the future during periods of potential icing relative to the Holtec HI-STORM 100 spent fuel storage casks on site that are authorized for storage under CoC No.1014, Amendment 1, Energy Northwest considered provisions contained in Amendment 2 of CoC No. 1014. The consideration of Amendment 2 provisions was limited to the provision relative to the icing conditions between a cask and the pad surface and the applicability to the currently stored casks, that number fifteen (15). Specifically, the provisions of Section 3.4.3.b. of Appendix B, CoC No. 1014, Amendment 2, were considered.
Energy Northwest evaluated the casks by comparing the elements and characteristics of casks produced under Amendment 1 with those produced under Amendment 2. The same comparison method was used for evaluation of the pads. The conclusion was that there were no appreciable differences in the two interacting components of the storage system that would warrant concern regarding the use of the Amendment 2 provision (CoC No. 1014, Amendment 2, Appendix B.3.4.3.b.) on casks produced, loaded and stored under the provisions of the CoC No. 1014, Amendment 1.
2.2 Staff Safety Evaluation The NRC staff reviewed the changes initiated and approved under the Holtec HI-STORM 100, Amendment 2 and the CoC No. 1014, Amendment 2, on the cask or the pad beyond Appendix B, Section 3.4.3.b, for any relevance in an evaluation of the behavior of a spent fuel storage cask under the controlling accident condition for lateral loading (seismic) of the casks on the concrete support pad. None of the changes associated with that amendment other than the subject section was determined to have any relevant influence on the proposed analyses.
Energy Northwest has stated that there will be a demonstration through the provisions of Section 3.4.3.b of Appendix B of the CoC No. 1014, Amendment 2, that the casks will not tip over or be caused to come off the supporting ISFSI pad under the worst lateral loading design conditions. If impacts between casks occur on the pad as a result of cask movement, the maximum g-load permitted as a result of impact will be the 45-g value, which is a cask system limit. The analyses that are to be completed under the provisions of Section 3.4.3.b. of Appendix B of Amendment 2 of the CoC No. 1014, shall meet the requirements of 10 CFR 72.212 (b)(2)(i) and (b)(3).
3.0 Conclusion The staff reviewed the evaluations provided by Energy Northwest in the exemption request to permit deviation from the ISFSI pad COF requirement of 0.53. The staff has reviewed and evaluated the application of Section 3.4.3.b. of Appendix B of Amendment 2 of CoC No. 1014 in lieu of the current requirement contained in Section 3.4.3.a. of Appendix B of Amendment 1 of CoC No. 1014 that the coefficient of friction be maintained at a minimum value of 0.53 and finds that there are no technical reasons why this methodology would be invalid. The acceptability of the analysis model and the subsequent analyses performed under Section 3.4.3.b., as well as the results, will have to be reviewed and evaluated under 10 CFR 72.212 by Energy Northwest.
On this basis, the staff concludes that the proposed exemption does not pose an increased risk to public health and safety.
4.0 References
- 1. Icing Conditions Between Bottom of Dry Storage System and Storage Pad, NRC Information Notice 2003-16, October 6, 2003.
- 2. Seismic Analysis Report on HI-STORM 100 Casks at Private Fuel Storage Facility, Revision 1, V.K. Luk, et al., Sandia National Laboratories, Albuquerque, NM, March 31, 2002.
- 3. Standard Review Plan for Dry Cask Storage Systems, NUREG-1536, U. S. Nuclear Regulatory Commission, January 1997.