ML16285A270

Independent Spent Fuel Storage Installation - Withdrawal of Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214

ML16285A270
Person / Time
Site:	Maine Yankee, 07201015
Issue date:	09/27/2016
From:	Jonathan Brown Maine Yankee Atomic Power Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
OMY-16-031
Download: ML16285A270 (3)

Text

MAINE YANKEE 321 Old Ferry Road, Wiscasset, Maine 04578 September 27, 2016 OMY-16-031 Re: 10 CFR 72.4 and IO CFR 72.7 ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Maine Yankee Atomic Power Company Maine Yankee Independent Spent Fuel Storage Installation NRC License No. DPR-36 (NRC Docket No. 50-309)

Subject:

Withdrawal of Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 for the Maine Yankee Independent Spent Fuel Storage Installation On April 14, 2016, Maine Yankee Atomic Power Company (Maine Yankee) requested an exemption from the requirements of 10 CFR 72.212(a)(2), 10 CFR 72.212(b)(3),

10 CFR 72.212(b)(5)(i), 10 CFR 72.212(b)(11 ), and l 0 CFR 72.214 for the Maine Yankee Independent. Spent fuel Storage Installation (ISFSI) (Reference 1). The requested exemption was for the limited purpose of allowing Maine Yankee to reinstate the:version of Technical Specification (TS) A 3.2.2, "Concrete.Cask Average

. Surface Dos~ Rate," . established in.

Amendment No. 2 of Certificate of Compliance (CoC) No. 72-1015 (Reference 2) as the applicable TS for Maine Yankee, in lieu of the version of TS A ~ .2.2 established in Ameq:dment No. 5 of the NAC-UMS CoC No. 72-1015 (Reference 3). The exemption request was intended to resolve a difference between the Applicability statement for TS A 3.4.2 that state.s "During STORAGE OPERATIONS," and the Frequency.for Surveillance Requfrement (SR)'3.2.2J that states "Prior to STORAGE OPERATIONS."

The Applicability for TS A 3.2.2 was changed from "During LOADING OPERATIONS" in Amendment No. 2 of CoC No. 72-1015 to "During STORAGE OPERATIONS" in Amendment No. 3 of CoC No. 72-1015 (Reference 4) primarily because of the experience gained during the.

Maine Yankee loading campaign.* The term LOADING OPERATIONS is specificallydefined in the TS A I.I, "Definitions." Since LOADING OPERATIONS ends when the NAC-UMS System is secured to the transporter, the Amenqment No~ 2 version of SR 3.2.2.1 provides a very narrow timeframe to ~erform SR 3.2.2;1 .. This i~ because TRANSPORT OPERATIONS begins when th.e NAC,UMS System is secur,edJo the transporter and ends when the NAC-UMS System is at its destination and no longer secured cm the.transporter, generally the beginriing of STORAGE OPERATIONS. . . . .

On March 22, 2004, the NRC issued CoC No. 72-1015 Amendment No. 3 to NAC (Reference 4). This document :changed the Applicability for NAC UMS TS A 3 .2.2 from "During LOADING OPERATIONS" to "During STORAGE OPERATIONS." The NRC's

Maine Yankee Atomic Power Company OMY-16-031/September 27, 2016/Page 2 Safety Evaluation Report for Amendment No. 3 to CoC No. 72-1015 identified this change as an "Editorial Consistency" (Reference 5).

The Applicability of TS A 3.2.2 from Amendment No. 3 ofCoC No. 72-1015 (Reference 4) is the same as the Applicability of TS A 3.2.2 established in Amendment No. 5 ofCoC No. 72-1015 (Reference 3). When Maine Yankee registered the previously loaded casks and canisters to Amendment No. 5 of CoC No. 72-1015, the Applicability ofNAC-UMS TS A 3.2.2 changed from "During LOADING OPERATIONS" to "During STORAGE OPERATIONS" (Reference 6). Prior to the adoption of Amendment No. 5, Maine Yankee had previously performed and met SR 3.2.2.1 for each of the 60 NAC-UMS casks. Thus, Maine Yankee is not required to perform SR 3 .2.2.1 again for any of the 60 NAC-UMS casks. In addition, there are no additional casks to be loaded at Maine Yankee, so no additional performances of SR-3.2.2.1 will be required for newly loaded casks.

At the request of the NRC, Maine Yankee is withdrawing the exemption request, with the following understanding:

1) Maine Yankee currently remains in compliance with the Limiting Condition for O~eration (LCO) 3.2.2 of the NAC-UMSTS, provided in Amendment No. 5 ofNAC-UMS CoC No. 72-1015. Maine Yankee established that each of the 60 casks that are utilized to store spent fuel met the average surface dose rate requirements for the sides, top, and inlets and outlets established in the version ofLCO 3.2.2 in accordance with SR 3.2.2.1 (Amendment No. 2). There are no additional casks to be loaded with spent fuel at Maine Yankee, so no additional performances of SR 3.2.2.1 will b~ required. In addition~ the casks and canisters have been in storage for a number of years. The cask surface dose rates and canister heat loads have declined naturally and will continue to decline over time; *

2) Given the current static condition of the Maine Yankee ISPSI, only a beyond design basis event would drive the average surface dose rates on the sides, top, or inlets and outlets of one or more casks to exceed the applicable acceptance criterion established in NAC-UMS TS A 3.2.2. Based on these considerations, the current configuration complies with TS A 3.2.2 and is safe; and

3) In the event that NAC (the CoC Holder) and the NRC take action to resolve the inconsistency in the Applicability Statement for NAC-UMS TS A 3.2.2 and Surveillance Requirement 3.2.2.1 via the amendment process defined in 10 CPR 72.244 and 10 CPR 72.246 or some other process, Maine Yankee would be willing to adopt that resolution as part of its licensing basis in accordance with the applicable regulations.

This letter contains no commitments.

Maine Yankee Atomic Power Company OMY-16-031/September 27, 2016/Page 3 If you have any questions regarding this submittal, please do not hesitate to contact me at (207) 882-1303.

Respectfully, J.: ::-:~!:E.

ISFSI Manager

Reference:

1. Letter from J. Stanley Brown, P, E. (Maine Yankee) to Document Control Desk (NRC),

Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 for the Maine Yankee Independent Spent Fuel Storage Installation, dated April 14, 2016 (OMY-16-024)

2. Amendment No. 2 ofNAC-UMS Certificate of Compliance No. 72-1015, including Appendix A, "Technical Specifications for the NAC-UMS System."

3. Amendment No. 5 ofNAC-UMS Certificate of Compliance No. 72-1015, including Appendix A, "Technical Specifications for the NAC-UMS System."

4. Amendment No. 3 ofNAC-UMS Certificate of Compliance No. 72-1015, including Appendix A, "Technical Specifications for the NAC-UMS System."

5. NRC Safety Evaluation Report, Docket No. 72-1015, NAC-UMS Storage System, Certificate of Compliance No. 72-1015, Amendment No. 3, dated March 22, 2004.- * *

6. Letter from J. Connell (Maine Yankee) to Document Control Desk (NRC), Maine Yankee Atomic Power Company Adoption ofNAC-UMS System, Amendment No. 5 Certificate of Compliance and Canister Registration, dated July 12, 2011.

cc: D. Dorman, NRC Region I Administrator R. Powell, Chief, Decommissioning Branch, NRC, Region I J. Goshen, NRC Project Manager P. J. Dostie, SNSI, State of Maine J. Hyland, State of Maine K. Cole, NAC International