RA-18-052, Supplement to Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance and Supplement to Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary ...

Supplement to Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance and Supplement to Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary ...

ML18128A291
Person / Time
Site:	Oyster Creek
Issue date:	05/08/2018
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
RA-18-052
Download: ML18128A291 (6)

Text

Michael P. Gallagher Exelon Nuclear Exelon Generation ~ Vice President License Renewal and Decomm1ss1ornng 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp .com m1chaelp.gallagher@exeloncorp.com 10CFR50.12 10 CFR 50.54(w)(1) 10 CFR 140.8 10 CFR 140.11(a)(4)

RA-18-052 May 8, 2018 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15

Subject:

Supplement to Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance and Supplement to Request for Exemption from 10 CFR 140.11 (a)(4), Concerning Primary and Secondary Liability Insurance

Reference:

1) Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Request for Exemption from 10 CFR 50.54(w)(1 ), Concerning On-Site Property Damage Insurance," dated March 29, 2018 (ADAMS Accession No. ML18088A237)

2) Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Request for Exemption from 10 CFR 140.11 (a)(4), Concerning Primary and Secondary Liability Insurance,"

dated March 29, 2018 (ADAMS Accession No. ML18088A849)

3) SECY-93-127, "Financial Protection Required of Licensees of Large Nuclear Power Plants During Decommissioning," dated May 10, 1993 (ADAMS Accession No. ML12257A628)

4) Staff Requirements Memorandum for SECY-93-0127, dated July 13, 1993 (ADAMS Accession No. ML003760936)

On March 29, 2018, Exelon Generation Company, LLC (Exelon) submitted requests for permanent exemption from 10 CFR 50.54(w)(1) (Reference 1) and 10 CFR 140.11(a)(4)

(Reference 2) for Oyster Creek Nuclear Generating Station (OCNGS). These requests were made pursuant to 10 CFR 50.12, and 10 CFR 140.8, "Specific exemptions," respectively.

U.S. Nuclear Regulatory Commission OCNGS Supplement to Requests for Exemptions Docket Nos. 50-219 and 72-15 May 8, 2018 Page 2 Based upon further review of industry precedent, an area needing further information was identified. The information concerns a demonstration that the spent fuel could be air cooled if the spent fuel pool was fully drained. In SECY-93-127, "Financial Protection Required of Licensees of Large Nuclear Power Plants During Decommissioning," (Reference 3), the NRC staff considered decommissioning plants' potential financial liability and the low likelihood and reduced short-term public health consequences of a zirconium fire to determine that the overall risk at decommissioning plants does not justify the full insurance coverage that operating reactors have once a decommissioning plant's spent fuel has sufficiently decayed. In its Staff Requirements Memorandum for SECY-93-0127 (Reference 4), the Commission approved a policy that authorized reductions in commercial liability insurance coverage through the exemption process after the spent fuel had undergone an appropriate period of cooling, which the NRC staff defined as when the spent fuel could be air-cooled if the spent fuel pool was drained of water.

Therefore, Exelon is supplementing this information in the Attachment.

This letter contains no new regulatory commitments.

If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264.

Respectfully, Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC Attachment'. Supplement to Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance and Supplement to Request for Exemption from 10 CFR 140.11 (a)(4}, Concerning Primary and Secondary Liability Insurance cc: w/Attachment Regional Administrator - NRC Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

Attachment Supplement to Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance and Supplement to Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary Liability Insurance

Attachment Supplement to Requests for Exemptions Docket Nos. 50-219 and 72-15 Page A-1 of A-3

1. BACKGROUND On March 29, 2018, Exelon Generation Company, LLC (Exelon) submitted requests for permanent exemption from 10 CFR 50.54(w)(1) (Reference 1) and 10 CFR 140.11(a)(4)

(Reference 2) for Oyster Creek Nuclear Generating Station (OCNGS). These requests were made pursuant to 10 CFR 50.12, and 10 CFR 140.8, "Specific exemptions," respectively.

Based upon further review of industry precedent, an area needing further information was identified. The information concerns a demonstration that the spent fuel could be air cooled if the spent fuel pool was fully drained. In SECY-93-127, "Financial Protection Required of Licensees of Large Nuclear Power Plants During Decommissioning," (Reference 3), the NRC staff considered decommissioning plants' potential financial liability and the low likelihood and reduced short-term public health consequences of a zirconium fire to determine that the overall risk at decommissioning plants does not justify the full insurance coverage that operating reactors have once a decommissioning plant's spent fuel has sufficiently decayed. In its Staff Requirements Memorandum for SECY-93-0127 (Reference 4), the Commission approved a policy that authorized reductions in commercial liability insurance coverage through the exemption process after the spent fuel had undergone an appropriate period of cooling, which the NRC staff defined as when the spent fuel could be air-cooled if the spent fuel pool was drained of water.

2. TECHNICAL EVALUATION Exelon has compiled data comparing the input parameters to the representative NRC generic Analyses (NUREG/CR-6451, 1997, Reference 5) to the data for Oyster Creek Nuclear Generating Station (OCNGS). Since OCNGS fuel assemblies have a 21 % lower power density and 5 months longer decay period there should be lower heat rate(s) than those cited for NUREG/CR-6451. The OCNGS parameters that are non-conservative to the inputs used in the NUREG (slightly smaller pitch in the spent fuel racks and a longer burnup period) are more than compensated for by the longer decay period and lower assembly power density. As a result, the OCNGS spent fuel pool (SFP) conditions are bounded by the NUGREG/CG-6451 benchmark and that the OCNGS spent fuel would be air coolable at 12 months after permanent shutdown.

Attachment Supplement to Requests for Exemptions Docket Nos. 50-219 and 72-15 Page A-2 of A-3 Spent Fuel Zirconium Fire Comparison Parameter NU REG/CR- OCNGS Difference 6451 (reference 5)

Plant Data Power 1155 MWe 650 MWe (3300 MWt) (1930 MWt)

Assemblies 764 560 204 less hot assemblies MWt/Assembly 4.3 3.4 21 % lower pwr density Spent Fuel Pool Capacity 3300 Capacity 3035 Less bundles adding heat Storage Data All slots filled 2433 filled More air flow passages SFP Rack Design Design High Density High Density Material Stainless Steel Stainless Steel Pitch 6.255" 6.198" Boraflex ( 10 racks) 0.057" closer 6.106" Boral (4 racks) 0.149" closer Orifice size 4" 3.75" Rack orifice of 3.75" is bounded by fuel orifice of 3.5" Fuel Design Max Assembly 40 GWD/MTU 48.76 GWD/MTU Potentially up to 22%

Burn up higher heat due to increased max assembly burn up Source Term 7 Months 12 Months 35% less decay heat Decay contribution due to longer source term decay time.

Zirconium 565° c 565° c same Oxidation Temperature Limit Power Density Comparison Parameter NUREG/CR-6451 and OCNGS Reference 6 Power Per Assembly (MWO 4.3 3.4 Fuel Assemble L/W (inches) 5.28 5.26 Fuel Active Height (inches) 145.24 145.24 Active Volume (in 3 rm 3]) 4049.1 [0.0664] 4018.4 [0 .0659]

Power Density (MWt/m 3 ) 64.8 51.6 Uranium Mass per -- 0.181368 Assembly (MTU)

Attachment Supplement to Requests for Exemptions Docket Nos. 50-219 and 72-15 Page A-3 of A-3

3. REFERENCES

1) Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Request for Exemption from 10 CFR 50.54(w)(1}, Concerning On-Site Property Damage Insurance," dated March 29, 2018 (ADAMS Accession No. ML18088A237)

2) Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Request for Exemption from 10 CFR 140.11 (a)(4 ), Concerning Primary and Secondary Liability Insurance," dated March 29, 2018 (ADAMS Accession No. ML18088A849)

3) SECY-93-127, "Financial Protection Required of Licensees of Large Nuclear Power Plants During Decommissioning," dated May 10, 1993 (ADAMS Accession No. ML12257A628)

4) Staff Requirements Memorandum for SECY-93-0127, dated July 13, 1993 (ADAMS Accession No. ML003760936)

5) NUREG/CR-6451 "A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shutdown Nuclear Power Plants," dated April 1997

6) Office of Civilian Radioactive Waste Management, "Characteristics of Spent Fuel High-Level Waste, and Other Radioactive Wastes Which May Require Long-Term Isolation,"

DOE/RW-0184, U.S. Department of Energy, Washington, DC, December 1987 (Reference 15 in Reference 5)