ML20072K526
| ML20072K526 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/12/1994 |
| From: | Stetz J CENTERIOR ENERGY |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-59FR28496, RULE-PR-72 59FR28496-00010, 59FR28496-10, NUDOCS 9408300136 | |
| Download: ML20072K526 (4) | |
Text
..
I DOCKETED lD CENTERIOR U
ENERGY ysypc C200 Oan Tree Bosesor:
va t seem 94 AUG 15 P1 :07 n o so. 94w 70evenw ce os a6 m roo cwers o-44c 4, g 0FFi;?
V. (
DC F ug g.
. i ', G Ruil 7ha (sgen. 2in?gs)
Docket Number 50-346 License Number NPF-3 Serial Number 2246 August 12, 1994 The Secretary, U.S. Nuclear Regulatory Commission Attention:
Docketing and Service Branch Vashington, D. C.
20555 Subj ec t :
Comments on Proposed Rule to Add the Standardized NUHOMS Horizontal Modular Storage System to the List of Approved Spent Fuel Storage Casks Gentlemen:
On June 2, 1994, the Nuclear Regulatory Commission (NRC) published in the Federal Register (59 FR 28496) a proposed rule to add the Standardized NUHOMS Horizontal Modular Storage System to 10 CFR 72.214, List of Approved Spent Fuel Storage Casks.
Comments on the proposed rule vere solicited by the Federal Register Notice.
Toledo Edison welcomes the opportunity to comment on the proposed rule.
Toledo Edison commends the NRC for moving forward with the certification of the standardized NUHOMS storage system which is i
selected for use at the Davis-Besse Nuclear Power Station (DBNPS) to augment on site fuel storage capacity beginning in the summer of 1995.
Utilization of the NUHGdS system at the DBNPS will enable Toledo Edison to maintain sufficient capacity in the spent fuel pool to completely l
off load the reactor core following the refueling outage scheduled in early 1996.
Because of this need, Toledo Edison encourages the NRC to complete this rulemaking in an expeditious fashion.
Toledo Edison has reviewed the proposed Certificate of Compliance and Draft Safety Evaluation Report for the Standardized NUHOMS system.
Toledo Edison's comments are attached.
9408300136 940812 PDR PR 72 59FR28496 PDR operavg compon.es Cieveland Flectric 1%mmaug Totedo Ed' son
~
Docket Number 50-346 License Number NPF-3 Serial Number 2246 Page 2 1
Should you have any questions or require additional information regarding Toledo Edison's comments, please contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.
Very truly yours, John P. Stetz Vice President - Nuclear Davis-Besse Nuclear Power Station PVS/ eld Attachment cc:
L. L. Gundrum, NRC Project Manager J. B. Martin, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector USNRC Document Control Desk Utility Radiological Safety Board T
i
Docket Number 50-346 License Number NPF-3 Serial Number 2246 Attachment Page 1 2
1 Comments on the Proposed Certificate of Compliance Page A-4 The requirement to load the first canister with a design basis fuel load should be modified to allow more latitude in the selection of fuel.
It is likely that Toledo Edison vill be the first use of the standardized NUHOMS system.
Although, Toledo Edison currently has design basis spent fuel, our philosophy is to perform dry casking of the oldest fuel first, thereby minimizing both heat load and radiation dose. This philosophy is also consistent with our public information i
campaign which has always stated that the oldest fuel vould be loaded first. The requirement for the first user to load design basis fuel seems contrary to the As Lov As Reasonably Achievable (ALARA) principle.
Page A-6, first paragraph in Bases The reference to Tables 12-la and lb appears to be in error.
The reference should be to Tables 1-la and 1-lb.
Some clarification of the integrity of spent fuel permitted to be stored is requested.
It should be made clear that fuel need not be specially inspected to be eligible for storage, that pinhole leaks do not constitute gross breeches, and that fuel is eligible for storage provided that it does not require special handling or storage provisions within the spent fuel pool.
Page A-8, Assembly Length The specification for assembly length refers to Safety Analysis Report (SAR) Chapter 3 Chapter 3 addresses the length of as built new fuel.
l I
Irradiated fuel vill be longer than new fuel. This should be clarified.
Page A-19, Basis paragraph The sentence in the middle of the paragraph that begins " Acceptable damage may occur..." should read " Unacceptable damage may occur..."
Page A-25 The Action for Technical Specification 1.2.16, Yearly Average Ambient Temperature, appears to be a surveillance requirement versus an action statement.
It is unclear what action should be taken if either of the two specified limits (Yearly average temperature < 70F or average daily ambient temperature < 100F) is exceeded.
j i
Docket Number 50-346 License Number NPF-3 Serial Number 2246 Attachment Page 2 Page A-27, first paragraph The first paragraph states that the postulated adiabatic heatup would result in concrete temperatures being exceeded in approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.
As a result, it is appropriate and conservative to perform the visual surveillance to verify no vent blockage on a daily basis to ensure that a blockage has not existed for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. The last sentence in the first paragraph should reflect that the module needs to be removed from service if it cannot be established that the blockage is less than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, not 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance interval vill adequately verify this.
Page A-28 Section 1.3 indicates that a module must be removed from service if a vent blockage is in existence for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Surveillance 1.3.2 indicates that a module must be removed from service if the concrete accident temperature criteria has been exceeded for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. A vent blockage for less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> vould not cause the temperature limit to be exceeded, as explained in Section 1.3 and the objective for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> frequency required by Surveillance 1.3.1.
The apparent conflict between Section 1.3 and the action for Surveillance Requirement 1.3.2 needs to be resolved.
It appears that the Surveillance Requirement 1.3.2 Actions are appropriate.
l l
l l
1 l
t