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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217E9711999-10-13013 October 1999 Submits Notification of Major Changes to Trojan Liquid Radioactive Waste Treatment Sys,Iaw PGE-1201.Detailed Description of Change Provided ML20217C8171999-10-0606 October 1999 Forwards Notice of Receipt of Availability for Comment & Meeting to Discuss License Termination Plan,Per 990805 Application ML20216F7621999-09-23023 September 1999 Forwards Corrected Response to Request 2 Contained in NRC 990920 RAI Re Application of Pacificorp for Transfer of License NPF-1.Response 2 Should Have Stated That Na General Partnership Is Partnership Formed in Nv ML20216F2871999-09-20020 September 1999 Informs NRC of Developments That Have Occurred Since 990524 Application Was Filed Re Pacificorp Transfer of License of FOL NPF-1.NRC Is Urged to Act & Approve Transaction Expeditiously by 990930.Supporting Documentation Encl ML20211Q3281999-09-0909 September 1999 Forwards Insp Rept 50-344/99-06 on 990630-0701,21 & 0408-08. No Violations Noted.Insp Conducted to Review Decommissioning Activities Underway at Trojan Site & to Accompany Shipment of Reactor Vessel to Hanford,Washington for Burial ML20211J2101999-08-30030 August 1999 Forwards Request for Addl Info Re Application for Approval of Proposed Corporate Merger of Pacificorp & Scottishpower ML20211B6611999-08-16016 August 1999 Forwards fitness-for-duty Program Performance Data Rept for Period of 990101-0630,IAW 10CFR26.71(d) ML20211B4091999-08-16016 August 1999 Forwards Environ Assessment & Finding No Significant Impact to Application for an Exemption & License Amend Dated 980129.Proposed Exemption & License Amend Would Delete Security Plan Requirements of 10CFR50.54(p) & 10CFR73.55 ML20211A7131999-08-16016 August 1999 Forwards Environ Assessment & Finding of No Significant Impact to Application for Exemption & License Amend Dtd 980827.Proposed Exemption & License Amend Would Delete EP Requirements of 10CFR50.54(q),10CFR50.47(b) & 10CFR50,app E ML20210R7691999-08-11011 August 1999 Forwards Proposed Rev 23 to PGE-8010, Trojan Nuclear QAP, in Response to NRC 990708 RAI Re Relocation of TS ACs to Qap.Revised QAP Will Be Made Effective Concurrently with Implementation of License Change Application Lca 245 ML20210H5971999-07-27027 July 1999 Forwards Notice of Consideration of Approval of Application Re Merger & Opportunity for Hearing.Notice Being Forwarded to Ofc of Fr for Publication ML20216D6611999-07-23023 July 1999 Submits Summary of Proprietary Submittals for Transtor Part 71 & Part 72 & Trojan ISFSI Applications ML20210F8601999-07-22022 July 1999 Forwards Rev 1 to PGE-1076, Trojan Reactor Vessel Package Sar. Changes to Rept Contained in Rev 1 Received NRC Approval by Ltr ML20210A6401999-07-19019 July 1999 Corrects Ref in Item 4 of Which Constitutes Rev 2 of Authorization from Wf Kane, for Trojan Reactor Vessel Package as Approved Package for Shipment Under General License,Subj to Listed Conditions ML20210B4481999-07-12012 July 1999 Forwards Rept Describing Effects of Earthquake That Occurred on 990702 Near Satsop,Wa,Iaw Trojan Nuclear Plant Defueled Sar,Section 4.1.3.1 ML20209D6231999-07-0808 July 1999 Forwards RAI Re Licensee 980827 Request for Amend That Would Delete Number of License Conditions & TS Requirements That Would Be Implemented After All Sf Has Been Removed from 10CFR50 Licensed Area.Response Requested within 30 Days ML20209C6481999-07-0606 July 1999 Forwards Rev 8 to Defueled Sar,Including Changes Since Last Submittal.Attachment Includes Brief Description of Each Change Included in Rev ML20209B7821999-07-0101 July 1999 Responds to NRC 990609 RAI Re License Change Application 244 & Accompanying Request for Exemption.Detailed Info Supports Estimation of Remaining Radioactive Matl Previously Provided by Licensee ML20212J3281999-06-15015 June 1999 Forwards Amend 22 to PGE-1012, Trojan Nuclear Plant Fire Protection Plan, IAW 10CFR50.48(f).Amend Reflects Revs Made During Decommissioning Activities & Does Not Reduce Effectiveness of Fire Protection ML20195J0111999-06-0909 June 1999 Responds to Requesting License & Exemption Re Emergency Preparedness ML20207D3861999-06-0101 June 1999 Forwards Rev 1 to PGE-1077, Trojan Nuclear Plant Reactor Vessel & Internals Removal Project Transportation Safety Plan ML20196L1251999-05-24024 May 1999 Forwards Application for Amend to License NPF-1 for Indirect Transfer of License,To Extent That Such Approval Required Solely to Reflect Change in Upstream Economic Ownership of Pacificorp ML20207A2751999-05-14014 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization, Division of Licensing Project Mgt Created.Organization Chart Encl ML20206N9411999-05-11011 May 1999 Forwards Revised Epips,Including Rev 7 to EPIP 3, Response Organization Checklists & Rev 9 to EPIP 5, Emergency Preparedness Test Propgram. Changes to EPIPs 3 & 5 Ref New Owners of on-site Railroad Line,Portland & Western Railroad ML20206J8681999-05-0707 May 1999 Forwards Insp Repts 50-344/99-05 & 72-0017/99-04 on 990419-22.No Violations Noted.Insp Observed Work Activities Associated with Lifting of Reactor Vessel in Preparation for Removal & Shipment to Hanford Reservation for Burial ML20206J7931999-05-0707 May 1999 Forwards Insp Repts 50-344/99-04 & 72-0017/99-02 on 990322- 25 & 29-0408.One Violations Identified & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy ML20206H4331999-05-0505 May 1999 Forwards Amend 201 to License NPF-1 & Se.Amend Revises PDTSs by Deleting ISFSI Area,Revises Subsection 4.1.1,replaces Figure 4.1-1 with New Figure 4.1-1 & Adds New Page to Figure 4.1-1 to Reflect Access Control (ISFSI) Area ML20206N1571999-05-0404 May 1999 Forwards Util Quarterly Decommissioning Status Rept for First Quarter of 1999,IAW State of or Energy Facility Siting Council Order Approving Trojan Decommissioning Plan, ML20206E1731999-04-29029 April 1999 Informs That NRC Staff Has Performed an Acceptance Review of Trojan Nuclear Plant License Termination Plan,Submitted by ,To Determine Whether LTP Provides Adequate Info to Allow Staff to Conduct Detailed Review ML20206E0211999-04-28028 April 1999 Forwards Copy of Environ Assessment & Finding of No Significant Impact Re 970212 Application for Amend.Proposed Amend Would Revise Trojan Permanently Defueled TS to Delete ISFSI Area ML20206C9591999-04-23023 April 1999 Forwards Amend 200 to License NPF-1 & Safety Evaluation. Amend Changes License NPF-1 by Revising License Condition 2.C.(10), Loading of Fuel Into Casks in Fuel Building ML20206C9221999-04-23023 April 1999 Forwards Amend 199 to License NPF-1 & Safety Evaluation. Amend Changes License NPF-1 by Adding New License Condition Entitled, Loading of Fuel Into Casks in Fuel Building ML20205S9761999-04-21021 April 1999 Forwards Trojan Nuclear Plant,Radiological Environ Monitoring Rept for CY98. Rept Submitted in Accordance with Trojan Permanently Defueled TS 5.8.1.2 & Sections IV.B.2, IV.B.3 & Iv.C of App I to Title 10CFR50 ML20205T5471999-04-20020 April 1999 Forwards Insp Repts 50-344/99-03 & 72-0017/99-03 on 990301-04,15-18 & 22-25.No Violations Noted ML20205N9061999-04-13013 April 1999 Forwards Insp Rept 50-344/99-02 on 990329-0401.No Violations Noted.Inspectors Examined Portions of Physical Security, Access Authorization & FFD Programs ML20205P7301999-04-0808 April 1999 Forwards PGE-1009-98, Operational Ecological Monitoring Program for TNP,Jan-Dec 1998, Including All Existing non-radiological Effluents ML20205B3661999-03-25025 March 1999 Transmits Completed Application for Renewal of NPDES Permit for Trojan Nuclear Plant,Iaw License NPF-1,App B,Epp,Section 3.2 ML20204G1781999-03-18018 March 1999 Forwards Rev 4 to PGE-1063, Suppl to Applicants Environ Rept - Post Operating License Stage ML20204B7551999-03-18018 March 1999 Forwards Updated TS 5.6 Re High Radiation Area,Per Telcons with Nrc.Justification for TS Was Provided Previously with Util Ltr Dtd 990317,but Has Been Updated & Is Included as Encl 2 ML20204C5151999-03-17017 March 1999 Forwards Licensee Comments on NRC Preliminary SER & License Re Trojan Isfsi.Encl Includes Justification for Inclusion in ISFSI TS of Alternative Method to 10CFR20.1601(c) for Controlling Access to High Radiation Areas ML20207J3721999-03-10010 March 1999 Forwards License Amend Application 247 Requesting Amend to License NPF-1 to Add License Condition Denoting NRC Approval of PGE-1078, Trojan Nuclear Plant License Termination Plan, Also Encl.With Certificate of Svc ML20207L0011999-03-0808 March 1999 Transmits Tnp co-owners Annual Rept of Status of Decommissioning Funding for Tnp.Rept Is Based on Most Recent Analysis of Tnp Decommissioning Estimate & Funding Plan,Per Rev 6 to Pge, Tnp Decommissioning Plan ML20207G9691999-03-0303 March 1999 Forwards Rev 6 to PGE-1061, Trojan Nuclear Plant Decommissioning Plan. Summary of Changes,Attached.Revised Portions Denoted by Side Bars ML20207D7751999-03-0202 March 1999 Forwards Amend 21 to PGE-1012, Trojan Nuclear Plant Fire Protection Plan, Per 10CFR50.48(f).Amend Reflects Revs Made During Decommissioning Activities ML20207B0441999-02-24024 February 1999 Forwards Endorsements 139 to Nelia Policy NF-0225 & 2 to Nelia Policy NW-0602 ML20207J0701999-02-11011 February 1999 Forwards Proposed Ts,Update to ISFSI SAR & Revised Calculation,Per Application for Trojan ISFSI License ML20202G4291999-02-0202 February 1999 Forwards Rev 0 to PGE-1076, Trojan Reactor Vessel Package Sar. Approval,With Certain Conditions,For one-time Shipment of Trojan Reactor Vessel Package Granted by Commission Via Ltr ML20202G0931999-01-26026 January 1999 Submits Following Info That Will Be Needed for NRC Staff to Complete Review & Issue Trojan ISFSI License,As Result of 990121 Meeting with NRC Following Insp & Observation of ISFSI Preoperational Testing During Wk of 990118 ML20202F2551999-01-25025 January 1999 Forwards Fitness for Duty Program Performance Data Rept for July-Dec 1998 ML20202C1621999-01-21021 January 1999 Forwards Insp Repts 50-344/98-04 & 72-0017/98-01 & NOV Re Inadequate Actions Taken by Radiation Protection Technician to Ensure That Radiological Conditions Safe Prior to Removing Warning Signs for Airborne Radioactivity Area 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217E9711999-10-13013 October 1999 Submits Notification of Major Changes to Trojan Liquid Radioactive Waste Treatment Sys,Iaw PGE-1201.Detailed Description of Change Provided ML20216F7621999-09-23023 September 1999 Forwards Corrected Response to Request 2 Contained in NRC 990920 RAI Re Application of Pacificorp for Transfer of License NPF-1.Response 2 Should Have Stated That Na General Partnership Is Partnership Formed in Nv ML20216F2871999-09-20020 September 1999 Informs NRC of Developments That Have Occurred Since 990524 Application Was Filed Re Pacificorp Transfer of License of FOL NPF-1.NRC Is Urged to Act & Approve Transaction Expeditiously by 990930.Supporting Documentation Encl ML20211B6611999-08-16016 August 1999 Forwards fitness-for-duty Program Performance Data Rept for Period of 990101-0630,IAW 10CFR26.71(d) ML20210R7691999-08-11011 August 1999 Forwards Proposed Rev 23 to PGE-8010, Trojan Nuclear QAP, in Response to NRC 990708 RAI Re Relocation of TS ACs to Qap.Revised QAP Will Be Made Effective Concurrently with Implementation of License Change Application Lca 245 ML20216D6611999-07-23023 July 1999 Submits Summary of Proprietary Submittals for Transtor Part 71 & Part 72 & Trojan ISFSI Applications ML20210F8601999-07-22022 July 1999 Forwards Rev 1 to PGE-1076, Trojan Reactor Vessel Package Sar. Changes to Rept Contained in Rev 1 Received NRC Approval by Ltr ML20210B4481999-07-12012 July 1999 Forwards Rept Describing Effects of Earthquake That Occurred on 990702 Near Satsop,Wa,Iaw Trojan Nuclear Plant Defueled Sar,Section 4.1.3.1 ML20209C6481999-07-0606 July 1999 Forwards Rev 8 to Defueled Sar,Including Changes Since Last Submittal.Attachment Includes Brief Description of Each Change Included in Rev ML20209B7821999-07-0101 July 1999 Responds to NRC 990609 RAI Re License Change Application 244 & Accompanying Request for Exemption.Detailed Info Supports Estimation of Remaining Radioactive Matl Previously Provided by Licensee ML20212J3281999-06-15015 June 1999 Forwards Amend 22 to PGE-1012, Trojan Nuclear Plant Fire Protection Plan, IAW 10CFR50.48(f).Amend Reflects Revs Made During Decommissioning Activities & Does Not Reduce Effectiveness of Fire Protection ML20207D3861999-06-0101 June 1999 Forwards Rev 1 to PGE-1077, Trojan Nuclear Plant Reactor Vessel & Internals Removal Project Transportation Safety Plan ML20196L1251999-05-24024 May 1999 Forwards Application for Amend to License NPF-1 for Indirect Transfer of License,To Extent That Such Approval Required Solely to Reflect Change in Upstream Economic Ownership of Pacificorp ML20206N9411999-05-11011 May 1999 Forwards Revised Epips,Including Rev 7 to EPIP 3, Response Organization Checklists & Rev 9 to EPIP 5, Emergency Preparedness Test Propgram. Changes to EPIPs 3 & 5 Ref New Owners of on-site Railroad Line,Portland & Western Railroad ML20205S9761999-04-21021 April 1999 Forwards Trojan Nuclear Plant,Radiological Environ Monitoring Rept for CY98. Rept Submitted in Accordance with Trojan Permanently Defueled TS 5.8.1.2 & Sections IV.B.2, IV.B.3 & Iv.C of App I to Title 10CFR50 ML20205P7301999-04-0808 April 1999 Forwards PGE-1009-98, Operational Ecological Monitoring Program for TNP,Jan-Dec 1998, Including All Existing non-radiological Effluents ML20205B3661999-03-25025 March 1999 Transmits Completed Application for Renewal of NPDES Permit for Trojan Nuclear Plant,Iaw License NPF-1,App B,Epp,Section 3.2 ML20204G1781999-03-18018 March 1999 Forwards Rev 4 to PGE-1063, Suppl to Applicants Environ Rept - Post Operating License Stage ML20204B7551999-03-18018 March 1999 Forwards Updated TS 5.6 Re High Radiation Area,Per Telcons with Nrc.Justification for TS Was Provided Previously with Util Ltr Dtd 990317,but Has Been Updated & Is Included as Encl 2 ML20204C5151999-03-17017 March 1999 Forwards Licensee Comments on NRC Preliminary SER & License Re Trojan Isfsi.Encl Includes Justification for Inclusion in ISFSI TS of Alternative Method to 10CFR20.1601(c) for Controlling Access to High Radiation Areas ML20207J3721999-03-10010 March 1999 Forwards License Amend Application 247 Requesting Amend to License NPF-1 to Add License Condition Denoting NRC Approval of PGE-1078, Trojan Nuclear Plant License Termination Plan, Also Encl.With Certificate of Svc ML20207L0011999-03-0808 March 1999 Transmits Tnp co-owners Annual Rept of Status of Decommissioning Funding for Tnp.Rept Is Based on Most Recent Analysis of Tnp Decommissioning Estimate & Funding Plan,Per Rev 6 to Pge, Tnp Decommissioning Plan ML20207G9691999-03-0303 March 1999 Forwards Rev 6 to PGE-1061, Trojan Nuclear Plant Decommissioning Plan. Summary of Changes,Attached.Revised Portions Denoted by Side Bars ML20207D7751999-03-0202 March 1999 Forwards Amend 21 to PGE-1012, Trojan Nuclear Plant Fire Protection Plan, Per 10CFR50.48(f).Amend Reflects Revs Made During Decommissioning Activities ML20207B0441999-02-24024 February 1999 Forwards Endorsements 139 to Nelia Policy NF-0225 & 2 to Nelia Policy NW-0602 ML20207J0701999-02-11011 February 1999 Forwards Proposed Ts,Update to ISFSI SAR & Revised Calculation,Per Application for Trojan ISFSI License ML20202G4291999-02-0202 February 1999 Forwards Rev 0 to PGE-1076, Trojan Reactor Vessel Package Sar. Approval,With Certain Conditions,For one-time Shipment of Trojan Reactor Vessel Package Granted by Commission Via Ltr ML20202G0931999-01-26026 January 1999 Submits Following Info That Will Be Needed for NRC Staff to Complete Review & Issue Trojan ISFSI License,As Result of 990121 Meeting with NRC Following Insp & Observation of ISFSI Preoperational Testing During Wk of 990118 ML20202F2551999-01-25025 January 1999 Forwards Fitness for Duty Program Performance Data Rept for July-Dec 1998 ML20199J1661999-01-14014 January 1999 Submits Summary of ISFSI Lid Welding Demonstration to Be Held 990118-25.Dates & Days Are Tentative & Can Be Adjusted as Necesssary or as Required ML20199J0801999-01-12012 January 1999 Forwards Schedule for Trojan Nuclear Plant ISFSI pre-op Test,Per Request ML20206Q0121999-01-0808 January 1999 Forwards Rev 1 to PGE-1073 Tnp ISFSI Security Plan,As Result of 981208 Telcon with Nrc.Encl Withheld,Per 10CFR73.21 ML20206P5991999-01-0404 January 1999 Requests That Svc List for Delivery of Documents from NRC Be Updated,Per 981230 Telcon.Substitute for Listings of HR Pate & J Westvold,Submitted ML20198T1651999-01-0404 January 1999 Forwards Rev 5 to PGE-1061, Trojan Nuclear Plant Decommissioning Plan. Table 2.2-5 Is Revised to Depict Major Components Removed from Plant During 1998.Revs Are Denoted by Side Bars ML20198E3981998-12-17017 December 1998 Forwards Updated ISFSI Emergency Plan,Per 981123 & Discussion in Meeting with NRC on 981119.Description of Changes Encl ML20196E2851998-11-25025 November 1998 Forwards Final Rept of Matl Properties of Neutron Shielding Matl to Be Used in Trojan ISFSI & Test Repts That Verified Matl Properties ML20196D9831998-11-24024 November 1998 Forwards Listed ISFSI Calculation Refs,Per 981110 Telcon ML20196B2321998-11-23023 November 1998 Informs That,Per Commitments Made in 981119 Meeting with Nrc,Rev to PGE-1075 Will Be Submitted No Later than 981218 ML20195J2321998-11-17017 November 1998 Forwards Rev 7 to Trojan Nuclear Plant Defueled Sar. Attachment to Ltr Includes Brief Description of Each Change Included in Rev ML20195E4811998-11-10010 November 1998 Forwards Rev 51 to Trojan Nuclear Plant Security Plan.Rev Withheld,Per 10CFR73.21 ML20155E0331998-10-27027 October 1998 Forwards Amend 7 to PGE-1052, Quality-Related List Classification for Tnp. Amend Removes Ref to Several Clean Up Sys,Deletes Exemptions Allowed by Reg Guide 1.143 & Deletes Figures No Longer Required to Support Discussion ML20154M4151998-10-14014 October 1998 Requests That Further Review of License Change Application LCA-238 Be Suspended as Result of Progress Made in Decommissioning,Installation of Natural Gas Pipe Line ML20154A4751998-09-28028 September 1998 Forwards Amend 20 to PGE-1012, Trojan Nuclear Plant Fire Protection Plan, Reflecting Revisions to Fire Protection Program Made During Decommissioning Activities ML20153D3021998-09-21021 September 1998 Forwards Rev 0 to PGE-1077, Tnp Reactor Vessel & Internals Removal Project Transportation Safety Plan, Per Request That Util Submit Description of Measures to Be Taken to Ensure Safe Transport of Tnp Rv & Internals Package ML20151X8571998-09-10010 September 1998 Provides Rev 2 to Poge, Trojan NPP Permanently Defueled TS Bases. Changes Identified in Revised Text by Side Bars ML20151X7171998-09-10010 September 1998 Forwards Rev 3 to PGE-1063, Trojan Nuclear Power Station, Suppl to Applicant Environ Rept. Section 4.5 Revised to Delete Ref to Selected Room Coolers ML20153B0001998-09-0909 September 1998 Forwards Figures & Tables Identifying Nodes Assigned for Trojan ISFSI Transfer Station Analysis,TI-056,Rev 1 ML20237E9421998-08-27027 August 1998 Requests Exemption of Emergency Plan Requirements of 10CFR50.54(q),10CFR50.47(b) & 10CFR50,App E Following Transfer of Spent Nuclear Fuel to ISFSI ML20151W5381998-08-25025 August 1998 Forwards Rev 22 to PGE-8010, Poge Nuclear QA Program for Trojan Nuclear Plant. Rev Reflects Administrative Changes That Continue to Meet Requirements of 10CFR50,App B ML20237E1811998-08-25025 August 1998 Forwards Description of Review Methodology & Summary of Results,Including List of Identified Variations from Guidance Contained in Std Review Plan,Per NUREG-1536 1999-09-23
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M M M WW Stephen M. Quennoz Trojan Site Executive March 20,1997 VPN-023-97 Trojan ISFSI Docket 72-017 Mr. Donald A. Cool Director, Division ofIndustrial and Medical Nuclear Safety Office ofNuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, DC 20555 Mr. William F. Kane Director, Spent Fuel Projects Office Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Sir:
Reauest for Exemption from the Reauirements of 10 CFR 72.124(b)
This letter requests an exemption from certain requirements of 10 CFR 72 in accordance with the provisions of Section 72.7, " Specific exemptions." Section 72.7 authorizes the NRC to grant exemptions from the requirements of 10 CFR 72 if such exemptions are authorized by law, will not endanger life or property or the common defense and security and is otherwise in the public interest.
PGE is requesting an exemption from a provision of paragraph 72.124(b), " Methods of criticality control," requiring that the design of an ISFSI include a positive means of vedfying the continued efficacy of solid neutron absorbing materials used for criticality control. As described in the attached request for exemption (Attachment I), the Trojan ISFSI does include the use of solid neutron absorbing material. However, this neutron absorbing material is not credited or relied upon to preclude criticality during the storage of spent fuel at the Trojan ISFSI. Since the neutron absorbing material is not relied upon for criticality control during storage of the spent fuel and the sealed nature of the storage system design precludes direct monitoring or inspection of the material, PGE is requesting an exemption from this requirement. More detail concerning the basis for this request is contained in Attachment I. This request is being submitted as an l f!?Olr ii 9703270319 970320 4 DR ADOCK 0500 gg 71760 Columbia River Highway, Rainier, OR 97048 503/556-3713
VPN-023-97 March 20,1997 Page 2 of 2 i
amendment to PGE's previously submitted application for an ISFSI license (PGE letter VPN-012-96 dated March 26,1996).
1
, If you have any questions regarding this information, please contact Ray Pate, Licensing, at (503) 556-7480.
1.
Sincerely, i
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! Stephen M. Quennoz Trojan Site Executive Attachment c: NRC Document Control Desk
! M. T. Masnik, NRC, NRR D. G. Reid, NRC, NMSS R. A. Scarano, NRC Region IV David Stewart-Smith, ODOE 1
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STATE OF OREGON )
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COUNTY OF COLUMBIA ) f
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I, Stephen M. Quennoz, being duly sworn, subscribe to and say that I am the Trojan Site I Executive for Portland General Electric Company, the applicant herein; that I have full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, i information, and belief the statements made in it are true. !
l Date # ## _,1997 i
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, @ % > % c:ih n = = Q j Stephen M. Quennoz U Trojan Site Executive Portland General Electric Company On this day personally appeared before me Stephen M. Quennoz, to me known to be the I individual who executed the foregoing instrument, and acknowledged that he signed the same as his free act.
GIVEN under my hand and seal this 20 day of NOfdl ,1997.
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,, Notary Public in ankor the State of Oregon 9 angERLEYA.LINMg NOTARY PUBUCN ur coMMESDN EH E 997 Residing at blthtI1UL00tu314 My commission expires lo - / - 4'7 "
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i Attachment I Request for Exemption from the Requirements of l 10 CFR 72.124(b)," Methods of criticality control" I
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Attachment I to VPN-023-97 i March 20,1997 Eane1of4 Request for Exemption Background Information By letter dated March 26,1996 (PGE letter VPN-012-96) PGE submitted an application for a specific license for an independent spent fuel storage installation (ISFSI) to be constructed at the existing site of the Trojan Nuclear Plant. The license application included a safety analysis report for the Trojan ISFSI which describes the proposed ISFSI design. As described in the SAR, the Trojan ISFSI will use the Sierra Nuclear Corporation (SNC) TranStor design for spent fuel 1 storage. This is a vertical cask, dry storage system. Spent fuel assemblies are contained in sealed metal baskets (PWR baskets) which are in turn housed in cylindrical concrete casks. Up to
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twenty-four spent fuel assemblies may be stored in each basket. The system is designed to allow !
the transfer of the sealed PWR baskets from the storage casks to approved shipping containers for subsequent transport of the spent fuel to a final repository or interim storage facility without the need to reopen the PWR baskets or directly manipulate spent fuel assemblies.
Specific Exemption Requested The specific regulatory requirement from which PGE seeks exemption is contained in 10 CFR 72.124(b), " Methods of criticality control." This paragraph is repeated below.
(c) Methods ofcriticality control. When practicable the design of an ISFSI or MRS must be based on favorable geometry, permanently fixed neutron absorbing materials (poisons), or both.
Where solid neutron absorbing materials are used, the design shall provide for positive means to verify their continued efficacy.
PGE seeks an exemption from the second sentence of this paragraph which requires the design of an ISFSI to provide for a positive means of verifying the continued efficacy of neutron absorbing materials.
Bases for Exemption Request In accordance with regulations, the storage system is designed to ensure that the spent fuel assemblies remain in a subcritical configuration throughout the storage period. As noted in Section 3.3.4.1, " Control Methods for Prevention of Criticality," of the Trojan ISFSI SAR, the TranStor storage system relies solely on the geometiy of the spent fuel assemblies i . the PWR basket to maintain the required subcritical conditions during storage. PGE submitted the
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Attachment I to VPN-023-97
- ! - March 20,1997 Pane 2 of 4 supporting criticality calculation (PGE01-10.02-01, Revision 0) in response to NRC's request for 1 additional information dated November 25,1996 (PGE letter VPN-085-96 dated December 23, 1 1996). As shown in this calculation, the geometry of the dry storage configuration alone !
maintains a large margin to criticality (a k,, ofless than 0.41, even accounting for uncertainty and
- computer code bias).
l The TranStor* PWR basket does incorporate solid neutron absorbing material in its design.
However, the neutron absorbing material is not necessary to maintain subcritical conditions during ,
storage and is not credited in the calculations supporting subcriticality during spent fuel storage at I the Trojan ISFSI.
l
, The solid neutron absorbing material, along with the spent fuel, will be sealed inside the PWR' baskets. The PWR baskets are welded closed following initial loading of spent fuel. The design i j of the TranStor system provides for the ultimate transfer of these sealed baskets from the f
- concrete storage casks to approved transportation containers. Once the spent fuel is loaded into
- the PWR basket and the basket lid is welded in place, the basket remains sealed throughout the ,
storage period at the Trojan ISFSI, the transfer to the shipping container, and shipment to the final repository location. This design helps to minimize the radiation exposure to workers that
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t would result from repeated direct handling of spent fuel assemblies. The sealed basket design, i however, a'so precludes any direct monitoring or inspection of the solid neutron absorbing materialinside the PWR basket. I I
Following completion of the storage period at the Trojan ISFSI, the loaded PWR baskets will eventually be transferred to a shipping container and moved to a permanent repository or interim storage facility. The shipping container will be licensed under the provisions of 10 CFR 71,
" Packaging and Transportation of Radioactive Material." 10 CFR 71 requires the evaluation of potential transportation accident conditions including the immersion of the shipping cask in water and the intrusion of water into the PWR basket. Criticality calculations performed to support such potential transportation accident conditions consider the effects of the neutron poison materials in the PWR basket. PGE submitted this calculation, PGE01-10.02.02-03, Revision 0, to the NRC by letter dated March 10,1997 (VPN-017-97 dated March 10,1997). PGE referenced this calculation on the Trojan ISFSI docket in order to demonstrate appropriate margins to criticality during the initial loading of spent fuel into the PWR baskets in the Trojan fuel building. The initial PWR basket loading is performed under water. After the spent fuel is loaded into the PWR
- basket, the PWR basket is sealed and the water is evacuated prior to placing the PWR basket into a concrete cask.
The criticality calculation for a potential transportation accident is considered to conservatively bound the conditions that exist during loading of the PWR baskets based on the following factors: l
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c Attachment I to VPN-023-97
- March 20,1997 Pane 3 of 4 r
e The calculation usumes a fuel uranium enrichment of up to 4.2% wt.% U s The 23 i maximum enrichment of spent fuel to be stored in the Trojan ISFSI is 3.56%.
- e The calculation assumes fresh fuel. All of the spent fuel assemblies to be stored in the Trojan ISFSI have been exposed to varying degrees of burnup during operation of the
- Trojan Nuclear Plant.
e The calculation assumes pure water fills and surrounds the PWR basket. The spent fuel l
! loading operation at Trojan will be conducted with borated water of at least 2000 ppm ,
- boron.
Credit is taken for the neutron poison material incorporated in the PWR basket design only during i
- this initial loading of spent fuel into the PWR baskets. These conditions will exist only for a short time prior to the closure, evacuation, and vacuum' drying of PWR baskets and their subsequent
- placement into concrete casks for storage at the Trojan ISFSI. During the entire storage period, l the TranStor* storage system maintains subcritical conditions by relying solely on the favorable l geometry maintained by the PWR basket design. Since the neutron absorbing material is not l i'
relied upon to maintain subcritical conditions, the monitoring of the effects of this material for 1 potential degradation during the storage period would not serve to provide any additional
- assurance of subcritical conditions in the storage casks.
l As noted above, the neutron absorbing material will be relied upon in the licensing of the shipping
! container under the provisions of 10 CFR 71. Although 10 CFR 71 does not contain a requirement for positive means of verifying the efficacy of the solid neutron absorbing materials l similar to that contained in 10 CFR 72.124(b), there is adequate basis to conclude that the solid
- neutron absorbing material used in the TranStor system will perform adequately following the storage period at the Trojan ISFSI.
i As noted in reponse to Question 3-10 ofNRC's request for additional information dated l November 25,1996 (PGE letter VPN-085-96 dated December 23,1996), Boral was selected as
- the neutron absorbing plates in the TranStor basket internals because it maintains its material
- characteristics for the duration of storage and shipment. Boral plates are able to maintain their neutron absorption properties over a long period of time because of the large number of boron-10 27 i atoms present in the plates. The Boral plates in a PWR basket contain about 10 boron-10 atoms,
- which is several orders of magnitude larger than the 2 x 10" neutrons that would be emitted by a basket over a 40-year storage period. Therefore, the neutron absorption characteristics of the Boral would not be appreciably affected by a 40-year storage period. The maximum temperatures specified by the Boral vendor for the dry storage condition are 1000*F short term and 850*F long 1 term. The temperatures listed for normal operation and off-normal events in Trojan ISFSI SAR
- (Table 4.2-12) for fuel cladding are less than these temperatures (the fuel cladding would be at a
- higher temperature that the Boral plates). Therefore, the Boral will not experience significant
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Attachment I to VPN-023-97
] March 20,1997 j Pane 4 of 4 1
i e thermal degradation during the 40-year storage period. The Boral will also experience minimal -
corrosion while in the PWR basket's inert helium atmosphere. The low oxygen content and lack
- of an electrolyte (water) minimize potential corrosion. Based on these properties there is .
adequate evidence to ensure the efficacy of the Boral plates following 40 years of storage within j the ISFSI environment.
Conclusions l
i The solid neutron absorbing material incorporated into the design of the Trojan ISFSI is contained inside sealed PWR baskets and is not accessible for direct monitoring or inspection during the storage period. The desip" of the storage system does not rely on this material to maintain ;
- subcritical conditions duru s mrage of spent fuel at the Trojan ISFSI. During the storage period J j at the Trojan ISFSI, favorabic geometry alone will maintain the spent fuel in a subcritical
)
- condition by a large margin. Therefore, monitoring of the efficacy of the neutron absorbing l
} material during the storage period would not add to the assurance that the subcritical configuration described in the ISFSI SAR will be maintained during the storage period. The requested exemption would in no way endanger the health and safety of the public or be inimicable to the common defense and security.
Therefore, in accordance with 10 CFR 72.7, " Specific exemptions," PGE requests that an exemption from the requirement for monitoring of the continued efficacy of neutron absorbing
! material, contained in 10 CFR 72.124(b), be included in the Trojan ISFSI license, an application l for which is currently pending before the NRC.
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