ML120650735
| ML120650735 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/17/2012 |
| From: | Peterson A State of NY, Energy Research & Development Authority |
| To: | Boska J Plant Licensing Branch 1 |
| Boska J, NRR/DORL, 301-415-2901 | |
| References | |
| TAC ME1671, TAC ME1672 | |
| Download: ML120650735 (6) | |
Text
a Energy. Innovation. Solutions.
February 17, 2012 John Boska, Senior Project Manager Plant Licensing Branch I-i Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Mail Stop: O-8C2 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Comments on Indian Point License Amendment Request for Inter-unit spent fuel transfer
Dear Mr. Boska:
The State of New York welcomes the opportunity to provide comments on the July 2009 license amendment request submitted by Entergy to allow transfer of spent fuel from the spent fuel pool at Indian Point Unit 3 to the spent fuel pool at Unit 2. The enclosed consolidated comments are submitted on behalf of the New York State Departments of Public Service and Environmental Conservation.
Thank you for accepting our comments. We look forward to continuing to work with NRC to ensure that any actions performed in relation to this request are completed in the safest possible manner.
Sincerely, Alyse Peterson Senior Project Manager State Liaison Officer Designee New York state Energy Research and Development Authority Albany Buffalo New York City west valley Site 17 Columbia Circle, Albany, NY 12203-6399 726 Exchange Street 485 Seventh Avenue Management Program 1(866) NYSERDA (518) 862-1091 Suite 821 Suite 1006 9030-B Route 219 Buffalo, NY New York, NY West Valley, NY nyserda.ny.gov I
info@nyserda.org 14210-1484 10018-6815 14171-9500 (716) 842-1522 (212) 971-5342 (716) 942-9960 Francis J. Murray, Jr., President and CEO (716) 842-0156 (518)862-1091 (716) 942-9961
Indian Point Unit 3 Spent Fuel Move February 17, 2012 Consolidated Comments of the New York State Executive Agencies: Department of Public Service and Department of Environmental Conservation
Background
Indian Point Unit 3 has been accumulating spent fuel and other high level waste items in the spent fuel pool (SF1) since initial operation of the plant in 1976. Modifications to the original design of the SFPs ability to store fuel has increased the amount of spent fuel stored to what we believe is one of the most, if not the most densely stored pool in the country. There are over 1,200 spent fuel assemblies in the Unit 3 SFP and the pool is at capacity.
The process of removal of fuel from a SFP to dry cask storage is an approved process that has been installed at numerous nuclear plants in the country, including Indian Point Unit 2. However, at Indian Point Unit 3 the design of the SFP storage building is such that direct removal of fuel into dry cask storage canisters is not easily accomplished, short of constructing an entire new building over the existing building. This would in itself pose a different array of issues. The main issues are crane capacity, building configuration, and cask transport issues. A dry cask, similar to what is used at Indian Point Unit 2, fully loaded weighs approximately 117 tons. The capacity of the crane in the Unit 3 spent fuel building is only 40 tons.
To accomplish moving fuel from Unit 3, Entergy has proposed moving smaller batches of fuel from the Unit 3 SFP and placing them into the Unit 2 SFP. This requires upgrading the Unit 3 fuel storage building crane to a 40-ton capacity with single failure design; designing a special cask for handling smaller loads (maximum 12 assemblies); leveling the fuel storage building floor and enlarging the doorway; relocating tool racks; upgrading the roadway between the two units fuel storage buildings; and modifying the protected area of the site.
Entergy elected to proceed with a license amendment to have a new cask design and the changes necessary to achieve the movement of fuel from Unit 3 to Unit 2. Entergy filed the initial amendment on July 8,2009. Entergy filed several additional responses to NRC requests for additional information (RAI) to address issues such as operating procedures, principal design criteria, materials evaluation, shielding design, structural evaluation, thermal hydraulics, criticality, and general information.
These comments are offered solely in the context of the current operating license for Indian Point Unit 3. The State of New York maintains its position that the NRC should not renew the licenses for Indian Point Unit 2 and Unit 3 and these comments are not intended nor should they be construed to modify or in any way affect that position.
Consequence of Not Approving Entergys Application As stated earlier, there are over 1200 spent fuel assemblies currently stored in the Unit 3 SFP.
The reactor core holds 193 assemblies. Based on capacity of the pool and the elements stored, there is not sufficient space in the spent fuel pool for a full core off-load, should that be necessary. The plant has been operating in this risky condition for the last two fuel cycles. Should a situation arise where fuel needs to be removed from the reactor, the plant would become idle until enough fuel is removed from the pool to make room.
Likewise, at the current time, Unit 3 cannot perform a normal refueling of the reactor. If sufficient fuel is not removed from the SFP before the next scheduled refueling of the reactor in March 2013, the plant will become fuel congested and not be able to refuel to resume normal operation.
Concerns Although the NRC and Entergy have addressed and resolved numerous issues that were of concern to the State, we remain primarily concerned with the multiple interactions needed for this operation given the potential for accidents and the fact that accidents have occurred in the past.
Paramount to these concerns is the multiple handling of the spent fuel. This is the only plant in this country, and to the best of our research, in the world, that will have to move fuel in the proposed manner. Normally, fuel would be handled only once as it is moved from the spent fuel pool directly into dry cask storage and transported to an Independent Spent Fuel Storage Installation (ISFSI). However, because of the inability to move fuel directly to dry cask storage, the proposed method would cause each spent fuel assembly to be handled three times before it reaches the ISFSI. This increase in handling likewise increases the risk of an accident.
Numerous examples of fuel handling issues have been documented. When the NRC was asked for a record of the fuel handling mishaps in the United States, it replied that it does not keep statistics of these events. Our review has shown that numerous fuel handling events have occurred. Some examples of fuel and fuel related incidents include the following:
Spent fuel assembly separated from the handling tool and fell on top of the spent fuel rack; Damage to fuel assemblies during refueling operations due to misalignment; Incorrect fuel bundle moved during fuel shuffle; Fuel assembly dropped in spent fuel pool from the fuel handling crane; Fuel bundle miss-oriented during fuel movements; Fuel assembly dropped 4 causing assembly damage; Absorber control rod dropped in transfer channel during core component handling; During cask loading, fuel bundle placed in wrong cell location in the cask; During dry run cask handling, an electrical failure occurred leaving the cask suspended; New fueF miss-positioned in an incorrect location in the spent fuel pool; and, Fuel assembly improperly grappled and dropped 2 feet in the spent fuel pool.
Additionally, Entergy has identified the dry cask-refuel functions as a most error likely task for the radiological safety risk activity category. This and the above examples support our concern for increased risk of an adverse condition to occur during fuel spent moves, and for extraordinary precautions.
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Under the current license and the proposed license amendment Entergy has no approved plan for moving damaged fuel. The State recommends that Entergy and the NRC develop a supplemental amendment that will address the removal of damaged fuel.
Adequate Protection NRC Commissioner William C. Ostendorff addressed the issue of Adequate Protection in his April 29, presentation Regulatory Decision-Making in the Wake of Fukushima to the 2011 Edison Electric Institutes Spring Legal Conference. In this presentation, Commissioner Ostendorif reiterated the NRCs statutory hallmark as reasonable assurance of adequate protection of public health and safety and common defense and security. He aptly pointed out that the courts and the NRC have historically refused to define adequate protection. Continuing, he outlined four general principles of adequate protection: an extremely broad grant of authority; a nexus to radiological health and safety; determined on a case-by-case basis; and does not mean zero risk.
In addition to these four general principles, Commissioner Ostendorff identified four areas for risk consideration: 1) assessment of probabilities and consequences; 2) concerns based on realistic assumptions: real world safety, security or legal issues; 3) not looking for zero risk; and 4) critical function of NRC and Commissioners to decide how much risk is acceptable. Highly irradiated spent fuel is perhaps the most important area in which these guiding principles must be strictly adhered.
Commissioner Ostendorif clearly made his case that zero risk is not the standard. However, the handling of lethal spent fuel is an area where maximum risk avoidance should be the goal. Every possible action that can be taken to avoid or minimize the risk of exposure to spent fuel must be taken.
This is the responsibility of Entergy as the licensee, and the NRC inspectors, other staff, management, and Commissioners. Anything less is unacceptable. The need to redefine adequate protection was also discussed during the NRCs September 14, 2011 Briefing on the Japan Near Term Task Force Report Short-Term Actions. This adds extra emphasis on the need to take all possible actions available to make this project as safe as possible.
We recognize that the NRC sees the safety of this project as its chief responsibility that must be administered without pressure from licensees or other parties. Contained herein, we have proposed several preventive measures to address the myriad concerns that the State has that we believe enhance the protections already in place. We respectfully request that the NRC adopt these measures.
Additional Concerns and Proposed Remedies Pre-move inspection of the assemblies planned to be moved into each 12 assembly (max) load should be performed before any assembly is moved. Verification, with peer check, of orientation, serial numbers and planned loading pattern should be performed before any assembly is engaged for movement.
Before removal from P3 SFP, an independent verification by visual inspection, with peer check, must be performed to assure that none of the assemblies being removed are fresh fuel assemblies. This 3
is contrary to Entergys plan that verification be conducted after the assemblies are loaded into the shielded transfer cask (STC). Inspection and peer verification before any fuel is moved from its rack location, before placement into the STC, will preclude any fresh fuel from being removed from its proper storage location. This will also minimize the potential for increased radiological exposure and risk. A post move re-verification, as Entergy has proposed, should also be performed.
All workers associated with movement of spent fuel, from the preparatory stages at Unit 3 to the final placement in the ISFSI, should be subject to the NRCs rules for covered workers. The workers would therefore be subject to worker restrictions of maximum ceilings (hours worked),
minimum breaks, and minimum days off. The operative here is all workers, not just some workers directly associated with the fuel movements. The repetitive nature of the proposed work is highly poised for human performance errors including: time pressure, multiple tasks, overconfidence, peer pressure, physical injuries (slip/trip/fall), mental stress, distractions/interruptions, first shift/late shift, and off normal conditions. While Entergy has human performance training and tools to overcome human performance errors, the traps still remain. We strongly urge that strict compliance with the NRCs rules for covered workers be adhered to for all fuel movement personnel and activities.
While our research did not find any events resulting in thermal overloading, despite miss-positioning issues, we remain concerned for the potential for this to occur. Special attention must be mandated, with absolute strict procedure compliance and peer checking, for each assemblys pre selected location and orientation. Continued special attention for the location and orientation should be mandatory before and after placement in the STC, and when spent fuel is removed from the STC and placed into the Unit 2 pool.
We strongly recommend that fuel movement be accomplished only during daylight hours. No movement is to commence if there is not sufficient time, including allowance for delay, to complete the move in daylight hours.
Briefings of all workers involved in fuel movements should be conducted daily at the start of each shift, not just at the beginning of a campaign. It is imperative that all workers understand what is intended to be accomplished during each shift, by whom, and when.
Inspection of all fuel handling and transport equipment, at both units, is essential to avoid or minimize problems during operations. Most inspections are conducted on an elapsed time basis. We recommend that in addition to a straight time factor, that a frequency of use factor also be applied. This way, whether equipment is used a lot or very little, inspections will catch problems in time to be corrected before use.
While Entergy has addressed cask handling and movement in its application and in its responses to the NRCs requests for additional information, we remain concerned that an event could occur during movement and transport due to adverse weather conditions such as rain, snow, ice, high winds, and extreme high or low temperatures. We recommend that a condition be imposed that would preclude any fuel movement from starting if adverse weather is forecast or otherwise expected. Planning for fuel movement campaigns should include sufficient time to allow for possible weather delays. Loading and 4
unloading operations performed within the fuel storage buildings of Unit 2 and Unit 3 would not be subject to the adverse weather condition.
A shielded transfer cask should not be used as a storage cask. Fuel movement which is begun but not completed for any reason would result in the transfer cask being, by default, used as a storage cask. Transfer casks are not designed for storage and should not be used for such, even on a short term basis. A specific condition should be imposed stating that no fuel movement may begin which cannot proceed to completion with placement of fuel into the Unit 2 spent fuel pool.
Summary New York State has expressed numerous concerns with the movement of spent nuclear fuel from Indian Point Nuclear Station Unit 3 to its companion plant at Unit 2. Although we are mindful of the situation and the consequences of not moving this fuel, the increased handling of the spent fuel increases the inherent risk for adverse conditions to develop. To help assure adequate protection to the health and safety of the public, the following enhancements and conditions are proposed by the State and should be adopted bythe.NRC and included in the license amendment:
NRC should develop a supplemental license amendment that will address movement of damaged fuel; Pre-move inspection of the assemblies planned to be moved into each 12 assembly (max) load should be performed before any assembly is moved; Before removal from 1P3 SFP, an independent verification by visual inspection, with peer check, must be performed to assure that none of the assemblies being removed are fresh fuel assemblies; All workers associated with movement of spent fuel, from the preparatory stages at Unit 3 to the final placement in the ISFSI, should be subject to the NRCs rules for covered workers; Strict procedure compliance and peer checking is required for each assemblys pre-selected location and orientation before and after placement in the STC and when spent fuel is removed from the STC and placed into the Unit 2 pool; Fuel movement should be accomplished only during daylight hours; Briefings of all workers involved in fuel movements should be conducted daily at the start of each shift; In addition to a straight time factor, a frequency of use factor should also be applied to inspection of all fuel handling and transport equipment at both Units; Planning for fuel movement campaigns should include sufficient time to allow for possible weather delays; and A shielded transfer cask should not be used as a storage cask.
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