ML20128L905

Forwards Requests for Exemption from Requirements of 10CFR70.24(a) Re Criticality Accident Requirements & Justification for Exemption

ML20128L905
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/16/1993
From:	Machon R PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9302220041
Download: ML20128L905 (3)

Text

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i um amm-3 y am Portland General Electric Company l B "

! James E. Cross Vice President and Chief Nuclear Officer l

February 16, 1993 Trojan Nuclear Plant Docket 50-344 l License NPF-1 I U.S. Nuclear Regulatory Commission

] Attn Document Control Desk j Washington DC 20555

Dear Sirs:

! Requests for Exemption from the Requirements of i Title 10 of the Code-of Federal Regulations, Part 70.24(a) j fl0 CFR 7JL2f fA)1 Criticality AcciflenLARfluir.emeRLs t

' Portland General Electric Company (PGE) has permanently ceased operation of the Trojan Nuclear Plant. The reactor has been defueled and an application for a Possession Only Facility Operating-License-has been submitted to the

Nuclear Regulatory Commission (NRC) for review and approval. By this

letter, PGE is seeking to obtain exemption from the requirements of i 10 CFR 70.24(a) in accordance with 10 CFR 50.12. The attachment to this 1etter contains the request and supporting justification for this exemption.

{

Sincerely, R h j for J. E. Cross i

i Attachment j

i c: Mr. John B. Martin Regional Administrator, Region V  !

U.S. Nuclear Regulatory Commission I Mr. David Stewart-Smith-State of Oregon:

j Department of Energy _

i

! Mr. Kenneth Johnston i NRC Senior Resident Inspector Trojan Nuclear Plant 9302220041 930216 f PDR ADOCK-05000344 i P PDR ,

l i 1 121 SW Salmon Street, Portland, OR 97204 I l 503/464-8897- i

Trojan Nuclear Plant Document Control Desk Docket 50-344 February 16 1993 License NPF-1 Attachment Page 1 of 2 REQUEST FOR EXEMPTION FROM THE REQUIREMENTS OF TITLE 10 TO THE CODE OF FEDERAL REGULATIONS, KZ0l4_(10 CFR 70 2AL_CRIllCALIILAC.CIDMLEQUIREMIS

f. Ken 1pAlon_ Request 10 CFR 70.24(a) requires licensees, who are authorized to possess certain quantities of Special Nuclear Materials, to maintain a monitoring system to detect a criticality in areas where the material is used, handled, or stored. This section also requires licensees to maintain emergency procedures and conduct evacuation drills for each area where Special Nuclear Material is used, handled, or stored. 10 CFR 70.24(b) requires these licensees to provide a means for identifying quickly individuals receiving doses of 10 rads or more. This section also requires maintenance of facilities, equipment and services necessary to treat radiation emergencies. 10 CFR 70.24(c) exempts holders of licenses for the operation of nuclear power reactors from the requirements of 10 CFR 70.24(b) for fuel used or to be used in the reactor.

10 CFR 70.24(d) states that a licensee may apply for an exemption from the requirements of 10 CFR 70.24 if good cause exists. Portland General Electric Company (PGE) believes good cause exists, and in accordance with the provisions of 10 CFR 50.12, requests specific exemption from the requir, ents of 10 CFR 70.24(a). Such an exemption would not present an undue risk to the public health and safety and is consistent with the common defense and security.

Backstaund PGE has permanently ceased operation of the Trojan Nuclear Plant. The reactor has been defueled and the irradiated fuel assemblies which were used during reactor operation are stored in the spent fuel pool.

The Spent Fuel Pool storage racks at Trojan are high density racks that use fixed spacing and a neutron absorber to maintain the fuel assemblies in a sub-critical array. The racks are designed to maintain the effective neutron multiplication factor (k gg)e for stored fuel assemblies less than 0.95 under both normal and abnormal conditions, as detailed in PGE Topical Report PGE-1037, Spent Fuel Storage Rack Replacement Report and the Nuclear Regulatory Commission (NRC) Safety Evaluation Report dated June 8, 1984.

The analyses were performed using a maximum fuel enrichment of 4.5 weight percent U-235. The analyses demonstrated a 95 percent probability, with a 95 percent confidence level that K egg of the stored fuel will remain less than 0.95, even if the spent fuel pool is filled with unborated water. The analyses included statistical variations in reactivity due to eccentrically positioned fuel assemblies, dimensional variations permitted by fabrication tolerances and variations in the neutron absorber material.

Jrojan Nuclear Plant Document Control Desk

• Docket 50-344 February 16 1993 License NPF-1 Attachment Page 2 of 2 Abnormal and accident conditions were also considered. These considerations included variation in water temperature due to loss of normal cooling with water temperature up to 212'F et the surf ace (260'F maximum), a single fuel assembly lying across the top of loaded racks and a dropped fuel assembly. None of these abnormal conditions resulted in exceeding a neutron multiplication factor of 0.95 with uncertainties and biases included.

In support of the permanent cessation of operation of the Trojan Nuclear Plant, PGE developed and submitted a Certified Fuel Handler program report to the NRC for approval. The report describes PGE's program for the certification of personnel that supervise or perform duties necessary to ensure the handling, storage, and cooling of nuclear fuel is done in a manner consistent with the health and safety of the public. This program includes personnel training in radiological safety principles and monitoring, as well as Plant administrative and safety procedures. Fuel handling activities will be conducted in accordance with administrative procedures. These procedures include limits and precautions for handling fuel assemblies and instructions for actions to take in the event of a fuel handling accident.

The design of the storage racks, combined with procedural controls over fuel handling activities and Certified Fuel Handler training provide adequate assurance against the occurrence of an accidental criticality.

Therefore, implementation of the requirements of 10 CFR 70.24(a) is not necessary to meet the underlying purpose of the rule, preventing personnel exposure due to an accidental criticality event in the Spent Fuel Pool. PGE also believes that since adequate assurance against an accidental criticality is provided, the exemption from Section 70.24(b) provided by 10 CFR 70.24(c) is still applicable to Trojan.

Specific exemption to the requirements of 10 CFR 70.24 was issued with the original Trojan Special Nuclear Materials License (SNM-1542).

However, this exemption is not currently reflected in the Trojan Facility Operating License (NPF-1).

Entential Environmental Impact Pursuant to the provisions of 10 CFR 50.12, PGE is requesting exemption to the requirements of 10 CFR 70.24(a). The proposed exemption is administrative in nature. As such, the exemption will not result in a change in type or quantity of radioactive or non-radioactive effluents, an increase in the licensed power level or Plant configuration.

Therefore, the proposed exemption will not have a significant impact upon the environment.

EWF/bsh 7431W.0293