ML20148A796

Discusses Oconee Nuclear Station Compliance w/10CFR70.24

ML20148A796
Person / Time
Site:	Oconee
Issue date:	02/13/1997
From:	Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML082490708	List: ML20148A587 ML20148A605 ML20148A644 ML20148A696 ML20148A713 ML20148A796
References
FOIA-97-99 NUDOCS 9705090144
Download: ML20148A796 (1)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION i,

j REGloN tt Oconee Nuclear Station n..a.m. orm.

,p February 13. 1997 MEMORANDUM TO:

Jon R. Johnson Director Division of Reactor Projects Mike Scott. Senior Resident inspector FROM:

Oconee Nuclear Station INSPECTION PLAN FOR COMPLIANCE WITH 10 CFR

SUBJECT:

(DRP ACTION ITEM No. 97-02)

Ocor,ee Nuclear Station was licensed for commercial operation in 10 CFR October 1973, and September 1974 for Units 1. 2. and 3 respectively.

70.24 was incorporated into the Code of Feceral Regulations on No The Oconee The facility does not comoly with the requirements in 10 CFR 70.24.

Nuclear Station recieves the new fuel and places it directly into the The requested There is no intermediate storage facility for the new fuel.

Pool.

exenption by Duke Power Company is attached.

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Mi h Det PoewCompany Seniorike hendent EQ Aarmg MeerGeneson owkes,NC 252014006 (SJMJ20008ee (D)NHJ50 Air DUM 90 WEN February 4, 1997 U. S. Nuclear Regulatory Co: omission Washington, D. C. 20555 Attention: Document Control Desk

Subject:

Oconee Nuclear Station Docket Numbers 50-269, -270, and ~267 McGuire Nuclear Station Docket Nu:nbers 50-369 and -370 Catawba Nuclear Station l

Decket Numbers 50-413 and -414 Request for Exemption From the Requirements of 10 CFR 70.24 l-Pursuant to 10 CFR 70.14 (a) and 70.24(d), Duke Power Company requests an exemption.to the requirements of 10 CFR'70.24, These regarding criticality accident monitoring.

requirements are considered to be unnecessary, because fuel storage rack design and Technical Specification requirements This exemption is are sufficient to preclude criticality.-

requested for each of Duke's three nuclear stations.

J Justification for this exemption. request is contained in the Attachment'.

If there are any questions regarding this request, please call Scott Gewehr at (704) 382-7581, Very trul

yours, X.3.n,c k d

M. 5. Tuckman 1

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SENT BY:0WE POWER 00NPANY

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Justification for Examption from the Requirements of 10 CFR 70.24, Criticality Accident Recuirements Requirements and Basis for Exemption 10 CFR 70.24 establishes requiraments for licensees to maintain in each area where special nuclear material is handled, used, or stored, a criticality monitoring system and emergency procedures, and document retention of current or superseded procedures.

Paragraphs 70.14 (a) and 70.24 (d) anticipate that relief from these requirements is appropriate in some circumstances.

A

' showing of good cause and the dettrmination that relief will not endanger life, property, or the common defense, and is otherwise in the public interest, may entitle a licensee to such relief.

For the reasons given below, Duke Power feels that compliance with the requirements of 70.24 is unnecessary, and hereby requests an exemption for Catawba, McGuire and Oconee Nuclear Stations.

Previous Exen tions Prior to the issuance of Facility Operating Licenses (FOLs) for Catawba and McGuire, each unit received special nuclear material (SRM) under licenses SNH-1920 (Catawba Unit 1),

SNM-1949 (Catawba Unit 2), SNM-1773 (McGuire Unit 1) and SNM-1885 (McGuire Unit 2). (The requirements regarding criticality monitoring contained in Section 70.24 came into being after Oconee began commercial operation.)

The SNM licenses contained explicit exemptions to the requirements o'r 10 crn 70.24.

These exemptions were based on analyses performed by Duke and the NRC staff, which concluded that

" reasonable and satisfactory precautions" existed to preclude a nuclear criticality accident. (

Reference:

NRC safety evaluation for revision to SNM-1920, dated January 16, 1994.)

These SMH licenses were terminated upon receipt of the respective units' FOLs; the exemptions were not

. transferred to the FOLs.

The administrative and Technical Specification controls on the storage of nuclear fuel remain in effect and continue to provide

• reasonable and satisfactory precautions" against a criticality accident.

The previous acceptability of this exemption in the SNM licenees forms the basis of this request to include this exemption in the FOLs at McGuire and Catawba; and, by logical extension, Oconee.

TOTAL P.02

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,r Nuclear Station tion Applicability to Oconeeand Technical SpecificaOconee Nuclear and of administrative of nuclear fuel atplace at utions" to McGuire controle comparable to those inand satisfactory precacontrols includ storage Le els on the v

stations' Technicalspacing of fue are l

These lies in Catawba; the "reasonab ecriticality accident.

Station which ictions with the eometricburnup/ enrichment restr fuel pool and avoid a example, compliance spentwhich are imposed Specifications, the gthe fuel storage area, fuel pla ment in the s

are govern spent controle These of Duke's nuclear stations.

ations.

exemption is administrativeupon fuel handling oper would also apply to an all threewhich indicates that Catawba common to some logic Guire and appropriate for Mc the Oconee.

M provides that therequirements Criteria to Justify an 70.14 (a)s from the 10 CFR determines areor property or The pertinent part ofmay

• grant such exemption

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-l Comr.issionregulations in this pard will not endanger life therwise in the authorized by authorized by law anand security and are oexamption isw of the whole or ocamon defense That such an7 0.24 (d), exemption "in public interest."

clear by Paragraph It has the of" Section 70.24the exemption an option to pursue law is made d by the NRC Staff thatd by the requirements acknowledges the or property, as e idenceSNM licenses in part from the v

already been determinewill not endanger li e exemption in previousoccurred at the f

and the Nothing has ted to be pre ious granting ofand Catawba.

inished the " reasonable" whi J

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stations which has dimsatisfactory precaut for McGuire l

l are at Oconee consistent in place to prevent a ill not controls in placeand Catawba, and prov ide a criticality accident w be Similarly, the and eeourity would not i

in an McGuire of confidence that a could not result of SNH; at those ocasmon defenseexemption or diversionrequested herein degree the d of the loss The increase in the likelihoowhich an exemption is endangered, because occur.

l is meet a requirements from re l

intended to detect or p t rest rces to Finally, the public in eof expenditures of reso the not clearly unnecessary a are diversion.

avoidance f

case by therequirement which is f

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' 10 CR.Ctk l 0-146 kSilor0 Age Y FR lirt, sept. 2.17t14 se emended at 27 of di arose shall be provided by two d*3

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4148. Mar.11.17tt: as FR 306e4, cosas. Not teotors.

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e.1 pts:3e FR esass. July is. 1994: 42 FR liles.

(2) Persone 11oensed priCr to Decema

-(o)'Holdets of 3 Mar. 81.1977; 43 FR e44. Feb.11,197e: 4e FR ber 6.1974. to Phaaaa" opecial nuclear 880 8 91*

g '"operttion peos. Mar.12,1 set:64 FR 18o44. Asr. T. lee 8i ei mateid subkCt % thle eeodon n'.ay

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FRieset. Apr.80,19ed) maintain a monitoring system'ospable "Q'at tC P

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0) of 4 hoor one foot front th4 eedroe trf the ts.

Specta: nt The Commiselon will hold a beiring distionrne monitorinir dettooe'in the

• 'er W usediathe under 10 CFR part 2. subparte A. G. and eyetem shall have A preest alarm point

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1. on each app!!oatied for isesanoe of a of not lees than 6 millireene per hode

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d good osase a'fots Isoense for construction and operation (in ortler to svold.fbles)&larms) not of a utenlum enrichm6nt facility. The more than to millitehne pet hour. In no d r aremud

'* P Y past A'em, ant b M4 ult Commise1on will publish public notice er,st may anPetek dettes'bd ihrther,j

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of the hearing in the Federal Register than 130 feet fedmithe speolal seclear -

'eq,ggg at least 80 dare befbre the hearing, snaterial being handtad. ased, te stored:

on. Suc dietances teartte'thecessary to

seson leseer.the reghireseenbe!ef'this para-

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(at rm 14est. Apr. 40, lessI s

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$NLS4 Cet44editry" ameldaat requir,.

w, (3) The licensee sh&11 taalatal:1 omer-(m)' Each lioene6e anthorised to poe-toney procedness.fet back area in g gg,gg '

sees opscial nuclear material in a quan* which this iloensed spoolat neolear ma' y.

au. u for de al nei tity exooeding '!Oo gTame of contained urial te handlediede' d, or stored to on-

.'Ta) Each adotloant uranium-138. 830 grame 6f trentuan-333, acto that au perseasel withdraw to an.

450 greme of pictonium; 1.000 grame of area of safety upon time scending of the

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contataed uranintrwaB6 if no urantum alarm / note procedaree must IJsolude.

g es(aX1) and (2; eraphe enriched to more than 4 percent by the conduct of dtille to Martes per-tertit a decorr weight of uranium-386 le present. 460 sonner with the*teestaWoe plani sed g,, Dlan as described grame of any somWastion thereof, or cedgnsMon'of*a

+= indivMeelg of this ecoMon.

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one-half such ~ quantittee if mosai,ee for dotarmining thicasse of the alarei; (1) Cspoeico 3%

l moders6ere or n rWiectors made ~ of and placement of 2ndletteerservey to, ohment faciljty:

(8) A spectfte Ito,m

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graphite, heavy water or' berylliam rnay be present, shall rnalatain in och struments in -acceaetble-loomuone fur M A8M1 t " L use in each snitnergesaKThe lloemees staa in whleh such licensed spooial au-eBall' Ntain a oopy of terrentnprose, ear insterial la qi.

clear material le handled, used, of dares for each attaf de a record fbe se W Mates the appl. j I'

stored, a monitoring system tnecting 'long as llosased special anoleer aw la appeedix B l the requissemente of etther paragraph rial ta handled / tneet or Stored-te th6 estoalat fundin4 l j

MX1) or (ax2), as appropriate, and araa. The lloemsoo thell retain any en:

.Hbenitted when a.

pas 14 intolWd if l using gamma-or sautron.eenaltive re-perseded partlantof the preceddres fbe g eate thaa 1 (unf t; l distion detectors which w!!! energize three yease after.tt:4 porWen le espero the eum of the ratio l i

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l dental criticality ooours. Thle eeotion (b) Each licensee authorteed to poM each lootope to the l is not,latended to requirt tmderwater es<es special nuclestcmaterial in qsaa, Dpendia 3 to part 30 l monitoring whon special nuclear mano-tities in eraees ef athose spoo18ed la

) E"CA ePD!loant fc l Authorteing Poese. I rial is handled or stored beneath water. pengesyti(a) shal$r o' - -

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produces an absorbed dose in soft tie-qualitud to handMeredi&Woei?

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sue of 30 rsde of combined neutron and genotes, arrangetattttd+ftien ded;ln the amc rsinma ndiation at an anahtelded dio-tation of taNred er ed6thkdas (d) of this I

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I 10 CFR 70.14(a)

Tennessee VaHey Autnonty. P st CMee ecx 2000..SmOasy. Tennessee 37379 2cco 10 CFR 70 24(a) 10 CFR 70.24(d)

'97 FEB 26 A9 5 February 20,1997 U.S. Nuclear Regulatory Commission XITN. Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of

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Docket Nos.50-327 Tennessee Valley Authority

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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - UNITS I and 2 - REQUEST FOR EXEMPTION FROM 10 CFR 70.24 CRITICALITY MONITORING REQUIREMENTS In accordance with the provisions of 10 CFR 70.14(a), TVA is submitting a request for an exemption from the requirements of 10 CFR 70.24(a), " Criticality Accident Requirements" for SQN Units I and 2 His request involves no changes to radianon monitoring instrumentation or emergency procedures presently utilized at SQN.

Specific exemptions from Section 70.24 were previously granted in the construction phase special j

nuclear material (SNM) licenses for each unit (SNM-1716 and SNM-1863).

The basis for the exemption request is detailed in the attached enclosure and meets the good cause requirements outlined in 10 CFR 70.24(d). TVA believes the exemption request is appropriate for the same reasons as the exemption granted in the original SNM licenses. Further, we feel the proposed exemption is authorized by law and will not endanger life or property or the common defense and security, and is otherwise in the public interest.

If you have any questions about this exemption request, please telephone me at (423) 843-7170.

l Sincerely, p

r, R. H. Shell Manager of Licensing and Industry Affairs i

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U.S. Nuclear Regulatory Comnussion Page 2 February 20,1997 Enclosure cc (Enclosure):

Mr. R. W. Hernan, Project Manager l

Nuclear Regulatory Commission l

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 I

NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator l

U.S. Nuclear Regulatory Commission

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j Region 11 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323-2711 l

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i ENCLOSURE REQUEST FOR EXEMPTION FROM 10 CFR 70.24(a)

CRITICALITY ACCIDENT REQUIREMENTS I.

EXEMPTION REQUESTED AND REGULATORY BACKGROUND i

Pursuant to 10 CFR 70.14(a) and 70.24(d), TVA requests an exemption from the requirements of 10 CFR 70.24(a)" Criticality Accident Requirements" for SQN Units I and 2. Specifically, an exemption is requested for accident criticality monitoring for the handling, use, and storage of special nuclear material (SNM) in the form of nuclear fuel, calibration sources and neutron monitoring instrumentation (such as source range monitors (SRMs), intermediate range monitors (IRMs), and incore fission detectorsJ.

10 CFR 70.24(d) anticipates that licensees may request relief from the requirements of Section 70.24, in whole or in part, if good cause is shown. 10 CFR 70.24(c) states thst holders of Part 50 operating licenses are exempt from 10 CFR 70.24(b) provisions. Therefore, only an exemption to

-Section 70.24(a) is being requested.

Exemptions from 10 CFR 70.24 were previously granted in the construction phase SNM licenses for each unit (SNM-1716, and SNM-IS63).

TVA believes an exemption is appropriate for the same reasons as for the exemption granted in the original SNM licenses. An accident critica'ity monitoring system was not and is not necessary at SQN Units 1 and 2.

II.

JUSTIFICATION FJ THE L;,EMPTION SNM in Calibration Sources and Neutron Monitoring Instrumentation The major form of SNM used at SQN is nuclear fuel. However, other small quantities of SNM are in the form of fissile material in calibration sources and neutron monitoring instrumentation. He quantity of SNM U-235 in each flux detector (SRM / IRM) and incore detector, is small and is 7 grams and 4 milligrams respectively. SQN also has several calibration sources containing very small amounts of plutonium-239 totaling approximately 0.02 milligrams.

The quantity of SNM specified to be enough for a critical mass in Section 1.1 of Regulatory Guide 10.3, " Guide for the Preparation of Applications for Special Nuclear Material Licenses of Less than Critical Mass Quantities", is 350 grams of U-235,200 grams of U-233, and 200 grams of Pu-239.

He quantities of SNM in the nuclear instrumentation described above is far below the amounts for which criticality monitoring would be of concem.

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SNM IN UNIRRADIATED NUCLEAR FUEL The principal form of SNM subject to 10 CFR 70.24(a) is unirradiated (new) nuclear fuel. New fuel bundles are received and transported m NRC approved packaging (commonly referred to as shipping containers). Package design for the shipping contamers ensures that a geometncal criticality safe configuration is maintained during transport, handling, and storage.

New fuel may be placed in the new fuel storage vault or in the spent fuel pool. SQN has installed new fuel storage racks for storage of new fuel. The design basis and description of the new fuel storage racks and the spent fuel pool storage racks are provided in Chapter 9 of the Final Safety Analysis Report (FSAR) and section 5.6.1.2 of the SQN Technical Specifications (TS).

New fuel shipments are received in the approved shipping containers. The containers are opened and the bundles are inspected and placed directly in the new fuel vault or in the spent fuel pool.

Handling of new fuel and irradiated fuel is carefully controlled by site fuel handling procedures.

Strict limits are presenbed for the maximum number of fuel bundles permitted to be removed from approved storage locations at any given time. Given these circumstances, a criticality safe configuration is maintained and there is no need to maintain enticality monitoring system pursuant to 10 CFR 70.24.

This exemption request involves no changes to radiation monitoring instrumentation, plant equipment, or emergericy procedures presently utilized at SQN, and does not involve changes to l

safety analyses found in Chapter 15 of the FS AR. Also, this exemption request does not involve changes to current TS requirements related to fuel handling, or invcive changes to operations related to the spent fuel pool or enticality monitonng of fuel in the reactor core.

Based on the above, the design of the shipping containers and fuel racks in combination with the procedural controls associated with fuel handling ensure that conditions that may lead to accidental criticality are precluded. Accordingly, the requested exemption will not endanger life or property or be inimical to the common defense and security. Thus, we believe the exemption is authorized by law, and there is good cause for grantmg an exemption for accident criticality monitoring requirements for SQN Units land 2. Granting of an exemption is also consistent with the same exemption granted from 10 CFR 70.24 in the original construction phase SNM licenses.

111.

Conclusion TVA has concluded, based on the preceding justification. that operation of SQN in accordance with the proposed exemption to 10 CFR 70.24(a) is authorized by law, will not present an undue risk to the public health and safety, is consistent with the common defense and security, and is othensise in i

the public interest.

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