ML20205F257
| ML20205F257 | |
| Person / Time | |
|---|---|
| Issue date: | 03/05/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-99-069, SECY-99-069-01, SECY-99-069-R, SECY-99-69, SECY-99-69-1, SECY-99-69-R, NUDOCS 9904060158 | |
| Download: ML20205F257 (11) | |
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March 5.1999 SECY-99-069 FOR:
The Commissioners FROM:
William D. Travers Executive Director for Operations
SUBJECT:
EXEMPTION FROM 10 CFR 72.212 AND 72.214 CONDITIONS OF USE FOR THE VSC-24 DRY STORAGE CASK AT THE ARKANSAS NUCLEAR ONE INDEPENDENT SPENT FUEL STORAGE INSTALLATION PURPOSE:
To request, by negative consent, Commission approval of the staff's intent to inform Entergy Operations, Inc. (Entergy), of its finding that an adequate safety basis supports granting an exemption from the 10 CFR 72.212(a)(2) general license conditions and 10 CFR 72.214 Certificate of Compliance (COC) conditions to store burnable poison rod assemblies (BPRAs) in,
the Ventilated Storage Cask-24 (VSC-24) system at the Arkansas Nuclear One (ANO)
U Independent Spent Fual Storage Installation.
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BACKGROUND:
g ANO is a general licensee under 10 CFR Part 72 that uses the Sierra Nuclear Corporation (SNC) VSC-24 system to store spent fuel. Eight VSC-24s have been loaded at the ANO site; six of the casks contain Combustion Engineering 16x16 fuel from the ANO Unit 2 (ANO-2) spent fuel pool (SFP) and two of the casks contain Babcock and Wilcox (B&W) 15x15 fuel from the ANO Unit 1 (ANO-1) SFP. The ANO-2 SFP currently has enough space to fully offload the fuel in the ANO-2 reactor core. However, the ANO-1 SFP does not have a full core offload reserve.
The ability to fully offload the reactor core is not a regulatory requirement but an operational consideration that the staff supports to maintain operational flexibility.
CONTACT: Stephen C. O'Connor, NMSS/SFPO (301) 415-8561 9904060158 990305 PDR SECY
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99-069 R PDR Y
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The Commissioners l Currently, the COC for the VSC-24 does not approve the storage of BPRAs. On December 30, 1998, SNC submitted a COC amendment request to specifically store B&W 15x15 fuel containing BPRAs in VSC-24s.- On January 18,1999, Entergy requested an exemption from the requirements in 10 CFR 72.214 regarding the conditione specified in the COC for the VSC-24 contents at ANO to allow for the storage of BPRAs. For the staff to grant the exemption from 10 CFR 72.214, we must also grant ANO an exemption from the generallicense conditions of 10 CFR 72.212(a)(2). Section 72.212(a)(2) states that the general license for storage of j
spent fuel at power reactor sites is limited to storage of spent fuel in casks approved under the
_ provisions in 10 CFR Part 72. By exempting ANO from both 10 CFR 72.214 and 72.212(a)(2),
ANO will be authorized to use its general license to store spent fuel in casks approved under
' Part 72, as exempted, to allow storage of BPRAs.
i The staff has completed its technical review of the December 30,1998, SNC amendment request and will soon be proceeding with rulemaking to add this amendment of COC No.1007 to the list of approved casks in 10 CFR 72.214. The staff estimates that rulemaking will not be -
completed until January 2000. Entergy requested the exemption to allow loading of BPRAs by May 1,1999.
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DISCUSSION:
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The ANO-1 SFP currently has 117 spaces available for future fuel storage (each space in the SFP can store 1 fuel assembly). However, the ANO-1 core contains 177 fuel assemblies.
j During the next refueling outage, scheduled to t :S n in September 1999, an additional 60 fuel i
assemblies will be unloaded to the ANO-1 SFP (leaving 57 spaces in the SFP). Since each cask holds 24 fuel assemblies, 5 casks must be loaded prior to the September 1999 refueling outage to obtain full core offload capability. The ANO-1 and -2 SFPs are separate pools with different rack designs. Furthermore, cask loading activities cannot be performed simultaneously with refueling activities at ANO because of coincident manpower and space requirements.
ANO-1 uses BPRAs in the B&W fuel assemblies as a method to control core reactivity. A BPRA is composed of a stainless steel Fpider assembly and retainer meOhanism, with up to 16
-zircaloy-clad rods containing a i mtron poison. The BPRAs are inserted into the fuel assemblies through the upper end fittings of the assembly and held in place agalnst lift forces in the core by the retainer mechanism. Spent BPRAs are currently stored as an integral part of fuel assemblies in the ANO-1 SFP.
- The ANO-1 SFP has enough fuel assemblies without BPRAs to load only one of the five casks necessary to regain full core offload reserves. The loading of these assemblies is scheduled to begin in April 1999.' To med he September 1999 refueling outage schedule, all cask loading activities must be completed by July 1,1999. Entergy requested an exemption from the 10 CFR j
72.214 conditions for cask use to load BPRAs in the remaining four casks needed by ANO-1.
COC No.1007 does not currently allow the storage of BPRAs.
t-Cask preparation and loading activities for each cask loaded with B&W 15x15 fuel take approximately 2 weeks. If Entergy does not receive the exemption from the staff by May 1,
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The Commissioners ' 4 i
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1999, ANO must take actions to disposition BPRAs left in the ANO-1 SFP to continue loading
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casks and regain a full core offload reserve in the SFP.
Staff performed a safety evaluation and environmental assessment of the proposed exemption I
and found no reduction in the safety margin as a result of storing ANO BPRAs along with spent i'
- fuel in the VSC-24s.'
l 1
' The staff evaluated the storage of BPRAs with B&W 15x15 fuel by reviewing the SNC's COC j
j amendment request and performing confirmatory analysis. The staff performed a detailed safety evaluation of the proposed exemption request and found that the addition of the BPRAs j
to the B&W 15x15 fuel does not reduce the VSC-24 safety margin, j
The addition of BPRAs to the B&W fuel increases the weight of the fuel assembly from 689 kg l
(1,516 lbs) to 716 kg (1,576 lbs). The staff found the VSC-24 structural effectiveness adequate j'
to safely maintain spent fuel assemblies containing BPRAs.
l The thermal load of the B&W fuel assemblies (with or without BPRAs) was found to remain at a j
maximum of 1 kW (0.95 BTU /sec).
1 Only fuel with an initial enrichment below 3.3 weight percent uranium-235 is approved for
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storage with BPRAs in the VSC-24s. The addition of BPRAs to B&W 15x15 fuel assemblies l
does not change the acceptable initial enrichment for storage.
i The maximum potential cask dose rates were found to increase by no more than 13 percent at any location on a loaded VSC-24 system. For a VSC-24 loaded with fuel containing BPRAs, the highest dose would be found at the top center of the cask. This dose was calculated to increase from 30 mrem /hr without BPRAs to 32.2 mrem /hr with BPRAs. Furthermore, the off-site dose ra*.es remain well within the 10 CFR Part 20 limits.
Staff also evaluated the following possible attematives to granting tha exemption and the ramifications of each:
1.
Remove BPRAs from the fuel to be loaded in casks and disassemble the BPRAs by cutting the assemblies into pieces and storing in canisters for low-level waste storage.
Resulting adverse considerations would include pool cleanliness, contamination control, increased personnel dose due to handling, an increased amount of radioactive waste, and the potential for particle migration into the primary system leading to subsequent fuel failures.
2.
Leave fuel with BPRAs in ANO-1 SFP. Should a situation arise that requires a full core offload prior to receiving the COC amendment, ANO would have to remove BPRAs from fuel assemblies to be loaded in casks. The BPRAs would need to be stored at the sides of the SFP, between the fuel rack and the SFP walls, for an interim period. Storage in this manner may cause the BPRAs to deform such that re-insertion into fuel assemblies at a later date would not be possible. These BPRAs would be handled as low-level waste.
The Commissioners 3.
Remove BPRAs from the fuel assemblies to be loaded in casks and store them in the SFP racks. However, BPRAs require the same amount of SFP storage space whether they are stored in an assembly or not (unless stored on the sides of the SFP, as described in item 2 above). Removing BPRAs from the assemblies allows more casks to be loaded, but does not increase available SFP space to regain full core offload reserve. The BPRAs would eventually need to be disposed of as low-level waste, as
- described in item 1 above.
4.
Re-rack the SFP. Entergy has not pursued the option of re-racking the ANO-1 SFP.
The last Entergy request to re-rack the ANO-1 SFP was granted by the staff on April 15, 1983.
. In summary, staff has determined that the storage of BPRAs in the VSC-24 system does not pose any increased risk to public health and safety and actually decreases the potential occupational dose associated with disassembling the BPRAs fron1 the fuel assemblies. Staff finds that the storage of BPRAs in VSC-24 systems at ANO adequately protects public health and safety and the environment.
Since the rulemaking to revise Part 72 reflecting the amended VSC-24 COC will not be completed in time to support ANO's loading schedule, staff intends to grant the exemption as requested.
To address the storage of BPRAs at other licensee sites in the short term, staff is preparing
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interim Staff Guidance and an Information Notice to clarify that the storage of control components (including BPRAs) must be specifically addressed in the COC application.
Furthermore, this exemption request highlights the current regulatory process requiring rulemaking to amend a Part 72 COC. To resolve the issue of the extended time it takes to amend a COC through rulemaking, staff is currently evaluating simplifying the process for amending a COC.
RESOURCES:
The Office of the Chief Financial Officer has reviewed this document and has determined that granting the exemption will have no net impact on resources.
COORDINATION:
The Office of the General Counsel has reviewed this document and has no legal objection. In addition, the Office of the Chief Information Officer has reviewed this document and has no objections to the content.
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The Commissioners RECOMMENDATION:
Staff requests action withir 10 days. Action will not be taken until the SRM is received. We consider this action to be within the delegated authority of the Director, Spent Fuel Project Office, Office of Nuclear Matenal Safety and Safeguards.
k W
Wiliam D. Travers j
Executive Director for Operations
Attachment:
Proposed letter from W. Brach, NRC, to J. Vandergrift, ANO (w/ encl.)
SECY NOTE:
In the absence of instructions to the contrary, SECY will notify f
the staff on Wednesday, March 24, 1999 that the Commission, by negative consent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners OGC OCAA OIG OPA OCA ACNW CIO CFO EDO REGIONS SECY
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NUCLEAR REGULATORY COMMISSION i:
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. Mr. Jimmy D. Vandergrift l
Director, Nuclear, Safety Entergy Operations, Inc.
1448 S.R. 333.
Russellville, AR 72801 i
SUBJECT:
EXEMPTICN FROM 10 CFR 72.212 AND 10 CFR 72.214 CONCHTIONS OF l
USE FOR THE VSC-24 SYSTEM AT THE ARKANSAS NUCLEAR ONE INDEPENDENT SPENT FUEL STORAGE INSTALLATION (TAC NO. L22806)
Dear Mr. Vandergrift:
This is in response to your January 18,1999, letter requesting an exemption to 10 CFR 72.214, i
pursuant to 10 CFR 72.7. In your letter, you request an exemption from the conditions in the Certificate of Compliance (COC) for the Ventilated Storage Cask-24 (VSC-24) system listed in 10 CFR 72.214, COC No.1007, to allow the storage of bumable poison rod assemblies (BPRAs) in VSC-24s at the Arkansas Nuclear One (ANO) Independent Spent Fuel Storage Installation.
l For the U.S. Nuclear Regulatory Commission (NRC) to grant the exemption from 10 CFR 72.214, we must also grant ANO an exemption from the generallicense conditions of 10 CFR 72.212(a)(2). Section 72.212(a)(2) states that the general license for storage of spent fuel at reactor power sites is limiad to storage of spent fuel in casks approved under the provisions in 10 CFR Part 72. Condition 8 of COC No.1007 specifies that the approved VSC-24 system is subject to the Conditions for Cask Use (COC Attachment A). Table 1 of the Conditions for Cask Use shows the fuel assembly weight as s1516 lbs. The fuel assembly weight value would
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be increased to s1576 lbs for fuel with BPRAs. This letter grants your exemption request and 4
provides the NRC's basis and conditions for the exemption.
We understand that the spent fuel pool (SFP) for ANO Unit 1 has lost full core offload (FCO) reserves. Furthermore, ANO must load four VSC-24 casks with fuel containing BPRAs to regain FCO reserves prior to the next refueling outage, scheduled for September 1999.
However, COC No.1007 does not approve the storage of BPRAs.
On December 30,1998, SNC submitted a COC amendment request to specifically store Babcock and Wilcox 15x15 fuel containing BPRAs in VSC-24s. The staff has completed its
.achnical review of this amendment request and has begun the rulemaking process of revising 10 CFR 72.214 to add this amendment to the approved version of COC No.1007.
PRED M!310NAL Attachment
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- J. Vandergrift,
After reviewing (1) the information provided in your letter and (2) the December 30,1998, VSC-24 COC amendment request submitted by SNC, the staff has determined that the safety
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~ basis for the storage of ANO BPRAs in the VSC-24 is adequate to grant your requested
'i exemption. The staff reached this decision at a result of its technical review of the safety significance of storing BPRAs in the VSC-24 versus the ramifications of disassembling the BPRAs from the fuel assemblies and storing them in the SFP. A safety evaluation for the i
exemption request is enclosed.
NRC staff evaluated public health and safety and environmentalimpacts of the proposed.
exemption and determined that granting the exemption would not result in any significant
- impacts. For this action,'an Environmental Assessment and Finding O' No Significant impact have been prepared and published in the Federal Reaister (XX FR XXXXX, XX/XX/99). A copy of the Federal Reaister was provided to you by letter dc J XXXXX,1999. Based on the foregoing considerations, the staff has determined that yanting the proposed exemption from the conditions of 10 CFR 72.212(a)(2) and 72.214, to permit loading of ANO BPRAs in VSC-24s, is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest. ANO is hereby granted this exemption with the condition that fuel containing BPRAs loaded in VSC-24s at ANO must not exceed the technical specifications delineated in the enclosed safety evaluation, as well as all conditions and technical specifications in the current VSC-24 COC. In addition, other conditions that must be met are as follows:
1)
No more than four VSC-24s containing BPRAs will be loaded under this exemption to allow ANO to regain full core offload reserves in the Unit 1 SFP. Future loading of BPRAs in VSC-24s will be accomplished subsequent to issuance of a revision to COC No.1007 addressing this issue.
2)
Only fuel with an initial enrichment below 3.3 weight percent uranium-235 is approved for storage with BPRAs in the VSC-24s. The SFP boron concentration should continue to be maintained at greater than, or equal to,2850 parts per million as specified in the COC.
3)
Loading of the four VSC-24s containing BPRAs must be accomplished prior to the September 1999 ANO Unit 1 refueling outage (1R15). After this date, loading of BPRAs i
in VSC-24s will be performed in accordance with the revision to COC No.1007 addressing the storage of BPRAs.
'4)
ANO must perform the 10 CFR 72.21r. evaluations in accordance with the terms of the general license provisions of 10 CFR Part 72, Subpart K, prior to loading any VSC-24s containing BPRAs.
5)
ANO must inform NRC within 30 days, if any of the conditions of this exemption cannot be met.
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.J. Vandergrift -
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. If you have any questions, please contact Mr. Stephen O'Connor of my staff at 301-415-8561.
Any future correspondence related to this action should reference Docket 72-13 and TAC No.L22806.
Sincerely, l
i E. William Brach, Director j
Spent Fuel Project Office Office of Nuclear Material Safety i
and Safeguards Dockets 72-13/-1007,50-313
Enclosure:
Safety Evaluation cc: Service List s
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. cc:
i Executive Vice President Mr. C. Randy Hutchinson
& Chief Operating Officer Vice President, Operations, ANO 4
Entergy Operations, Inc.
Arkansas Nuclear One P. O. Box 31995 Entergy Operations, Inc.
Jackson, MS 39286-1995 1448 S.R. 333 Russellvi!Ie, AR 72801 Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502-
)
Manager, Rockville Nuclear Licensing Framatone Technologies i
1700 Rockville Pike, Suite 525 Rockville, MD 20852 Senior Resident inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 4
j 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 Vice President, Operations Support Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 a
li 's DOCKET:
72-13 APPLICANT:. Entergy Operations, incorporated Arkensas Nuclear One Power Plant
SUBJECT:
EVALUATION OF REQUEST FOR EXEMPTION FROM 10 CFR 72.212 AND
-10 CFR 72.214 CONDITIONS OF USE FOR THE VSC-24 SYSTEM AT THE ARKANSAS NUCLEAR ONE INDEPENDENT SPENT FUEL STORAGE INSTALLATION BACKGROUND L
l By letter dated January 18,1999, Entergy Operations, Inc. (Er.ergy), requested an exemption i
from the requirements in 10 CFR 72.214 regarding the conditions specified in the Certificate of Compliance (COC) for the Ventilated Storage Cask-24s (VSC-24s) at the Arkansas Nuclear -
l One (ANO) Power Plant to allow for the storage of bumable poison rod assemblies (BPRAs).
ANO Unit 1 uses BPRAs in the Babcock and Wilcox (B&W) 15x15 fuel assemblies at a method l
to control core reactivity. Spent BPRAs are currently stored as an integral part of fuel assemblies in the ANO Unit 1 spent fuel pool (SFP).
ANO is a general licensee under 10 CFR Part 72 and approved to use the Sierra Nuclear Corporation (SNC) VSC-24 system to store spent fuel. Eight VSC-24s have been loaded at the ANO site; six of the casks contain Combustion Engineering 16x16 fuel from the ANO Unit 2 SFP and two of the casks contain B&W 15x15 fuel from the ANO Unit 1 SFP. However, the ANO Unit 1 *FP does not have a full core offload (FCO) reserve. The ability to fully offload the reactor core is not a regulatory requirement but an operational desire of the licensee. In addition, the staff believes that it is prudent for licensees to have FCO capability for operational flexibility.
Currently, the COC for the VSC-24 does not approve the storage of BPRAs. On December 30, i
1998, SNC submitted a COC amendment request to specifically store B&W 15x15 fuel containing BPRAs in VSC-24s.
DISCUSSION j
The staff evaluated the storage of BPRAs with B&W 15x15 fuel by reviewing the COC amendment request submitted by SNC and performing confirma%ry analysis. SNC provided additional information and revised calculations in response to the staff's requests. The staff performed a detailed safety evaluation of the proposed exemption request and found that the addition of the BPRAs to the d&W 15x15 fuel does not reduce the VSC-24 safety margin.
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PREDECISIONAL Enclosure L
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, Safety Evaluation -
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l The addition of BPRAs to the B&W fuelincreases the weight of the fuel assembly from 689 kg (1,516 lbs) to 716 kg (1,576 lbs). The staff found the VSC-24 structural effectiveness adequate to safely maintain spent fuel assemblies containing BPRAs.
The thermal load of the B&W fuel assemblies (with or without BPRAs) was found to remain at a
- maximum of 1 kW (0.95 BTU /sec).
The maximum potential cask dose rates were found to increase by no more than 13 percent.
l Furthermore, the off-site dose rates remain well within the 10 CFR Part 20 limits.
4j-The staff evaluated fuel with an initial enrichment below 3.3 weight percent uranium 235 for 1
storage with BPRAs in the VSC-24s. The addition of BPRAs to B&W 15x15 fuel assemblies does not change the acceptable initial enrichment for storage. The SFP boron concentration will continue to be maintained at greater than, or equal to,2850 parts per million as specified in the COC.
CONCLUSIONS The staff performed a detailed safety evaluation of the proposed exemption request and COC amendment equest and found that the addition of the BPRAs to the B&W 15x15 fuel does not reduce the VSC-24 safety margin. In addition, the staff has determined that the storage of i
BPRAs in the VSC-24 does not pose any increased risk to public health and safety.
REFERENCES Sierra Nuclear Corporation, " License Amendment Request 98-01 to VSC-24 SAR B&W Fuel with BPRAs," 1998.
U.S. Nuclear Regulatory Commission, " Safety Evaluation Report for the Pacific Sierra Nuclear Associates Safety Analysis Report for the Ventilated Storage Cask System," 1993.
PRINCIPLE CONTRIBUTORS Stephen O'Connor 1
1 4.