ML18153A650
| ML18153A650 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 01/28/1997 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 96-474, NUDOCS 9702040019 | |
| Download: ML18153A650 (7) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 28, 1997 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No.96-474 NL&OS/GDM R3 Docket Nos. 50-280, 50-281 50-338, 50-339 License Nos. DPR-32, DPR-37 NPF-4, NPF-7 NORTH ANNA POWER STATION UNITS 1 AND 2 REQUEST FOR EXEMPTION FROM 10 CFR 70.24(a)
CRITICALITY ACCIDENT MONITORING REQUIREMENTS Pursuant to 10 CFR 70.24(d) and 70.14(a), Virginia Electric and Power Company requests permanent exemption from the criticality monitoring requirements specified in 10 CFR 70.24(a), "Criticality Accident Requirements," for Surry and North Anna Power Stations Units 1 and 2.
This request, as described in the attachment, involves no changes to radiation monitoring instrumentation or emergency procedures presently used at either station.
Although exemptions from the requirements of 10 CFR 70.24(a) were previously granted for each unit at both stations with the issuance of the special nuclear material (SNM) licenses for each unit, the exemptions were not incorporated.into the 1 O CFR 50 operating licenses. Therefore, we are submitting this request for exemption from 10 CFR 70.24(a) to formally restore relief from criticality monitoring requirements relative to our 10 CFR 50 licenses. We believe this exemption is technically justifiable for the same reasons that the NRC previously granted the exemption for the SNM licenses. A criticality accident monitoring system and associated emergency procedures are not necessary for either Surry or North Anna Power Stations.
No new commitments are intended as a result of this letter. If you have any questions or require additional information, please contact us.
Very truly yours, James P. O'Hanlon Senior Vice President - Nuclear
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- Attachment cc:
Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. R. A. Musser NRG Senior Resident Inspector Surry Power Station Mr. R. D. McWhorter NRG Senior Resident Inspector North Anna Power Station
Attachment Request for Exemption from 10 CFR 70.24(a)
Criticality Accident Requirements Surry Power Station Units 1 and 2 North Anna Power Station Units 1 and 2
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Request for Exemption from 1 O CFR 70.24(a)
Criticality Accident Monitoring Requirements North Anna and Surry Power Stations Units 1 and 2
Background
Pursuant to 10 CFR 70.24(d) and 70.14(a), Virginia Electric and Power Company requests an exemption from the requirements of 10 CFR 70.24, "Criticality Accident Requirements," for Surry and North Anna Power Stations Units 1 and 2. This request involves no changes to radiation monitoring instrumentation or emergency procedures presently used at either station.
Specific exemptions from 10 CFR 70.24 were previously granted for each unit at both stations and were contained in the special nuclear material (SNM) licenses for each unit. However, the exemptions were not incorporated into the 10 CFR 50 operating licenses when they were issued and the SNM licenses expired. Therefore, we are submitting this-request for exemption from the requirements of 10 CFR 70.24(a) to formally obtain relief relative to our 10 CFR 50 licenses.
We believe* this exemption is technically justified.
A criticality accident monitoring system and associated emergency procedures are not necessary for either Surry or North Anna Power Stations due to plant design and existing administrative controls that preclude inadvertent criticality. Furthermore, exemptions from the requirements of 10 CFR 70.24(a) have recently been granted to other licensees based on technical justifications similar to that provided herein.
Regulatory Requirements 10 CFR 70.24(a) requires licensees authorized to possess certain amounts of special nuclear material to maintain a monitoring system and emergency procedures for the purpose of detecting and responding to an accidental criticality event.
These requirements are applicable to North Anna and Surry Power Stations.
Specifically, Section 70.24(a) requires licensees to:
Maintain in each area in which such licensed special nuclear material is handled, used or stored, a monitoring system meeting the requirements of either paragraph (a)(1) or (a)(2), as appropriate, and using gamma-or neutron-sensitive radiation detectors which will energize clearly audible alarm signals if accidental criticality occurs; Maintain emergency procedures for each area in which this licensed special nuclear material is handled, used or stored to ensure that all personnel withdraw to an area of safety upon the sounding of the alarm; and,
Retain a copy of current procedures for each area as a record for as long as licensed special nuclear material is handled, used or stored in an area. The licensee shall retain any superseded portion of the procedures for three years after the portion is superseded.
1 O CFR 70.24(d) anticipates that relief from these requirements is appropriate in certain circumstances and allows licensees to apply for exemption from 10 CFR 70.24 if good cause is shown. Good cause_exists for North Anna and Surry Power Stations based on the following reasons: 1) as explained below, fuel storage design and procedural controls preclude accidental criticality, 2) compliance with 10 CFR 70.24(a) would not serve the underlying purpose of the regulation, 3) exemptions from the requirements of 1 O CFR 70.24(a) were previously approved for North Anna and Surry Power Stations Units 1 and 2 in their SNM licenses, 4) since the original exemptions were issued, no changes in the use, storage, or handling of SNM have occurred which would make compliance with 10 CFR 70.24(a) necessary and 5) the requested exemption has already been granted to other licensees for reasons similar to those provided below.
In addition to showing good cause pursuant to 10 CFR 70.24(d), a request for exemption from 10 CFR 70.24(a) must also satisfy the requirements of 10 CFR 70.14(a). Our exemption requests satisfy these requirements as discussed below.
Requirements of Section 70.14(a)*
The specific requirements for granting exemptions from 10 CFR 70 regulations are set forth in 10 CFR 70.14(a). Under 10 CFR 70.14(a), the NRC is authorized to grant an exemption upon a demonstration that the exemption: (1) is authorized by law, (ii) will not endanger life or property or the common defense and security, and (iii) is in the public interest. The following addresses each of these requirements and demonstrates that the NRC should grant the exemption requests.
A.
The Exemption Requests are Authorized By Law The NRC's authority to grant exemptions from its regulations in 10 CFR 70 is established by law as discussed in 10 CFR 70.14(a). ** Furthermore; 10 CFR 70.24(d) clearly states that the NRC has specific and express authority to exempt licensees from the requirements of 10 CFR 70.24.
Therefore, granting exemptions is explicitly authorized by the NRC's regulations.
B.
The Exemption Requests Will Not Endanger Life or Property or the Common Defense and Security The manner in which SNM is used, stored and handled at North Anna and Surry provides adequate protection for the health and safety of the public.
Specifically, design characteristics, procedural controls and accident analyses ensure that
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"'atcid~ntal or inadvertent criticality will not occur at either North Anna or Surry.
Furthermore, the exemption requests are consistent with the common defense and security since the presence or absence of a criticality monitoring system does not ensure against the loss or diversion of SNM. Each of the remaining requirements is addressed individually in the following discussion.
1.UseofSNM At Surry and North Anna Power Stations, SNM is present principally as nuclear fuel.
Other smaller quantities of SNM are used on site; however, the total amount used in non-fuel applications is significantly less than the quantity specified in 10 CFR 70.24(a). The small quantity of non-fuel SNM present, and the form in which it is used and stored, precludes an inadvertent criticality.
Therefore, SNM used as nuclear fuel is the only material on site subject to the requirements of 10 CFR 70.24(a).
Inadvertent or accidental criticality of SNM while in use in the reactor vessel is controlled by the Part 50 license through compliance with the Surry and North Anna Technical Specifications (TS}, including reactivity requirements (e.g., shutdown margins, limits on control rod movement), instrumentation requirements (e.g.,
reactor power and radiation monitors), and controls on refueling operations (e.g.,
refueling boron concentration and source range monitor requirements).
Since access to the fuel in the reactor is not physically possible while in use and is furthermore covered by the underwater handling exclusion of 70.24(a), there are no criticality concerns with fuel in the reactor vessel.
- 2. Storage of SNM SNM as nuclear fuel is stored in two locations - the spent fuel pool and the new fuel storage area. Fuel stored -in the spent fuel pool is maintained underwater and is therefore excluded from criticality monitoring requirements as allowed by 10 CFR 70.24(a).
The new fuel storage areas at both North Anna and Surry are used to receive and store new fuel in a dry condition upon arrival onsite and prior to loading into the reactor. The new fuel storage area is designed to store new fuel in a geometric array that precludes criticality.
New fuel is stored vertically in an array with a distance of 21 inches between assemblies to assure Kett is less than or equal to 0.98 with fuel of the highest anticipated enrichment in place assuming optimum moderation, e.g., an aqueous foam envelopment as the result of local fire fighting operations.
- 3. Handling of SNM Both irradiated and unirradiated fuel is moved to and from the reactor vessel and the spent fuel pool to accommodate refueling operations, as well as within the reactor
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- -* * '. *vessel and spent fuel pool. Unirradiated fuel is also moved into the Fuel Building for storage and to and from the new fuel storage area. Irradiated fuel is also moved out of the Fuel Building for storage at the onsite Independent Spent Fuel Storage Installation. In every case, fuel movement is procedurally controlled and designed to preclude criticality concerns. Furthermore, accident analyses previously reviewed by the NRG have demonstrated that a fuel handling accident (i.e., a dropped fuel assembly or a spent fuel cask handling accident) will not create conditions that exceed design specifications. In addition, the Technical Specifications specifically address refueling operations and impose restrictions on fuel movement to preclude an accidental criticality, as well as limit the movement of certain loads over spent fuel in the reactor vessel and the spent fuel pool.
Additionally, the Emergency Response Plans for each station contain provisions for coping with unusual events such as a dropped fuel assembly.
Therefore, the criticality monitoring requirements of 10 CFR 70.24 are not necessary for the safe handling of SNM, and granting this exemption will not endanger life or property or the common defense or security.
C.
The Exemption is in the Public Interest The installation and continued maintenance of a criticality monitoring system would necessarily require the expenditure and diversion of resources from other more significant activities. Implementation of 10 CFR 70.24(a) would require the operation and maintenance of the systems for the life of the stations, as well as the planning and conducting of drills specifically designed to respond to a criticality accident. Monitoring based on the guidance in 10 CFR 70.24(a) is unnecessary because of the lack of a credible accident that would produce a criticality. The minimal benefits of complying with the criticality monitoring requirements of 10 CFR 70.24(a) are not commensurate with the diversion of resources from risk significant activities.
Consequently, the exemption request is in the public interest.
Conclusion Exemptions from the requirements of 10 CFR 70.24(a) have been previously granted to numerous other Part 50 licensees for similar reasons as stated h-erein. Furthermore, compliance with 10 CFR 70.24(a) would result in expenditures beyond those required of similar facilities for a system which has been shown by evaluation to be unnecessary.
Therefore, because the exemptions from the requirements of 10 CFR 70.24(a) for North Anna and Surry Power Stations Units 1 and 2 are authorized by law, will not endanger life or property or the common defense and security, is in the public interest due to the presence of special circumstances, and are requested for good cause, Virginia Electric and Power Company respectfully requests that, in accordance with the requirements of 1 O CFR 70.14 and 70.24(d), the NRG should grant the requested exemptions.