ML20206N398

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Responds to Comments & Questions Submitted to NRC Staff Re Recent License Amend Issued by NRC to Callaway Unit 1 License.Provides Context for Conclusion That Reracking of Callaway SFP Maintains Adequate Protection of Public Safety
ML20206N398
Person / Time
Site: Callaway Ameren icon.png
Issue date: 05/10/1999
From: Mel Gray
NRC (Affiliation Not Assigned)
To: Drey L
AFFILIATION NOT ASSIGNED
References
NUDOCS 9905170216
Download: ML20206N398 (3)


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May 10, 1999-Mrs. Leo Drey 515 West Point Avenue University City, MO 63130

Dear Mrs. Drey:

. Your letter dated February 16,1999 submitted comments and questions to the NRC staff I

regarding a recent license amendment issued by the NRC to the Callaway Plant, Unit i license.

This amendment approved the reracking of the Callaway spent fuel pool. In your letter you stated that your questions were rhetorical in nature and that you were not requesting a response from the NRC. In my letter to you dated April 8,1999, I stated that the NRC staff would consider your questions and comments and a response would be provided. While the staff has not responded to your questions individually, the following discussion will provide the context for the staff's conclusion that raracking of the Callaway spent fuel pool maintains adequate protection of the public health and safety.

During our telephone conversation on February 18,1999, I provided information on the Public Document Room services. You indicated that you intended to obtain copies of the Union Electric Company (UE) letters requesting the rerack amendment. However, it was not clear to me whether you had in your possession a copy of the NRC safety evaluation issued with the amendment. Therefore, I have enclosed a copy of the amendment and safety evaluation (Enclosure 1).

The encloud safety evaluation discusses the staff's review of the reracking modification in terms of criticality aspects, spent fuel cooling plant systems, hoisting systems, handling and control of spent fuel racks and fuel assemblies, spent fuel rack and pool structural design, rack materials, and radiological protection. The safety evaluation will provide infonnation relevant to many of your questions. Additionally, some of your questions concerned the structural adequacy of the spent fuel pool and cask loading pit areri. The NRC staff met with UE personnel on two occasions to discuss structuralissues. The summaries of these two meetings, which are on the Callaway public docket, are also enclosed for your information (Enclosures 2 and 3).

i The staff considered the reracking modification proposed by UE in the context of the Callaway Plant licensing basis. The Caliaway Plant licensing basis includes the design and technical requirements that must be met to ensure the Callaway Plant is operated in a manner that provides adequate protection of the public health and safety. The NRC established the licensing basis during initial plant licensing, in reviewing license amendment applications such as the rerack amendment, the NRC staff evaluated the proposal against the design and technical requirements that make up the Callaway licensing basis, and found that the requirements were met.

In your letter you expressed concern regarding the material condition of the spent fuel pool.

NRC regulations requiro licensees, such as UE, to have programs in place to assure effective, high quality maintenance be performed so that there is confidence that plant systems important to safety, such as the spent fuel pool systems, will perform satisfactorily in service.

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Mrs. L. DrGy - Additionally, the NRC focuses on the licensee's corrective action program to verify probJems are identified early on, corrected, and actions taken to prevent reoccurrence. The NRC periodically inspects these programs at the site to verify they are effective and meet regulatory requirements. -The NRC also maintains resident inspectors onsite to monitor management's safety performance. The resident inspectors' monitoring of activities, independent of licensee manaigement, provides added assurance that equipment will be maintained in accordance with the licensing basis. These requirements and inspection measures provide the NRC staff additional confidence that the spent fuel pool and support systems will be maintained in accordance with the Callaway Plant licensing basis.

. In your letter you asked whether it would be safer for UE to install dry storage casks at the -

Callaway Plant, Unit i verses increasing the spent fuel pool capacity. The NRC staff considers both wet pool and dry storage to be safe technologies. Dry storage design is passive in nature and simpler; however, both storage technologies are proven and well developed. Therefore, -

both methods provide for safe spent fuel storage.

In a postscript to your letter you asked whether the NRC staff had ever issued an Environmental Impact Statement (EIS) or " programmatic EIS" for a rerack amendment.

According to my research, the staff has not issued an EIS for a power reactor licensee rerack amendment request. In response to the Commission's direction in 1975 to consider the attematives for handling and storing spent fuel, the staff issued a generic EIS, NUREG-0575,

" Final Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel," dated August 1979. However, since that time national policy regarding certain alternatives, including reprocessing, has changed.

If I can be of further assistance in this matter, please contact me at (301) 415-3021.

- Sincerely,

/s/

Mel Gray, Project Manager, Section 2 Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nucl6ar Reactor Regulation 1

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Enclosures:

1. Amendment No.123 w/ Safety Evaluation
2. Meeting Summary dtd.1/20/99

- 3. Meeting Summary dtd.1/29/98 DISTRIBUTION: (w/o enclosures)

Docket File (50-483).

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,b Mrs. L. Drey Additionally, the NRC focuses on the licensee's corrective action program to verify problems are identified early on, corrected, and actions taken to prevent reoccurrence. The NRC j

periodically inspects these programs at the site to verify they are effective and meet regulatory j

requirements. The NRC also maintains resident inspectors onsite to monitor management's j

safety performance. The resident inspectors' monitoring of activities, independent of licensee management, provides added assurance that equipment will be maintained in accordance with the licensing basis.. These requirements and inspection measures provide the NRC staff additional confidence that the spent fuel pool and support systems will be maintained in accordance with the Callaway Plant licensing basis.

In your letter you asked whether it would be safer for UE to install dry storage casks at the Callaway Plant, Unit i verses increasing the spent fuel pool capacity. The NRC staff considers both wet pool and dry storage to be safe technologies. Dry storage design is passive in nature and simpler; however, both stora;;e technologies are proven and well developed. Therefore, both methods provide for safe spent fuel storage.

In a postscript to your letter you asked whether the NRC staff had ever issued an Environmental Impact Statement (EIS) or " programmatic EIS" for a rerack amendment.

According to my research, the staff has not issued an EIS for a power reactor licensee rerack j

amendment request. In response to the Commission's direction in 1975 to consider the i

altematives for handling and storing spent fuel, the staff issued a generic EIS, NUREG-0675,

" Final Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel," dated August 1979. However, since that time national policy regarding certain attematives, including reprocessing, has changed.

If I can be of further assistance in this matter, please contact me at (301) 415-3021.

Sincerely, Mel Gray, Project Manager, Section 2 Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation l

Enclosures:

1. Amendment No.123 w/ Safety Evaluation
2. Meeting Summary dtd.1/20/99 l
3. Meeting Summary dtd.1/29/98 i

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