ML18057A927
| ML18057A927 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/24/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9106030188 | |
| Download: ML18057A927 (11) | |
Text
consumers Power PDWERINli NllCHlliAN~S PRDliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 May 24, 1991 Director Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
GB Slade General Manager 10CFR72, SUBPART K - GENERAL LICENSE FOR STORAGE OF SPENT FUEL AT POWER REACTOR SITES - EXEMPTION REQUEST This letter transmits a request for an exemption from specific sections of 10CFR72 Subpart K to allow Consumers Power Company (CPC) to load Pacific Sierra Nuclear (PSN) Ventilated Storage Casks (VSC-24) prior to final approval of the cask certification. The reasons for this request are described below.
On March 9, 1990, CPC applied for a specific Independent Spent Fuel Storage Installation (ISFSI) license to use the VSC-24.
Subsequently, the issuance of 10CFR72 Subpart Kon August 6, 1990 provided a general ISFSI license to 10CFR Part 50 license holders.
On August 17, 1990, the NRC staff assured CPC that the Topical Safety Analysis Report on the PSN VSC-24 would be approved in October 1990 and certification would take an additional 6 months or less.
CPC then withdrew its application for a specific ISFSI license with reliance on the NRC estimated schedule for certification of the VSC-24 cask and the Palisades general ISFSI license to maintain full core discharge capability.
Due to the NRC workload on other projects, the Safety Evaluation Report for the VSC Topical Safety Analysis Report was not issued until March 29, 1991.
On April 25, 1991, the NRC staff informed CPC and PSN that the estimated time to complete the certification of the VSC-24 would take an additional 12 months instead of the previously estimated 6 months.
This six month schedule delay I
has the potential to cause the Palisades Plant to lose full core discharge capability at the beginning of fuel cycle 10 which is scheduled for mid-April I {
1992.
'To maintain full core discharge capability, an exemption under the prov1s1ons of 10CFR72.7 is being requested to allow use of the PSN VSC-24 before the cask is certified.
As an ancillary action, PSN must obtain exemption from 10CFR72.234(c) to fabricate the VSC-24 cask before the Certificate of Compliance is issued.
PSN plans to request such an exemption.
CPC supports that exemption and requests the NRC to expedite approval of both the CPC and PSN exemption requests.
The exemption request for Palisades to use the PSN VSC-24 under our 10CFR72 general license is included as Enclosure 1.
Consumers Power Company requests approval of this exemption before the end of June 1991 in order that we can meet the schedule presented in Attachment 1 to Enclosure 1 and thereby maintain full core discharge capability at the Palisades Plant.
~7~
Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment
ENCLOSURE I Consumers Power Company Palisades Plant Docket 50-255 EXEMPTION REQUEST IOCFR72 SUBPART K - GENERAL LICENSE FOR STORAGE OF SPENT FUEL AT POWER REACTOR SITES 2 Pages
1 EXEMPTION REQUEST Consumers Power Company (CPC) requests exemption under the provisions of Section 10CFR72.7 from the Certificate of Compliance requirements of 10CFR72 Subpart K to the extent that the Pacific Sierra Nuclear (PSN) Ventilated Storage Cask (VSC-24), used in the manner described in the NRC approved Revision 2A of the PSN report "Topical Safety Analysis Report For The Ventilated Storage Cask System" dated April 4, 1991, is approved for the Palisades Plant to use to store spent fuel under its general license as issued by Section 10CFR72.210.
The exemption would expire when the VSC-24 Certificate of Compliance is issued.
JUSTIFICATION FOR EXEMPTION
- 1.
The PSN VSC-24 has been approved by the NRC as long as the cask is used and fabricated as described in Revision 2A of the PSN report, "Topical Safety Analysis Report for The Ventilated Storage Cask System." This revision of the Topical Safety Analysis Report (TR) includes the Safety Evaluation Report (SER) issued by the NRC.
Thus the PSN VSC-24, when used in compliance with Rev 2A of the PSN TR, meets the provisions of 10CFR72(a)(2) except the process of issuing a Certificate of Compliance has not been completed.
- 2.
In February 1989 when the decision to use the VSC-24 system to maintain full core discharge capability at Palisades was implemented, CPC planned to obtain and applied for a site specific 10CFR72 ISFSI license. Later, in August 1990, the NRC issued 10CFR72 Subpart K which provided a general 10CFR72 license for the Palisades Plant.
With assurance from the NRC staff that PSN could obtain a Certificate of Compliance for the VSC-24 no more than six months after the SER on the VSC-24 was issued (the SER was scheduled to be issued in October 1990),
CPC withdrew its 10CFR72 site specific license request.
If the original NRC schedule (SER issued in October 1990) had been maintained, the VSC-24 Certificate of Compliance could have been issued in April 1991.
CPC did make contingency plans that allowed the certification of the VSC-24 to be delayed as much as 6 months to October 1991.
Because of the NRC workload on other projects, the SER on the VSC-24 was not issued until April 1991 and the estimated time to certify the cask increased from 6 to 12 months after the SER was issued.
Unless this exemption request is expeditiously approved, the additional delay will cause Palisades to operate without full core discharge capability through much of fuel Cycle 10 which begins in April of 1992.
- 3.
To ensure full core discharge capability for cycle 10, CPC must build a cask pad with appropriate security features, obtain the VSC-24 storage system and train people in its use. A schedule to accomplish this is included in Attachment 1.
- 4.
Full core discharge capability at the Palisades Plant is important to CPC to decrease the probability of an extended outage due to having to discharge the full core for an unscheduled reactor vessel inspection or
repair of certain primary coolant system instrument and drain valves.
Although the probability of having to perform an unscheduled full core discharge is small, if that capability is lost, the cost of funds to operate could become higher due to assurance desired by financial interests that full core discharge capability does exist.
- 5.
CPC will purchase and use VSC-24 casks fabricated in compliance with the NRC approved Revision 2A of the PSN Topical Report.
Those items required by the SER portion of Revision 2A of the TR to be addressed in an SAR for a site specific ISFSI license will be reviewed in compliance with the provisions of the Palisades 10CFRSO operating license.
2
- 6.
The other requirements of 10CFR72 Subpart K will be met except, that since the Certificate of Compliance for the VSC is not scheduled to be issued until approximately April 1992, a pro-forma Certificate of Compliance similar to that submitted to the NRC by PSN on April 4, 1991 with PSN's request for a Certificate of Compliance will be used to comply with Sections 72.212(b)(2), 72.212(b)(3) and 72.212(b)(7) which reference the Certificate of Compliance for prescribed evaluations and records.
Use of the pro-forma Certificate of Compliance does not significantly impact safety since the requirements suggested by PSN's pro-forma Certificate of Compliance are within the NRC approved parameters of the requirements of PSN's Topical Report, Rev 2A.
- 7.
At the beginning of cycle 10, if Palisades has at least three VSC-24 casks capable of being loaded, and has the ability to load, transport and store the casks, full core discharge capability will be maintained. Although three casks will meet our immediate needs, approval is sought under the exemption to load as many VSC-24 casks as necessary to provide safe and efficient operation. Attachment 1 to this request describes the present status of the Palisades spent fuel storage capability.
- 8.
Use of the VSC-24 cask at the Palisades site is within the design and analysis bases described in the Topical Safety Analysis Report as approved and discussed by the NRC in their Safety Evaluation Report. Therefore, fabrication and use of the VSC cask will not endanger life or property or the common defense and security and is otherwise in the public interest by reducing financial cost and providing increased assurance of the continued economical supply of electricity to Michigan.
ENCLOSURE 1 ATTACHMENT 1 Consumers Power Company Palisades Plant Docket 50-255 EXEMPTION REQUEST 10CFR72, SUBPART K - GENERAL LICENSE FOR STORAGE OF SPENT FUEL AT POWER REACTOR SITES 5 Pages
STATUS OF SPENT FUEL STORAGE AT PALISADES DURING FUEL CYCLES 9 & 10 At the present time, the plant is operating in Cycle 9.
The end of Cycle 9/beginning of Cycle 10 Refueling Outage is scheduled for February 15, 1992 through April 15, 1992.
The following assumes:
a) the control rods will be stored in a special rack; b) new fuel storage in the fuel pool is not considered since it can be put back in the shipping container; and c) a full core discharge (FCD) is required for repairs during Cycle 10.
- 1.
Present, during Cycle 9 204 spaces fi 11 ed Reactor Vessel
- 2.
Beginning of Cycle 10 (76 new fuel assembly are in RV) 204 spaces fi 11 ed Reactor Vessel 1
663 of 892 spaces filled 229 empty Spent Fuel Pool 663 + 76 = 739 of 892 spaces filled (153 spaces empty)
Spent Fuel Pool l
- 3.
If full core discharge is required during Cycle 10 and no spent fuel has previously been loaded into casks.
- a.
at start of FCD 204 spaces fi 11 ed Reactor Vessel ac R k W 1 (121 spaces )
to allow transfer cask placement 739 of (892 - 121) spaces fil 1 ed (32 spaces empty)
Spent Fuel Pool remove
= 771 3.b.1 Loading of VSC-24 Casks, transfer cask placed in pool 204 spaces fi 11 ed Reactor Vessel Transfer Cask 2
> 51 Assembly load n
~
1
-3 VSC-24 casks (would actually load 72 Assemblies) 688 of 771 spaces fi 11 ed 83 empty Spent Fuel Pool d
3.b.2 W-1 rack (121 spaces) reinstalled in Pool (Transfer cask and impact limiting pad removed) 204 spaces fi 11 ed Reactor Vessel 688 of 892 spaces filled 204 empty Spent Fuel Pool 3.b.3 204 assembly moved from RV to SFP (full core discharge) 0 spaces fi 11 ed Reactor Vessel 3
892 of 892 spaces filled 0 empty Spent Fuel Pool
- 4.
Resume operation after repairs completed (assumes still in Cycle 10) 204 spaces fi 11 ed Reactor Vessel 4
688 of 892 spaces filled 204 spaces empty Spent Fuel Pool
CRITICAL PATH ACTIVITIES FOR THE DRY FUEL STORAGE PROJECT FC-864 1990 1991 1992 s 0 N D J F M A M J J A s 0 N D J F M A M J J A EOC-9 I
I x
- 1. TOPICAL REPORT APPROVED BY NRC
- 2. CASK CERTIFIED BY NRC I
I
- 3. MSB FABRICATION I
I X x I
I x x
- 4. STORAGE PAD CONSTRUCTION I
I x x
- 5. CASK CONSTRUCTION I
I x x
- 6. TRANSFER CASK FABRICATION
- 7. PRE-OP TESTING
( 1) I I
~CJ
- 8. 1992 REFUELING OUTAGE I
I I
I
- 9. HAVE AT LEAST 3 CASKS READY TO LOAD
- 10. LOAD 8 CASKS*
I
- WHEN THE CASKS ARE ACTUALLY LOADED HAS NOT BEEN DETERMINED.
IF AT LEAST 3 CASKS ARE AVAILABLE, FULL CORE DISCHARGE IS POSSIBLE DURING CYCLE 10 (1) First MSB and VCC ready for testing 5