RS-13-140, Exemption Request for Transnuclear TN-68 Casks Loaded with Fuel Bundles with Incorrect Cooling Times

Exemption Request for Transnuclear TN-68 Casks Loaded with Fuel Bundles with Incorrect Cooling Times

ML13144A219
Person / Time
Site:	Peach Bottom
Issue date:	05/23/2013
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, NRC/NMSS/SFST
References
RS-13-140
Download: ML13144A219 (10)

Text

1010CFRCFR72.772.7 RS-1 3-140 RS-13-140 May 23, 2013 May 23,2013 ATTN: Document Control Desk ADirecto TIN: r, Document Division of Control SpentDesk Fuel Storage and Transportation Director, Office of Nuclear Material Fuel Division of Spent Storage and Transportation Safety and Safeguards Office of Nuclear Material U. S. Nuclear Regulatory Commission Safety and Safeguards U. S. Nuclear Regulatory Washington, DC 20555-0001 Commission Washington, DC 20555-0001 Peach Bottom Atomic Power Station Peach ReneweBottom Atomic Power Station,, Units Units 22 and and 33 d Facility Operating License Nos. DPR -44 and DPR-56 Renewed NRC Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 50-277, 50-278, NRC Docket Nos. 50-277. 50-278. and and 72-29 72-29

Subject:

Exemption Request for Transnuclear TN-68 Casks Loaded with Fuel Bundle

Subject:

Exemption s with IncorreRequest ct Cooling for Transnuclear TN-68 Casks Loaded with Fuel Bundles Times with Incorrect Cooling Times In accordance with 10 CFR 72.7, "Specific exemptions," Exelon Generation Compa In accordance with ny, LLC (EGC) is request ing10 CFR 72.7, "Specific exemptions," Exelon Generation Company, NRC approval of a one-time exemption for the Peach Bottom Atomic Power LLC (EGC) is requesting NRC approval of a one-time exemption Station (PBAPS), Units 2 and 3 Independent Spent Fuel Storage Installation (ISFSI) for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Independent Spent Fuel Storage Installation (ISFSI) from from the the requirements of 10 CFR 72.212(b)(3) and (b)(11). Specifically, the exemption requirements ses the of CFR 72.212(b)(3) and (b)(11). Specifically, the exemption request 10-com addres non pliance of four spent fuel assemblies with the terms andrequest addresses the Transnuclear,the non-compliance Inc. (TN) Certific of four spent fuel assemblies with the terms andconditi ons of conditions of ate of Compliance (CoC) Number 1027, Amendment 0, at the the Transnuclear, time of loading. Inc. (TN) Certificate of Compliance (CoC) Number 1027, Amendment 0, at the time of loading.

The regulations require, in part, compliance to the terms and conditions of CoC toThe thisregulations requirement, require, in part, compliance to the terms and conditions of CoC 1027.

in June 1027.Contra Contraryry and July 2001, four PBAPS Unit 3 fuel assemblies with cooling to thisless times requirement, than the minimu in June and July 2001, four PBAPS Unit 3 fuel assemblies with cooling m cooling time specified in CoC 1027, Amendment 0, Appendix A, times less than the minimum Technical Specification (TS) 2.1.1, cooling time specified in CoC 1027, Amendment 0, Appendix A, Table 2.1.1-1, "Minimum Acceptable Cooling Time as a Technical Functio n of Specification Max. Burnup (TS) 2.1.1, Table 2.1.1-1, "Minimum and Min. Acceptable Cooling Time as a Initial Enrichment," were loaded into four TN -68 casks (i.e.,

Function of Max. Burnup and Min. Initial Enrichment,"

one assembly per cask). Specifically, the four fuel assemblies had been were loaded into four TN-68 casks (Le.,

one assembly per cask). Specifically, instead of the required period of 10 years. the four fuel assemblies had beencooled cooledfor for9.8 9.8years years instead of the required period of 10 years.

EGC identified this condition on January 24, 2013, during a review of ISFSI fuel EGCUpon identified thisry,condition on January 24, 2013, during a review of ISFSI fuel charact erization characterization data. discove EGC verified that the actual heat load of each fuel bundle, at the time of data. Upon discovery, EGC verified that the actual heat loading, was less than the limit specified in TS 2.1.1.E.ii. The decay heat of load of each fuel bundle, at the time of loading, the assemb the limit specified in TS 2.1.1. E.ii. The decay heat of the assemblieshas lies continu edwas less than to decreas e since their initial loading in June and July 2001. As of September 14, has continued to decrease since their initial loading in June 2001, the four assemblies were in compliance with the TS 2.2.1, Table 2.1.1-1 and July 2001. As of September 14, the four assemblies were in compliance with the TS 2.2.1, Table 2.1.1-1 2001, ment. Cooling Cooling Time Time require requirement.

May 23, 20132013 U. S. Nuclear Nuclear Regulatory Regulatory Commission Commission Page 2 EGC also conducted conducted an anextent extentofofcondition conditionreview reviewforfor all all fuel assemblies assembliescurrently currently stored storedwithin within the PBAPS PBAPS ISFSI. All other loaded fuel assemblies were in compliance with the TSCooling ISFSI. All other loaded fuel assemblies were in compliance with the TS Cooling Time requirement, at at the the time time of of loading.

loading.

The attachment attachment toto this this letter letter describes describes the the need needand andjustification justification for for the issuance issuance ofof an an exemption, exemption, as well as an environmental well as assessment of environmental assessment of the the proposed proposed action.

action.

There There are are no no regulatory regulatory commitments commitments in in this this submittal.

submittal.

IfIf you have have any any questions questionsor orrequire requireadditional additional information, information, please pleasecontact contactMr.Mr. John John L.L. Schrage Schrage at at (630)

(630) 657-2821.

657-2821.

Respectfully, Respectfully, Patrick R. Simpson Manager - Licensing

Attachment:

10 10CFRCFR72.772.7Exemption ExemptionRequest, Request,Peach PeachBottom BottomAtomic AtomicPower PowerStation Station Independent Independent SpentSpentFuelFuelStorage StorageInstallation Installation cc:

cc: NRC NRC Regional Regional Administrator Administrator -- Region Region II

Attachment Attachment 10 CFR 72.7 10 CFR 72.7 Exemption Exemption Request Request Peach Bottom Atomic Peach Bottom Atomic Power Station Power Station Independent Spent Independent Spent Fuel Fuel Storage Storage Installation Installation

1. Background

1. Background The Transnuclear, The Transnuclear, Inc., (TN) TN-68 Inc., (TN) TN-68storage storage systemsystem is is designed designed to to store store 6868 spent spentfuel fuel assemblies for independent spent fuel storage installation (ISFSI) deployment. The system assemblies for independent spent fuel storage installation (ISFSI) deployment. The system is listed is listed inin 10 10 CFR CFR 72.214 72.214 as as Certificate Certificate of of Compliance Compliance (CoC) (CoC) NumberNumber 1027. 1027. ThisThis system system is is currently installed currently installed andand inin use use atat the the Peach PeachBottomBottom Atomic Atomic Power Power Station Station (PBAPS)

(PBAPS) under under aa 1010 CFR CFR Part Part 7272 general general license.

license.

During aa January During January 2013 2013 internal internal review review of of historical historical ISFSI ISFSI fuel fuel characterization characterization for for PBAPS, PBAPS, Exelon Generation Company, LLC (EGG) identified that in June and July 2001 , four PBAPS Exelon Generation Company, LLC (EGC) identified that in June and July 2001, four PBAPS Unit33 spent Unit spent fuel fuel assemblies assemblies with with cooling times less cooling times less thanthan thethe minimum minimum cooling cooling timetime specified specified in CoC in CoC 1027, 1027, Amendment Amendment 0, 0, Appendix Appendix A, Technical Specification A, Technical Specification (TS) 2.1.1, Table (TS) 2.1.1, Table 2.1.1-1, 2.1.1-1, "Minimum Acceptable Cooling Time as a Function "Minimum Acceptable Cooling Time as a Function of Max. Burnup and Min. Initialof Max. Burnup and Min. Initial Enrichment," were Enrichment," were loaded loaded into into four fourTN-68 TN-68casks casks (Le.,

(i.e., one one assembly assembly per per cask).

cask).

Specifically,the Specifically, thefour fourspent spentfuel fuelassemblies assemblies had had been been cooled cooled for for approximately approximately 9.8 9.8 years years instead of the required 10 years that is specified in TS Table 2.1.1-1. Upon discoveryof instead of the required 10 years that is specified in TS Table 2.1.1-1. Upon discovery ofthe the TS non-compliance, EGC verified that the actual heat load of each fuel bundle, at the timeof TS non-compliance, EGC verified that the actual heat load of each fuel bundle, at the time of loading, was loading, was less less than than the the limit specifiedininTS limit specified TS2.1.1.E.ii.

2.1.1.E.ii.The Thedecay decay heat heat ofof the the assemblies assemblies has continued has continued to to decrease decreasesince sincetheir their initial loading in initial loading inJune June andand JulyJuly 2001.

2001. As As of of September 14, September 14, 2001, 2001, thethe four four assemblies assemblies fully fully complied compliedwith withthe theTS TS2.2.1, 2.2.1,Table Table2.1.1-1 2.1.1-1 cooling time cooling time requirement.

requirement.

EGC also EGC also conducted conducted an an extent extentof of condition condition reviewreview forfor allall fuel fuel assemblies assemblies currently currently stored stored within within the PBAPS ISFSI. All other loaded fuel assemblies were in compliancewith the PBAPS ISFSI. All other loaded fuel assemblies were in compliance with the the TSTS cooling time requirement, at the cooling time requirement, at the time of loading. time of loading.

As As required required by by TS TS 2.2.2, 2.2.2, EGCEGC notified notified the the NRC NRC Operations OperationsCenter Centerwithin within24 24hours hoursofof discovery discovery of the TS of the TS non-compliance non-compliance (i.e., (Le., ENSENS notification notification 48698).48698). Similarly, Similarly, as as required required by by TS TS 2.2.3, 2.2.3, EGCEGC provided provided aa 30-day 30-day special special report report to to the the NRCNRC on on February February 22, 22, 2013.

2013. This This special special report report described described the the cause causeof of the the TS TS non-compliance non-compliance and and thethe actions actions taken takento to restore restore compliance and prevent recurrence. EGC also indicated in the special report compliance and prevent recurrence. EGC also indicated in the special reportthatthataa one-time one-time exemption request would be submitted to obtain NRC approval for the periodof exemption request would be submitted to obtain NRC approval for the period of time time thatthat the the four four spent spent fuelfuel assemblies assemblieswere werenon-compliant non-compliantwith with thetheTS-required TS-requiredcooling cooling time.

time.

2.

2. Request Request for for Exemption Exemption In accordance with In accordance with 10 10 CFR CFR 72.7, 72.7, "Specific "Specific exemptions,"

exemptions,"EGC EGCisisrequesting requestingNRC NRCapproval approvalofof aa one-time one-time exemption for the PBAPS, Units 2 and 3 ISFSI from the following requirementsofof exemption for the PBAPS, Units 2 and 3 ISFSI from the following requirements 10 10 CFR CFR 72.212, 72.212, duedueto toaanon-compliance non-compliancewith with the theterms termsand andconditions conditionsofofCoC CoC1027.1027.

• • 10 10 CFR CFR 72.212(b)(3),

72.212(b)(3), which which states states the the general general licensee licenseemust must"[e]nsure

"[e]nsure thatthat each each caskcask used used by the general licensee conforms to the terms, conditions, and specificationsofofaa by the general licensee conforms to the terms, conditions, and specifications CoC CoC or or an an amended amendedCoC CoClisted listed inin §§ 72.214" 72.214" n* The The portion portion of of 10 10CFRCFR72.212(b)(11) 72.212(b)(11)which which states states thatthat" " [t]he

[t]he licensee licensee shallshall comply comply withwith the the terms, terms, conditions, conditions, and andspecifications specificationsof ofthe the CoC...."

CoC .... "

Page Page11of of 88

Attachment Attachment 10 CFR 72.7 Exemption Exemption RequestRequest Peach Bottom Bottom Atomic Power Station Atomic Power Station Independent Independent Spent Spent Fuel Fuel Storage Storage Installation Insta"ation Specifically, fourfour spent spent fuel fuel assemblies assemblies were werenon-compliant, non-compliant,at atthe thetimetimeof ofloading, loading,withwith the the cooling time requirement in CoC 1027 time requirement 1027 Amendment 0, Appendix Appendix A, TS 2.2.1 for for durations durations ranging from58 ranging from 58toto8686days.

days. AsAs of September 14, 2001, of September 2001, all fourfour spent nuclearnuclear fuelfuel assemblies were in compliance with the terms assemblies were in compliance with the terms and conditions and conditions of CoC 1027.

1027.

These assemblies, assemblies, the the associated associatedcask casknumbers, numbers,maximum maximum burnup burn up values, load load dates, and and CoC non-compliance durations durations arearelisted listedinin the theTable Tablebelow.

below.All Allfour fourare areGE6 GE68x8 8x8type type assemblies, assemblies,with with aa uranium uranium content contentof of0.182 0.182MTU,MTU, aa minimum minimum initial average initial bundle average enrichment of of 2.99%,

2.99%, andand aa last at-power date of September September 14, 14, 1991.

1991.

Assembly Cask No. I Maximum Maximum Load Date CoC No. I Burnup Non-compliance Non-compliance (GWd/MTU)

• (GWdlMTU) Duration LJW874 TN-68-05 29.582 19-Jun-2001 19-Jun-2001 86 days LJW875 WW875 TN-68-06 29.577 26-Jun-2001 79 days LJW882 TN-68-07 29.578 10-Jul-2001 65 days LJW867 WW867 TN-68-08 29.580 17-Jul-2001 17 -Jul-2001 58 days Approval of Exemption Request

3. Basis for Approval In accordance In accordance with with 1010 CFR CFR 72.7, 72.7, the NRC may, may, upon application application by by any any interested person or upon its own initiative, initiative,grant grant such such exemptions from from the requirements requirements of of the the regulations regulations in in this part asas itit determines determines are areauthorized authorizedby bylaw lawandandwill will not not endanger endangerlife lifeororproperty propertyor orthe the defense and common defense and security security and and are areotherwise otherwiseininthe thepublic publicinterest.

interest.

a. Authorized by Law This exemption would allow EGC to continue to to store store four four spent spent nuclear nuclear fuelfuel assemblies assemblies at the PBAPS ISFSI which were, at the time of loading in in June June and and JulyJuly 2001, 2001, in non--

in non compliance with with the minimum cooling time requirementrequirement specified specified in in CoC CoC 1027, 1027, Amendment 0, 0, Appendix Appendix A, A, TS TS 2.2.1, 2.2.1, Table Table 2.1.1-1.

2.1.1-1. All All four four spent spent nuclear nuclear fuel assemblies currently comply with all TS requirements.

The NRC issued 10 CFR 72.7 under NRC issued under the the authority authority granted granted to to itit under under Section Section 133 133 ofof the Nuclear Waste Nuclear Waste Policy Policy Act Actofof1982, 1982,as as amended, amended, 42 U.S.C. § 10153. Section Section72.772.7allows allows the NRC to to grant grant exemptions exemptions from from the the requirements of 10 CFR CFR Part 72. Granting Granting thethe proposed exemption provides provides adequate adequate protection protection to public health and public health and safety, safety, and the environment. As environment. As described described below, below, the the proposed proposedexemption exemptionwill will not endanger endangerlife life or property, or the common defense and security, and is otherwise property, or the common defense and security, and is otherwise in the public in the public interest.

Therefore, the exemption is authorized by by law.

law.

Page 2 of 8 Page

Attachment Attachment 10 CFR 72.7 Exemption Exemption Request Request Peach Bottom Bottom AtomicAtomic Power PowerStation Station Independent Spent Fuel Independent Spent Fuel Storage Installation Storage Installation

b. Will not Endanger Endanger Life Life or or Property Property or or thethe Common Common Defense Defense and andSecurity Security EGC has has verified verified that that loading loading of of the four spent spent nuclear nuclear fuelfuel assemblies assemblieswith withcooling cooling times times lesslessthan thanthe theminimum minimumrequired requiredtime, time,for for the theapplicable applicabledurations, durations,did didnotnotimpact impact the the shielding, shielding, confinement, confinement, and and thermal thermal design design functions functions of of the the loaded loaded TN-68 TN-6a casks, casks, as as described in the Technical Analysis described in the Technical Analysis section below. section below.

In addition, addition, by SafetySafety Evaluation Report (SER) dated October October 30, 2007, 2007, the NRC NRC approved Amendment Amendment 1 to CoC 1027. 1027. This amendment, amendment, in in part, part, increased increased the the TSTS average average assembly assemblyburn-upburn-up limit limit andand decreased decreased the the TSTS minimum minimum allowable cooling cooling time time for all all fuel fuel types, except GE 7x7 types, except 7x7 assemblies.

assemblies.The Therevised revisedminimumminimumcooling coolingtimetimeforfor 8x8, 8x8, 9x9, andand 10x10 1Ox1 0 assemblies assembliesisisseven sevenyears, years,which whichisisspecified specifiedininaanew newfuelfuelselection selection flowchart that was added added to TS TS 22.1.1

.1.1 (i.e.,

(Le.,Figure Figure 2.1.1-2, 2.1.1-2,"Flowchart "Flowchart for Selection Selection of of 8x8, 8x8, 9x9, 9x9,and and10x10 1Ox1 0Fuel").

Fuel"). This Thisfigure figurealsoalsoincludes includesa amathematical mathematicalfunction functionfor for determination of decay decayheat heatas asa afunction functionofoffuel fuelburnup, burnup,cooling coolingtimes,times,and andinitial initialfuel fuel enrichment.

enrichment. InInApril April 2013, 2013, EGC updated the four applicable TN-68 casks four applicable casks to to the the requirements requirements of CoC 1027, 1027, Amendment Amendment 1, 1, in in accordance accordancewith with the the requirements requirements of of 1010 CFR 72. 72.

Given that: that: 1)1) The Theloading loading of of the the four four non-compliant non-compliant spent nuclear fuel fuel assemblies assemblies in in 2001 2001 did did not notimpact impactthe the shielding, shielding,confinement, confinement,and andthermal thermal designdesignfunctions functionsofofthe the loaded loaded TN -68 casks; TN-68 casks; 2) 2) The The non-compliant condition was resolved resolvedwithin within 8686days daysafter after loading; and and 3)3) The The TS- minimum-requiredcooling TS-minimum-required cooling time time has has been subsequently subsequentlyreduced,reduced, by by TSTS amendment, amendment, to to less lessthanthan the the actual actual cooling cooling timestimes of of the the four assemblies, at four assemblies, attime time of of loading, loading, the proposed proposed exemption exemption does doesnot notcompromise compromisethe theability abilityof ofthe thefour four asas--

loaded loadedTN -68 casks TN-68 casksto tosafely safelystore storethe thefour four fuel fuel assemblies.

assemblies. Therefore, Therefore,the theproposed proposed exemption does not endanger exemption does not endanger life or property life or property or the common defense defense andsecurity.

and security.

c.

c. Otherwise Otherwise in in the the Public Public Interest Interest The The proposed proposed exemption exemption isis based basedon onguidance guidanceprovided provided in in CoC 1027 1027 Amendment Amendment 0, 0, TS TS Bases Bases2.2.1.2.2.1.ThisThisstates states that thatnon-compliant non-compliantfuel fuelassemblies assembliesmay mayremain remainininthe the associated associatedcask caskififthis thisisisdetermined determined to to bebeaasafe safecondition.

condition.

InIn addition addition to to the the proposed exemption request, EGC EGC has has considered considered the thealternative alternative action action to to correct correct thethe historical historical condition, condition, as as established establishedininTS TS2.2,2.2,"Functional "Functional and and Operational OperationalLimits Limits Violations."

Violations/' Specifically, Specifically,ifif aaFunctional Functionaland andOperational OperationalLimit Limitisis violated, violated, TS 2.2.1 2.2.1 requires requires the the licensee licensee to to remove remove the the affected affected fuel fuel assemblies assemblies and and place place in in aa safe safe condition.

condition. In In this this case, case,the theapplicable applicablefuel fuel assemblies assemblieswould wouldbe beremoved removed from from their respective casks casks and either reloaded into a TN-68 cask, or unloaded intothe and either reloaded into a TN-68 cask, or unloaded into the PBAPS PBAPS Unit 3 spent fuel pool.

Unit 3 spent fuel pool.

This This action action would would require require EGC EGC to: to:

n* Transport Transporteach eachindividual individual cask caskfromfromthe theISFSI ISFSIpad padtotothe thePBAPS PBAPSReactor ReactorBuilding Building trackway trackway n* Lift each cask Lift each cask with with the ReactorReactorBuilding Building crane crane to to the thePBAPS PBAPSUnit Unit 33 spent spentfuelfuel pool pool n* Remove Remove the the casks' casks'lids lids and and applicable applicable fuel fuel assemblies assemblies Page Page33of of 8a

Attachment Attachment 10 CFR 72.7 Exemption Request Request Peach Bottom Atomic Power Station Independent Spent Fuel Fuel Storage Storage Installation Installation n* Relocate and/or reload the assemblies assemblies n* Reinstall thethe lid lid n* Remove the TN-68 casks from the the spent spent fuel fuel pool pool

• Process the reloaded casks to ensure cask integrity integrity n* Lower Lower the the loaded caskscasks to to the the Reactor ReactorBuilding Building trackway trackway n* Transport each cask back to the ISFSI cask back to the ISFSI pad. pad.

Based Based on on historical historical loading loading performance, performance, EGC EGC has hasdetermined determinedthat that the the implementation implementation of this process process would would result result in in approximately approximately 300 300 mrem mrem of of personnel personnel radiation radiation exposure exposure per cask (i.e.,(Le., 1.2 1.2 person-person-rem rem total) total) and and a financial financial cost cost of approximately approximately $409,000 $409,000 per per cask cask (i.e.,

(i.e., $1.63

$1.63million million total),

total), asas well well as asthe thegeneration generationof oflow-level low-levelradioactive radioactive waste waste (LLRW) (i.e.,(Le., in form of in the form of radiologically radiologicallycontaminated contaminated consumables consumables and andanti-anti-contamination clothing used during contamination clothing used during the unloading the unloading and reloading process). Inaddition, reloading process). In addition, the process processwould wouldresult resultin inadditional additional opportunities opportunities for for the occurrence occurrenceof ofboth bothoff-normal off-normal events events and and design design basis basisaccidents, accidents,such suchasasa afuelfuelhandling handlingor orcask caskdrop dropevent.event.

Since Since thethe four four assemblies assembliesare arecurrently currentlyininaasafesafecondition conditionininthe thefourfourindividual individual casks, casks, and in in full compliance with full compliance with thethe CoG CoC cooling cooling time time requirement, the the integrity integrity of the casks casks and and fuel fuel will not be will not be impacted impacted by by the the short period of non-compliance in 2001. Therefore, Therefore, the the additional additional personnel personnel radiation radiation exposure, exposure,generation generationofofLLRW, LLRW, and andfinancial financial cost cost would not be in in the the public public interest.

interest.

4. Technical AnalysisAnalysis The TN-68 system provides provides criticality control,passive criticality control, passive heat removal, confinement, confinement, and and shielding, independent of of any other facility structures or components. The structural design facility structures or components. The structural design of the caskcask also also maintains maintains the theintegrity integrity of of the fuel fuel during storage.

storage.

The cask cask design design requires requires certain certainlimits limits on spent spent fuel fuel parameters, parameters,including including fuel fuel type, type, assembly assemblyweight, weight, initial initial enrichment, maximum burnup, burnup, minimum minimum coolingCOOling time, and and physical physical condition condition to to safely safely store store the the spent spent fuel. TheseTheselimitations limitations are areincluded included in in the the thermal, thermal, structural, radiological, radiological, and and criticality evaluations for criticality evaluations for the the cask.

cask.

The TN-68TN-68 is designed designed to to store store 68 68boiling boiling water water reactor reactor (BWR)

(BWR) type spent spent fuelfuel assemblies.

assemblies.

CoC GoG 1027 1027 Amendment Amendment 00 establishes establishesaamaximum maximumallowable allowableinitial initial lattice-average lattice-averageenrichment enrichment of 3.7 wt% U-235, U-235, a maximum bundle average averageburnup burnupofof40 40GWd/MTU, GWdlMTU, aamaximum maximumdecay decay heat heat load load of of 0.312 0.312 kW/assembly, kW/assembly, and andaaminimum minimumcoolingcoolingtimetimeof oftentenyears, years,for forall allBWR BWRfuel fuel types.

types.

The allowable combinations of of burnup, burnup, enrichment, enrichment, and and cooling cooling timetime ensure ensure that the thermal, shielding, and confinement design functions for for aa loaded fuel assembly are fuel assembly are bounded by by those those evaluated evaluated in in the the Independent IndependentFuel Fuel Storage StorageSafety SafetyAnalysis Analysis ReportReport (IFSSAR)

(IFSSAR) for forthe the design design fuel fuel assembly.

assembly. With With respect respectto tocooling cooling time, time, thethespecified specifiedvaluevalueof of ten years years ensures ensuresthat thatthethemaximum maximum decay decay heat heatloadload perper assembly assemblyshall shall notnotexceed exceedthe theTSTS 2.1.1.E.ii value of 0.312 kW kW (i.e.,

(Le., the bounding design design value).

value).

Page Page 44 of of 88

Attachment 10 CFR CFR 72.772.7 Exemption Request Request Peach Bottom Atomic Atomic Power Power Station Station Independent Independent Spent Spent FuelFuel Storage Storage Installation Installation Reactivity parameters for Reactivity parameters for the the four fourloaded loadedfuel fuelassemblies assemblies and and associated associated casks caskswere werenot not affected by the non-compliance period. The The reactivity parameters of the fuel at the timeof reactivity parameters of the fuel at the time of loading complied with Technical Specification requirements.

with Technical requirements.

a. Thermal Design Function Upon discovery of of the the non-compliance for for the the four four spent spent nuclear fuel fuel assemblies, EGC EGG calculated the as-loaded decay heat load value for each fuel assembly, as-loaded decay heat load value for each fuel assembly, using the actual using the actual assembly burnup, enrichment, enrichment, and and cooling cooling times. This This calculation calculation was was performed performed using using the analytical analytical method in Regulatory Guide (RG) 3.54, "Spent Fuel Heat Generation in an (RG) 3.54, Independent SpentSpent FuelFuel Storage StorageInstallation,"

Installation," as aswell well asasthetheanalytical analytical method methodprovidedprovided in GoG in CoC 1027 1027 Amendment Amendment 1, 1, TS TS 2.1.1, 2.1.1, Figure Figure 2.1.1-2.

2.1.1-2. TheThe actual actual decay decay heat heatvalue value for for each ofof the four assemblies assemblies was was 0.201 0.201 kW kW using using the the RGRG 3.543.54 method method and and 0.194 0.194kW kW CoC Amendment 1 method. Both using the GoG Both values values arearebounded boundedby bythe theIFSSAR IFSSAR and and TS design limit of 0.312 kW. Therefore, the short period of limit of 0.312 kW. Therefore, the short period of time in 2001 when thetime in 2001 when the cooling time cooling time for foreach each ofof the the four fourassemblies assemblies was less lessthan thanthe theminimum minimum requiredrequired did did not not thermal design function impact the thermal function of of the the casks.

b. Radiation Shielding Design Function Function Shielding for Shielding for the the TN-68 TN-68 caskcask is provided mainly mainly by by the the cask body. For For the neutron neutron shielding, shielding, a a borated polyester resin compound surrounds surrounds the cask body and aa the cask body and polypropylene disk covers the lid.

polypropylene lid. Additional Additional shielding is provided by the steel shell shell surrounding the resin layer surrounding layer and by by the the steel steel and andaluminum aluminum structure structureof of the the fuel fuel basket.

basket.

Geometric attenuation, enhanced enhanced by byairair and andground groundattenuation, attenuation,providesprovidesadditional additional dose reduction reduction for for distant distant locations locations at at the the restricted restricted area area and site site boundaries.

boundaries.

As part of the initial IFSSAR for initial IFSSAR for GoG CoC 1027, 1027, Amendment 0, aa shielding shielding evaluation evaluation was was performed utilizing the source terms from a GE 7x7 fuel assembly utilizing the source terms from a GE 7x7 fuel assembly with an initial bundle- with an initial bundle-average enrichment average enrichment of of 3.3 wt%

wt% and aa total total maximum maximum bundle average average burnup burnup of of 40 40 GWd/MTU. Given GWd/MTU. Given the the design design basis burnupburnup and and enrichment, enrichment, this this fuel fuel assembly assemblytype type isis the most conservative based basedon onthe theinitial initial uranium uranium loading.

loading. The Theshielding shieldingevaluation evaluation resulted in projected radiation levels that that formed the the basis basisfor forthe thedose doserate ratelimits limitsinin TS 5.2.3, "Cask Surface Dose Dose Rate RateEvaluation Evaluation Program."

Program."

The total total gamma and neutron neutron sources sourcesof ofthe thefour fournon-compliant non-compliant fuel fuel assemblies assemblies were were approximately 27%

approximately 27% andand 70% lower, lower, respectively, respectively, than than thethe design basis basis fuel fuel sources.

sources.

Similarly,actual Similarly, actual contact contact dose dose rates ratesononthe theTN-68 TN-68cask, cask,following followingloading loadingof ofthe thefour four non-non-fuel assemblies compliant fuel assemblies inin 2001, 2001,wereweresignificantly significantly lower lower thanthanthetheTS TS5.2.3 5.2.3limits.

limits.

Therefore, the shielding shielding design designfunction function will will continue to limitlimit external dose dose to to levels levels bounded by by the the TN-68 TN-68 IFSSAR.

IFSSAR.

c. Confinement Design Function c.

The confinement of radioactivity during the radioactivity during the storage storage of of spent spentfuelfuel inin the theTN-68 TN-68 cask cask system is ensured by by the useuse ofof multiple confinementbarriers multiple confinement barriersand andsystems.

systems. These These barriers are the fuelfuel pellet matrix, the fuel cladding, and the cask.

fuel cladding, cask.

Page 55 of 8

Attachment Attachment 10 CFR 72.7 ExemptionExemption Request Request Peach Bottom Bottom AtomicAtomic Power Power Station Station Independent Independent Spent Spent Fuel Fuel Storage Storage Installation Installation The The long-term long-term integrity integrity of of the the stored fuel is dependent dependent on on storage storageininaadry, dry,inert inert environment and maintenance of adequate heat transfer mechanisms.

heat transfer mechanisms. This This environment is is established establishedby byremoving removingwater waterfromfrom thethe cask caskcavity cavityand andbackfilling backfilling the the cavity withwith helium helium(Le., (i.e.,anan inert inertgas).

gas). Helium assists in Helium assists in heat heat removal removal and and provides provides aa non-reactive environment to protect fuel assemblies against fuel assemblies againstfuelfuel cladding cladding degradation degradation which which might otherwise lead to to gross grossrupture.

rupture.

The thermal design function analyses for function analyses for storage operations operations assumeassumethat thatthethecask caskisis filled filled with helium. As described above, the decay heat load for each of the fournon-with helium. As described above, the decay heat load for each of the four non-compliant fuel assemblies are fuel assemblies arebounded boundedby bythe thethermal thermalanalysis analYSisininthe theIFSSAR IFSSARfor for aa design design fuelfuel assembly.

assembly. Therefore, Therefore,the theshort shortperiod periodofoftimetimeinin2001 2001whenwhenthe thecooling coolingtime time for each each ofof the the four four assemblies assemblieswas waslesslessthanthanthetheminimum minimumrequired, required,did didnotnotimpact impactthe the confinement confinement designdesign function function of of the the casks.

casks.

In addition, TS 3.1.1, "Cask "CaskCavity Cavity Vacuum Vacuum Drying," Drying," and TS TS 3.1.2, 3.1.2, "Cask "CaskHeliumHelium BackBack Pressure," specify Pressure," specify LimitingLimiting Conditions for Operation (LCOs) and Surveillance Surveillance Requirements Requirements (SRs) (SRs) to to ensure ensurethat thatthetherequired requiredhelium heliumenvironment environmentwithin within aa TN-68 TN-68 caskcask is is correctly established established during during loading operations. TS TS3.1.3, 3.1.3,"Cask "CaskHeliumHelium Leak Leak Rate" Rate" and and TS TS 3.1.5, 3.1.5, "Cask "Cask Interseal Interseal Pressure,"

Pressure," establish establish LCOsLCOs and SRs SRs to to ensure ensure that thatthis this environment environment is maintained maintained during storage storage operations.

operations. When When loaded loaded in in 2001, 2001, the thefour four applicable applicable TN-68TN-68 caskscasks were were in in compliance compliance with with TS 3.1.1 3.1.1 and TS 3.1.2. 3.1.2. Ongoing OngOing monitoring monitoring of of the the four four casks, casks, as required required by by TS 3.1.3 and and TS TS 3.1.5, 3.1.5, hashasconfirmed confirmed continued continued compliance with TS requirements. This compliance ensuresthat compliance with TS requirements. This compliance ensures thatthe the confinement confinement designdesignfunction function waswas satisfied satisfied when wheninitially initially loaded, and and continues continuesto tobe be satisfied satisfied during during storage storage operations.

operations.

5.

5. Environmental Environmental Consideration Consideration EGC EGC has has evaluated evaluated the theenvironmental environmental impacts impacts of of the proposed proposed exemption exemption request request and andhas has determined determined that that the the proposed proposedaction actionwillwill not not have have an an adverse adverseimpact impacttotothe theenvironment.

environment.

Therefore, Therefore, the the proposed proposed action action does doesnot notrequire requireany anyFederal Federalpermits, permits, licenses, licenses,approvals, approvals,or or other other entitlements.

entitlements.

a.

a. Environmental Environmental Impacts Impacts of ofthe the Proposed ProposedAction Action The The PBAPS PBAPS ISFSI ISFSI is is aaradiologically radiologically controlled, Protected Area Area with limitedlimited access, access, and and is is located located inside inside thethe EGCEGC Owner Owner Controlled Controlled Area. The Thearea areaconsidered consideredfor forpotential potential environmental environmental impact as as aaresult resultof of this this exemption exemption request requestisis the thearea areaininand and surrounding surrounding the theISFSI.

ISFSI.

The The interaction interaction of of aaloaded loadedTN-68 TN-68with with thetheenvironment environmentisisthroughthroughthe thethermal, thermal,shielding, shielding, and confinement design functions for and confinement design functions for the cask system. the cask system.

Upon Upon discovery discovery of of the CoCCoC 1027 1027 Amendment Amendment 00 non-compliance non-compliancefor for the the four four spent spent nuclear nuclear fuel fuel assemblies, assemblies, EGC EGC calculated calculated the the as-loaded as-loadeddecay decayheat heatloadloadvalue valuefor foreach each fuel fuel assembly, assembly, using using thethe actual actual assembly assemblyburnup, burnup, enrichment, enrichment, and andcooling cooling times.

times. The The Page Page 6of8 6 of 8

Attachment 10 CFR 10 CFR 72.7 72.7 Exemption Request Peach Bottom Peach Bottom Atomic Power Station Independent Spent Fuel Storage Installation actual decay heat value for each of the four actual four assemblies assemblies was was bounded bounded by bythe the IFSSAR IFSSAR and TS design design limit limit of 0.312 0.312 kW,kW, with significant margin.

Based on the actual radioactive radioactive source source terms terms forfor the the four four non-compliant non-compliant assemblies, assemblies, relative to relative to the the design design source source term, term, asaswell well asasthe theinitial initial radiation radiation levels levels on onthe thefour four applicable TN-B8 TN-68 casks, relative to design limits, the shielding design relative to design limits, the shielding design function will function will continue to limit limitexternal externaldosedose to levels bounded by by the the TN-68 TN-B8 IFSSAR.

IFSSAR.

Finally,since Finally, sincethe the decay decay heat load of the four four assemblies assemblies are arebounded boundedby bythe theIFSSAR I FSSAR design thermal analysis, the the confinement confinement design design functions functions of of the fuel fuel cladding and the the TN-68 structure TN-B8 structure were were not not adversely adversely impacted by the as-loaded as-loaded configurations.

configurations.

In that In that compliance compliance with with TSTS 2.1.1, 2.1.1, Table Table 2.1.1-1 2.1.1-1 forfor all all four four non-compliant non-compliantassemblies assemblies was achieved on SeptemberSeptember 14, 2001, EGC has concluded that all TN-B8 design 14, 2001, EGC has concluded that all TN-68 design functions impacting functions impacting the the environment are, and and will continue to be bounded will continue boundedby bythe theIFSSAR IFSSAR evaluations.

evaluations.

EGC has also determined that there are EGC are nono gaseous, gaseous,liquid liquid ororsolid solid effluents effluents (radiological or (radiological or non-radiological),

non-radiological), radiological radiologicalexposures exposures (worker or member member of of the public) or land disturbances public) or land disturbances associated with with the proposed action. Therefore, Therefore, approval of approval of the the requested requested exemption to allow allowthe the fuel fuelassemblies assemblies to remain remain as loaded has nono impact impact on the environment.

environment.

b. Adverse Environmental Environmental Effects Effects Which Which Cannot Cannot be be Avoided AvoidedShouldShouldthe theExemption Exemption be Approved As noted previously, previously, therethere are no environmental environmental impacts associated associatedwith with approval approval of of this this exemption. Therefore, there are no adverse environmental effects are no adverse environmental effects which cannot be which cannot be avoided should the exemption request be be approved.

approved.

c. Alternative to the ProposedProposed Action Action In addition to In addition to the the proposed proposed exemption request, EGC EGC has hasconsidered consideredthe thealternative alternative action to correct the historical condition, historical condition, as established established in TS 2.2, "Functional and in TS 2.2, "Functional and Operational LimitsLimits Violations."

Violations." Specifically, Specifically, if a Functional and and Operational OperationalLimitLimit isis violated, violated, TSTS 2.2.1 2.2.1 requires the licensee to remove the affected fuel assemblies and fuel assemblies and place in a safe condition.

condition. In In this this case, case, thetheapplicable applicable fuel fuel assemblies assemblieswould would be beremoved removed from their respective from their respective casks and and either either reloaded reloadedinto into aaTN-68 TN-68 cask, cask, or orunloaded unloadedintointoaa PBAPS spentspent fuel fuel pool.

pool. This Thiswould wouldinvolve involvethe thefollowing following steps:

steps:

n* Retrieve each each affected affected TN-68 TN-68 from the ISFSI Pad Pad andandtransport transporttotothe thePBAPS PBAPSUnit Unit33 Reactor Building trackway Reactor Building trackway n* Lift each cask with Lift each with the Reactor Reactor Building Building crane crane to to the the PBAPS PBAPSUnit Unit 33 spent spentfuel fuelpool pool n* Remove the the casks' casks' lids lids and and applicable applicable fuel assemblies assemblies n* Relocate Relocate and/or and/or reload reload thethe assemblies assemblies n* Reinstall the Reinstall the lid lid n* Remove the TN-68 TN-B8 casks casks from from the the spent spentfuel fuel pool pool n* Process the reloaded casks to ensure ensure cask cask integrity integrity Page 7 of of 88

Attachment 10 CFR 10 CFR 72.7 Exemption Request Peach Peach Bottom Atomic Power Station Independent Spent Fuel Storage Installation Independent

• n Lower Lowerthe the loaded loaded casks casks toto the the Reactor ReactorBuilding Building trackway trackway

• n Transport Transport eacheach cask back to the ISFSI ISFSI pad.

This alternative This alternativewould wouldrestore restorethe theaffected affected as-loaded as-loaded TN-68 casks casksto tocompliance compliancewith with CoC CoC 1027.

d. Environmental Effects of

d. of the Alternatives Alternatives to to the the Proposed Proposed Action Action The environmental impacts of of the the alternative alternative to to the the proposed proposedaction actionwould wouldresult resultininboth both real and real and potential potential radiological radiological impacts.

impacts. Based Basedon onhistorical historicalloading loadingperformance, performance,EGC EGC has determined determined thatthat the the implementation implementation of of this this process processwould wouldresult resultininapproximately approximately 300 mrem of personnel radiation exposure per cask (i.e.,

radiation exposure per cask (Le., 1.2 person-rem1.2 person -rem total) total) and and a financial cost financial cost of approximately $409,000$409,000 per per cask cask (i.e.,

(Le., $1.63

$1.63million million total), as well total), as well as the generation of low-level radioactive radioactive waste (LLRW) (LLRW) (Le., (i.e., in in the form form of radiologically contaminated consumables consumablesand andanti-contamination anti-contamination clothing clothing used usedduring during the theunloading unloading and reloading process).

process).InInaddition, addition,thetheprocess processwould wouldresult resultininadditional additionalopportunities opportunities for the for the occurrence occurrence of of both both off-normal off-normaleventseventsand anddesign design basisbasis accidents, suchsuch asasaafuel fuel handling or cask handling or cask drop event.

e. Conclusion and Status of

e. of Compliance Compliance As a result of the environmental As environmental assessment, assessment, EGC EGC concludes concludesthat thatthe theproposed proposedaction, action, which will which willallow allowEGC EGCtotomaintain maintainthethefour fourfuel fuelassemblies assemblies in their current storage storage configuration, is configuration, is in in the the public public interest interest in in that that itit avoids avoids thethe adverse adverse environmental, environmental, radiological, and financial effects associated radiological, and financial effects associated with with the alternative alternative theto the proposed proposedaction.

action.

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