ML19323B347
| ML19323B347 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 04/25/1980 |
| From: | Dawson D GENERAL ELECTRIC CO. |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 16181, NUDOCS 8005120264 | |
| Download: ML19323B347 (8) | |
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C G EN ER AL $ ELECTRIC AND SERVICES DlVISION GENERAL FLECTRIC CO*.iPANY,175 CURTNER AVE, SAN JOSE. CAllFORNIA 95125 SPEtiT FUEL SERVICES OPEPATI0t1 DMD-433 Docket ti O O-130 Materials License flo. Stim-1265 April 25, 1980 Office of tiuclear Material Safety & Safeguards Attn:
R.E. Cunningham, Director Division of Fuel Cycle & Material Safety U.S. tiuclear Regulatory Cormission Wathington, D.C.
20555
SUBJECT:
RESP 0fiSE TO REQUEST FOR ADDITI0tiAL liiFORMATI0ti: REtiEWAL OF MATERIALS LICEtiSE Stim-1265 Gentlemen:
4 The following information concerning the need for continued operation of the General Electric tiorris facility, alternatives considered, quality assurance matters, and the decay period for receipt of fuel is furnished in response to a request dated February 28, 1980, from L. Rouse of your staff.
- 1) Request:
With respect to need for continued operation, please provide the detaila of yotw ca. ;":itmcnt3 t0 provide 3torage cpacc to utilitica as a result of contract or carranty obligaticnc.
Provide thin infomation for the present fact stored oncite at the !!:rric facility, as ocll ao any obligations that may rmain ontatandig.
Sic ~.arice the present necdc that con-stitute a necesaity for continued cperation.
Additionally, incitdc in yo w recponce those alternatives that Gencral Electric has considered relat've to your needs for continued operaticn of the facility.
Response
General Electric needs to continue operation of its spent fuel storage facility at Morris in order to s W e:
(1) GE-owned 16181
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4 G E N E R AL (h> ELECTRIC 2-fuel, (2) utility-owned fuel either presently in storage or scheduled for receipt pursuant to existing contracts, and (3) l other utility-owned fuel if necessary to fulfill existing limited commitments to certain utilities in the event of an emergency j
situation or lack of full core discharge capability at their plant sites.
In addition, the ownership of and responsibility for additional fuel bundles originally supplied by GE to four utilities are in dispute. The resolution of the dispute with three of these utilities has been postponed.
GE is in litigation with the fourth utility.
It is GE's position that it does not own and has no responsibility for any of this fuel. However, GE cannot predict the outcome of the litigation or of the other disputes.
Continued operation will also have the advantage of providing a storage place which could be used to alleviate temporary, emergency storage needs of utilities, such as Dairyland Power, as requested by the Department of Energy.
Alternatives to the continued operation of the Morris facility considered were: close the facility as it stands; replace the Morris facility by constructing and licensing a new facility; transfer stored fuel to a private or government-owned facility; return stored fuel to the nuclear power plant where it was used; transfer stored fuel to any nuclear power plant that has storage space available; reprocess the stored fuel; or dispose of the stored fuel as waste material.
None of these were feasible alternatives to continued operation of the Morris facility for the following reasons:
Closing the facility with stored fuel in place is o
a violation of regulations.
Replacing the existing facility with a new facility o
i is inconsistent with the current energy and environ-mental policies of the Federal government.
There are no other licensed, private away-from-reactor o
facilities with sufficient capacity to store the spent fuel presently stored at Morris.
There are no known government facilities for storing o
I the spent fuel presently stored at Morris, Returning spent fuel to the source power plants may be o
impossible due to lack of sufficient storage space or d
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inadvisable due to storage space congestion and 1
It is also inadvisable loss of full core reserve.
because of additional handling and transport of fuel which would be required.
J Transferring stored fuel to power plants with space I
o available will create future storage problems at those facilities.
Reprocessing the stored fuel is contrary to current o
i governmental policies.
Disposing of the stored fuel as waste is not possible I
due to lack of,~ederal facilities.
o I
Of the alternatives considered, continued operation of the Morris facility represents the least environmental impact.
Closing the facility with fuel still in storage is not considered a viable The stored fuel alternative because it violates regulations.
Re-must be removed or the facility must continue operation.
placing the facility requires additional it.,d and resource I
utilization and eventual transportation of the fuel and its associated environmental impact (shown in 10CFR51, Summary Table Moving the fuel to any other site involves transportation S-4).
and if moved to power plant sites it may, in addition, necessitate plant shutdown and the consequent loss of electrical power Reprocessing of the fuel requires transportation to generation.
a reprocessing facility and the additional environmental impact Discarding due to the process (shown in 10CFR51, Table S-3).
i the fuel as waste requires transportation, land and resource utilization to construct facilities for such disposal and results in loss of the energy value of the fuel thus disposed. The latter two alternatives cannot be accomplished because federal policy prohibits reprocessing and federal policy for waste dis-posal has not been implemented.
d' 2)
Request:
Relative to quality assurance (QA), ths staff has revieued your b
QA plan and recomends revisions in tuo areas, "QA Records" and Guidance used for detemining adequacy of the QA plan 1
"A udit s ".
j is the criteria specified in ANSI N4G.2, "QA Program Requirements for Post Reactor Nuclear Fuel Cycle Facilitics," and proposed revisions to Pegulatory Guide 1.33, "QA Progrx: Requiremer.ts for j
j Operation at Nuclear Pooer Plants. "
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Response
I Changes described in Attachment A to this letter will be introduced in the next revision of Spent Fuel Services Operation Quality Assurance Plan, fIE00-20776, planned for i
completion by December 1980.
- 3) Request:
In considering your application for the reneval of Materialc l
License flo. S!!M-1265, the staff is basing its evaluation on the prenice that the receipt of any irradiated fuel at the Morria Operation vill have decayed [ sic] for a period of not loco than one year.
Accordingly, ce request that General Electric con ~ nit to not receiving any irradiated fuel at the Morris i
Operation that has not decayed for a period of at least one If General Electric car.not make auch a corr:~itment, indicate j
year.
l uhy not,
Response
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General Electric will commit to not receiving any irradiated l
fuel at the Morris Operation that has not decayed for a period of at least one year, with the following exceptions:
1 The present license requirement for fuel received at Morris Operation (see ftEDO-21326C, Chapter 10, Section 10.2.1.1.a.(4)) specifies that fuel shall be cooled a minimum of 90 days after reactor shutdown and prior to shipping.
Most spent fuel shipping l
casks have a maximum decay heat generation rate 3
limit that requires a minimum of 120 day cooling.
These license and certificate of compliance limits are the basis for some of General Electric's contracts.
Therefore, it may be necessary to accept fuel ship-ments r.ade under contracts that include these limits.
e.
Situations may arise at a utility's reactor which w' uld o
require shipment of fuel to Morris Operation which had had been cooled less than one year.
The fiRC shall be notified in advance on a case by case basis when it is necessary to implement either of these exceptions.
We trust that these responses to Mr. Rouse's requests will be Please contact C.C. Herrington (408*925-6385) or satisfactory.
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G EN ER AL [@ ELECTRIC i H.A. Rogers (408*925-6496) of this office if further information should be required.
Respectfully submitted, GENERAL ELECTRIC COMPANY k@M D.M. Dawson, Manager Licensing & Transportation 408*925-6330 MC 861 DMD:CCH:bn Attachment g :....
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ATTACHPENT " A" s
QUALITY ASSURANCE PLAN REVISIONS 1
Relative to quality assurance (CA), the c'aff has revieved your QA plan and reconr: ends revisions in ta creas, "QA Records" 1
Guidance used for detemining adequacy of the QA and " Audits. "
plan is the criteria specified in ANSI N46.2, "QA Program
\\
l "QA Prsgrm and proposed revisions to Regulatory Guide 1.33, i
Requirements for Operation at Nuclear Pouer Plants."
The following changes in NE00-20776, Spent Fuel Services Operation Quality will be introduced in the next revision, planned for com-f l
1 Ascarance Plan pletion by December, 1980.
r 1.
For Section 17.0 "0A Records" A definition of the term " permanent record" will be added to the i
a) section titled Glossary of Terms Used In This Plan, to be consistent T
with other areas of the Plan.
l 2.
For Section 18.0 " Audits" Paragraph 18.2.2(c) - General criteria for the composition of an audit a) team, and for the qualifications and responsibilities of lead auditors i
4 and auditors will be added.
Paragraph 18.2.2(e) - This paragraph will be changed to require an f,
b)
This audit response within.30 days after receipt of an audit report.
response will state corrective action (s) to be taken, including a i
schedule for completion of corrective actions, or other specific response i
to.the audit findings.
Paragraph 18.2.2(h) - This paragraph will be revised to reflect the c) following:
Results of actions taken to correct deficiencies that affect safety (1) and occur in facility equipment, structures, components or methods a
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of operation will be reviewed or reaudited within six months after completion of corrective action.
(2) The conformance of the facility operation to requirements con-tained in license conditions will be audited at least once within 12 months of the initiation of the license requirements, and every twelve months thereafter.
The performance, training, and qualifications of the facility staff
( 3) l engaged in safety-related activities will be audited at least once every 12 months.
Audits will be performed to ensure that all safety-related functions 4
( 4)
,are covered within a period of 24 months.
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NOTICE OF DISTRIBUTION to SERVICE LIST - DOCKET NO. 70-1308 In the matter of General Electric's application for renewal of Naterials
-License No. SNM-1265, capits of the documents discussed in the attached letter have been forwarded to the law firm of Mayer, Brown and Platt, 231 South LaSalle, Chicago, IL.
60604, counsel for General Electric Company, for transmittal to the service list as shown below:
Atomic Safety and Licensing Andrew C. Goodhope. Esq., Chairman Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 3320 Estelle Terrace Wheaton, Maryland 20906 Washington, D.C.
20555 Docketing and Service Section Dr. Linda W. Little Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission 5000 Hermitage Drive Washington, D.C.
20555 Raleigh, North Carolina 27612 Everett J. Quigley Dr. Forrest J. Remick Atomic Safety and Licensing Board RR1, Box 378 Kankakee, IL 60901 305 East Hamilton Avenue i
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State College, Pennsylvania 16801 Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Bridget Little Rorem Essex, IL 60935 Susan N. Sekuler, Esq.
George William Wolf f, Esq.
Office of the Attorney General 1
188 West Randolph Street Suite 2315 Chicago, IL 60601 i
Marjorie Ulman Rothschild, Esq.
l United States Nuclear Regulatory Commission Washington, D.C.
20555 List 3/28/80 A 16181