ML20210B752
| ML20210B752 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 07/21/1999 |
| From: | Oconnor S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Shankman S NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 07200030, TAC-L22922, NUDOCS 9907230225 | |
| Download: ML20210B752 (17) | |
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f CEn p 3 UNITED STATES l g g NUCLEAR REGULATORY COMMISSION p $ WASHINGTON, D.C. 20665-0001 Y...../ July 21, 1999 MEMORANDUM TO: Susan F. Shankman, Deputy Director Licensing and Inspection Directorate Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards
.A FROM: Stephen C. O'Connor, Project Manager Spent Fuel Licensing Section Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF JULY 7,1999, MEETING WITH MAINE YANKEE (TAC NO. L22922)
On July 7,1999, representatives of the Nuclear Regulatory Commission (NRC), Maine Yankee Atomic Power Company (MYAPC), Stone & Webster, and NAC International, Inc. (NAC) met to discuss MYAPC's plans to store spent fuel using the NAC-UMS dry storage system. An attendance list is included as Attachment 1. Attachment 2 consists of the handouts provided by MYAPC and NAC at the meeting. This meeting was noticed on June 18,1999.
MYAPC presented its schedule for loeding the first UMS cask in April 2001, and to complete fuelloading activities by August 2002. NAC representatives presented plans to submit an amendment to the UMS Safety Analysis Report (SAR) to include the storage of "non-standard" MYAPC fuel. The "non-standard" fuel SAR amendment would address the storage of water rods, consolidated assemblies, variable enrichment / axial blankets, removed fuel rods, damaged fuel and high burn-up fuel. NAC stated that the SAR amendment request was scheduled to be submitted to NRC on July 16,1999.
NRC staff described the rulemaking process and duration required for a Certificate of Compliance amendment resulting from the SAR amendment request. At the conclusion of the discussion on the 10 CFR Part 72 rulemaking process, a MYAPC representative presented a draft document titled "lSFSI Cask Rulemaking." The MYAPC document presents suggestions for streamlining the Part 72 rulemaking process. The MYAPC representative agreed to the staff's request to include the document in this NRC meeting summary. This MYAPC document is included as Attachment 3.
To support MYAPC's decommissioning plans, NAC representatives stated that they would subrnit a 10 CFR Part 72 exemption request on July 16,1999, to begin fabrication ,of UMS casks.for MYAPC. NAC presented plans to begin fabrication in April 2000.
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Docket No. 72-30,50-309 k Attachments: 1. Attendance List
- 2. Meeting Handouts
- 3. MYAPC Rulemaking Handout g g gg g) [ ('
Nn0R3 9907230225 990721 PDR ADOCK 05000309 Y PDR
. . July 21, 1999 MEMORANDUM TO: Susan F. Shankman, Drputy Director Lic:nsing and Insp2ction Dircctorate
. . Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards FROM: Stephen C. O'Connor, Project Manager (Original Signed by:)
Spent Fuel Licensing Section Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF JULY 7,1999, MEETING WITH MAINE YANKEE (TAC NO. L22922)
On July 7,1999, representatives of the Nuclear Regulatory Commission (NRC), Maine Yankee Atomic Power Company (MYAPC), Stone & Webster, and NAC International, Inc. (NAC) met to discuss MYAPC's plans to store spent fuel using the NAC-UMS dry storage system. An attendance list is included as Attachment 1. Attachment 2 consists of the handouts provided by MYAPC and NAC at the meeting. This meeting was noticed on June 18,1999.
MYAPC presented its schedule for loading the first UMS cask in April 2001, and to complete fuel loading activities by August 2002. NAC representatives presented plans to submit an amendment to the UMS Safety Analysis Report (SAR) to include the storage of "non-standard" MYAPC fuel. The "non-standard" fuel SAR amendment would address the storage of water rods, consolidated assemblies, variable enrichment / axial blankets, removed fuel rods, damaged fuel and high burn-up fuel. NAC stated that the SAR amendment request was scheduled to be submitted to NRC on July 16,1999.
NRC staff described the rulemaking process and duration required for a Certificate of Compliance amendment resulting from the SAR amendment request. At the conclusion of the discussion on the 10 CFR Part 72 rulemaking process, a MYAPC representative presented a draft document titled "lSFSI Cask Rulemak;ng." The MYAPC document presents suggestions for streamlining the Part 72 rulemaking pr3 cess. The MYAPC representative agreed to the staff's request to include the document in this NRC meeting summary. This MYAPC document is included as Attachment 3.
To support MYAPC's decommissioning plans, NAC representatives stated that they would submit a 10 CFR Part 72 exemption request on July 16,1999, to begin fabrication of UMS casks for MYAPC. NAC presented plans to begin fabrication in April 2000.
Docket No. 72-30, 50-309 Attachments: 1. Attendance List
- 2. Meeting Handouts
Dockets NRC File Center PUBLIC NMSS R/F SFPO R/F LKokajko PEng FLyon, NRR UMS Team MRoberts, R-l NJensen, OGC NRC Attendees SShankman LPittiglio VTharpe (4) ANorris, PMDA G:\ Maine Yankee \07-07MTG. SUM OFC SFPO E /S1M@ dE NAME SO'Conrjor kb CRC e DATE D!7i "") f /
[ OFflCIAL RECORD COPY
3 July 7,1999, Meeting between Maine Yankee Atomic Power Company and Nuclear Regulatory Commission ATTENDANCE LIST Name Affiliation Cad Paperiello NRC/NMSS Martin Virgilio NRC/NMSS Aby Mohseni NRC/NMSS William Brach NRC/NMSS/SFPO Wayne Hodges NRC/NMSS/SFPO Ross Chappell NRC/NMSS/SFPO Eric Leeds NRC/NMSS/SFPO Stephen O'Connor NRC/NMS3/SFPO James Hall NRC/NMSE/SFPO Sarah Colpo NRC/NMSS!SFPO John Greeves NRC/NMSS/DWM Michael Webb NRC/NRR Michael Meisner Maine Yankee George Zinke Maine Yankee Paul Bemis Stone & Webster William Butler, Jr. Stone & Webster Michael Holmes Stone & Webster Bud Auvil NAC Intemational Tom Thompson NAC Intemational Patrick Dostie State of Maine Uldis Vanags State of Maine Rita Bowser BNFL Fuel Solutions Alan Nelson NEl John Sutton Yankee Rowe/DE&S Robert Sweeney IBEX Stuart Webster CY/Bechtel Jenny Weil McGraw-Hill Altheia Wyche SERCH Licensing /Bechtel Attachment 1 f
l * }
I Attachment 2 I dhNAC l
) IPEINTERNATIONAL )
l NAC Submittals on the UMS Supportive of Maine Yankee
- Decommissioning j l
Bud Auvil Vice President, Project Operations, NAC International Paul Bemis Director of Licensing & Regulatory Affairs, Stone & Webster l Mike Meisner President, Maine Yankee Agenda ;
- UMS CoC and Amendment Objectives
- Schedule for UMS submittals
- Current NRC review schedule (restated)
- Maine Yankee non-standard fuel amendment
- Schedule for Maine Yankee full pool off-load
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l l
- Achieving overall Maine Yankee schedule
- Requested schedule for UMS Storage CoCs
- Maine Yankee /SWEC/NAC actions
- Requested NRC actions
- Conclusions T RNATIONAL 1
-O !
UMS CoC and Amendment l
Objectives l
- Achieve sound basis of full pool solution for all Maine Yankee fuel and waste by 12/99, with NRC approval I
- Maintain transport and storage schedules for review
- Submit MY non-standard fuel, excluding damaged fuel, in Transport supplement -
complete amo. ->
UMS CoC and Amendment Objectives (Continued) l
- Submit MY non-standard fuel, including damaged fuel, as prospective amendment to storage CoC -
July 16,1999 , .
- Submit damaged fuel for transport in response to Transport RAl-1
- Achieve NRC amendment approval for non-standard fuel storage by 12/99 A"ef ~4rio~xt
- 2
Schedule for UMS Submittals
- Transport Supplement - complete (as scheduled)
- Maine Yankee Non-Standard Fuel Amendment -July 16,1999
- Storage RAl-2 Response and SAR Supplement
- August 13,1999 (as scheduled)
T RNATIONAL Current NRC Review Schedule (Restated) 8/30/99 lssue RAl-l for UMS Transport 11/1/99 Issue Draft SER and CoC for UMS Storage -
4/00 issue CoC and SER (or Second RAI, if necessary) for UMS Transport 8/00 issue Transport CoC and SER(if Second RAI) 10/00 issue Part 72 CoC for UMS Storage (i.e., Rulemaking complete)
A",tifa~4Tio~At
- 3
i Maine Yankee Non-Standard Fuel l Amendment
- Consolidated Assemblies (2)*
- Variable Enrichment / Axial Blankets
- i
- Removed Fuel Rods *
- Damaged Fuel (in Screened Cans)
- High Burnup Fuel (< 50 GWD/MTU)* !
- These already submitted to NRC in Transport Supplement ofJune 18,1999 n=v ~ 1,0~ < ~"
Schedule for Maine Yankee Full Pool Off-Load 7/99 Request fabrication exemption 10/99 Initiate Material Order (for Standard Fuel) 4/00 Initiate Fabrication (for Standard Fuel)
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I/01 First Canister Delivery 4/01 Initiate Cask Loading 8/02 Complete Cask Loading / Pool Offload Anfesriost
- l i
4
Achieving Overall Maine Yankee Schedule Objective: Ensure rulemaking complete for
, standard and non-standard fuel pool contents prior to first cask offload (scheduled for April 20,2001)
Steps to accomplish above objective
- Establish expedited, creative review schedule for Maine Yankee Non-Standard Fuel Amendment 1
- Improve regulatory cycle time on the '
rulemaking initiatives N RNATIONAL 1
I Achieving Overall Maine Yankee Schedule (Continued)
Establish expedited review and approval schedule for Maine Yankee Non-Standard Fuel Amendment .
- Perform prompt NRC acceptance review
- Perform technical review for Amendment
- Technical review performed such that it does not impede or delay " standard fuel" review (storage or '
transport)
- Complete review by 12/99 R"~^ifas4Tionst
- 5
Achieving Overall Maine Yankee Schedule (Continued)
- Improve regulatory cycle time on the following rulemaking initiatives:
- Direct-to-final rulemaking for standard fuel CoC
- NAC-MPC rulemaking precedent
+ Other cask vendor rulemaking precedents
- No rulemaking for Amendments (i.e., Maine Yankee non-standard fuel)
- Above is consistent with NRC SFPO's own initiatives RM7as4Tios4t *"
Requested Schedule for UMS l
Storage CoCs !
12/99 Issue Draft CoC/SER for Non-Standard Fuel Storage i 4/00 Issue Draft Part 72 CoC/SER for Non-Standard Fuel l Storage (if RAI) !
6/00 issue Part 72 CoC for UMS Storage (Direct-to-Final -
l Rulemaking)
I 6/00 issue Part 72 CoC for UMS Non-Standard Fuel Sto;3ge (if no Rulemaking for Amendment, with no RAI) !
7/00 issue Part 72 CoC for UMS Non-Standard Fuel Storage (Direct-to-Final Rulemaking, with no RAI) 11/00 issue Part 72 CoC for UMS Non-Standard Fuel Storage if RAI (Direct-to-Final Rulemaking)
RI4^17asArios4t *"
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Recent NRC Successes in Responsive Licensing to Critical Schedules NAC has worked closely with NRC to achieve cri:ical licensing schedules, similar to Maine Yankee's Ucensed Certificate of Compliance Change Submittal Approval System Revision No. Date Date NAC-STC Shipment of Canistertzed Fuel- R 2 12/30/96 3/25/99 RAf Response 8/7/98 3/25/99 NAC-MPC Storage of Canisterized Fuel- R 0 4/30/97 3/25/99 (Draft) I RAI Response 10/8/98 3/25/99 (Draft)
NAC-LWT Revised TRIGA Fuel Parameters R 18 6/1/99 6/17/99 NAC-LWT Revised TRIGA Poisoned Basket R 17 l/29/99 3/31/99 NAC-LWT Shipment of Special MTR Fuel- R 15 2/3/99 2/10/99 NAC.LWT Revised Basket Configuration for MTR, Clad Defects - R 14 7/14/98 12/21/98 NAC-LWT Updated to B(U)-85 Cerofication - R 13 Il/21/97 Il/20/98 NAC-LWT Shipment of TRIGA Fuel Elements - R 12 Il/10/97 5/27/98
$$IERNATIONAL Recent NRC Successes in Responsive Licensing to Critical Schedules (Continued)
Ucensed Certificate of Con.pnance Change Submittal Approval System Revision No. Date Date NAC-LWT Shipment of HEU MTR Fuel R Ii 5/7/97 12/18/97 NAC-LWT Transport Brookhaven Fuel Letter 4/29/97 7/l5/97 NAC-LWT Transport HEU MTR Fuel Low Burnup, Short Cooled for Columbia - Letter 9/6/96 9/6/96 NAC-NU I/2 Revised Procedures, Drawings R 39 2/27/98 5/29/99 NAC-Nu 1/2 Revised Procedures R 38 2/27/96 3/29/96 NAC-Nu 1/2 Shipment of High Burnup, Short Cooled Rods R 36 10/9/95 10/31/95 NAC-Nu 1/2 Shipment High Burnup Rods - R 35 3/10/94 3/14/94
$5IERNATIONAL 7
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Maine Yankee /SWEC/NAC Actions NAC submits Maine Yankee Non-Standard Fuel (NSF)
Amendment (July 16,1999) and fully supports NRC's ,
review I Maine Yankee / Stone and Webster /NAC team fully supports NRC review to finalize draft CoCs/SERs for standard fuel storage and transport in accordance with current NRC schedule NAC/ Maine Yankee submits request for exemption to fabricate in 7/99 TfRNATIONAL Requested NRC Actions
- NRC completes acceptance review and parallel 1 technical review of Maine Yankee Non-Standard Fuel (NSF) Amendment by 12/99 -
- Vigorously pursue rulemaking related initiatives with Maine Yankee's support
- Support 4 month review and closure period for MY NSF amendment if RAI required (by 4/00).
l A",afe~Ario~At *" '
l 8
l
o Conclusions
- Licensir.g strategy is straightforward a Strategy supports Maine Yankee's stakeholders' objective of assuring full pool solution (operational ISFSI with no ongoing need/ requirement for spent fuel pool) 1
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L 1 l , ATTACHMENT 3 1*
i l Document presented by Maine Yankee Atomic Power Company at July 7, 1999 meeting' with NRC. l DRAFT ISFSI CASK RULEMAKING in 1990, the NRC amended its regulations to provide for the storage of spent fuel under a generallicense on the site of any nuclear power reactor provided the reactor licensee notified the NRC, used NRC-Certified storage casks, and stored the fuelin accordance with the cask Certificate of Compliance. The amended regulations in 10CFR 72 provided for approval of fuel storage casks via the rulemaking process (10CFR 72 Subpart L).
Eight (8) cask systems have been approved and added to 10CFR 72.214 through the process of " notice-and-comment" rulemaking. The " notice-and-comment" rulemaking process, as presently implemented, involves the following basic steps / timetable:
- 1. Vendor Submittal Time = 0
- 2. Staff Technical Review Vendor Response to Staff Requests for Additional Information.
Draft Certificate of Compliance and Safety Evaluation Report issued.
Notice of Proposed Rulemaking published. Time =16 months
- 3. Public Comment Period NRC resolution of Comments Final Rule publication Time = 27 months The experience gained by the NRC Staff and Industry over the past decade has shown that the additions and revisions to the list cf approved cask designs in 10CFR 72.214 has become noncontroversial and routine. From the NRC Staff perspective, this specific finding was recently documented in the publication of proposed rulemaking related to the addition of the HOLTEC Hi-Star Storage Cask System to 10CFR 72.214 (January 11,1999). In this publication, the NRC Staff noticed their intent to publish future additions and revisions to 10CFR 72.214 as direct - final" rules. Should this rulemaking process be established, the cask certification process from application to final c; ;tificate issuance could be improved by approximately 11 months.
r l
l DRAFT In the HOLTEC Hi-Star notice, the NRC Staff further described their intended l " direct - final" prccess which included a post publication 30 day public comment j i period. If no "significant adverse comments" were received during this period the l l published rule would become effective 75 days after publication. Should "significant adverse comments " be received during the public comment period, the NRC would withdraw the " direct - final" rule, address the comments, and would subsequently issue a final rule.
l Although the NRC Staffs intent to simplify the rulemaking process for Spent Fuel l
Dry Storage Casks is a step in the right direction, their described process goes beyond the " direct - final" process contained in the regulations.
l Subpart H of 10CFR 2 describes the regulations applicable to "Rulemaking."
l Paragraph 2.804 (d) describes the " direct - final " process as follows; 1
The notice and comment provisions contained in paragraphs (a), (b), and (c) of this section will not be required to be applied -
- 1. To interpretive rules, general statements of policy, or rules of agency organization, procedure, or practice; or
, 2. When the Commission for good cause finds that notice and public comment are impracticable, unnecessarv, or contrary to the public interast, sud are not required by statute.
The conclusiori that " additions and revisions to the list of approved cask designs in 10CFR 72.214 has become noncontroversial and routine", would appear to meet the above stipulation that notice and public comment would be
" unnecessary."
Paragraph 2.804 goes on to discuss the need for a 30-day post-promulgation comment period in paragraph 2.804 (e) as follows; The Commission shall provide for a 30-day post-promulgation comment period for -
(1) Any rule adopted without notice and comment under the good cause exception on paragraph (d)(2) of this section ,
where the basis is that notice and comment is
" impracticable" or " contrary to the public interest."
NOTE - the basis that the notice and public comment is unnecessary is NOT included.
A DRAFT (2) Any interpretive rule, or general statement of policy adopted without notice and comment under paragraph (d) (1) of this section, except for those cases for which the Commission finds that such procedures would serve no public interest, or would be so burdensome as to outweigh any foreseeable gain.
Based on paragraph 2.804(e), it would seem that a 30-day post promulgation public comment period would not be required for a " direct - final" rulemaking concerning additions and revisions to the list of approved cask designs in 10CFR 72.214.
If the above conclusion concerning the post promulgation public comment period was found incorrect then the last paragraph of 10CFR 2.804 needs to be examined.
(f) For any post-promulgation comments received under paragraph (e) of this section, the Commission shall publish a statement in the Federal Register containing an evaluation of the significant comments and any revisions of the rule or policy statement made as a result of the comments and their evaluation.
Paragraph (f) does not consider different treatment of "significant adverse comments" and does not address withdrawal of the published " final" rule pending evaluation of such comments.
CONCLUSION: The industry should strongly support and encourage the NRC to add storage cask systems to 10 CFR 72.214 via the " direct - final" rulemaking process described in 10CFR 2.804, by recognizing that notice and comment are unnecessary and eliminating the concept of a 30 day post-promulgation comment period.
l l
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.. July 111999 MEETING NOTICE Organization: Sacramento Municipal Utility District (SMUD)
Date and Time: July 28,1999,9:00 a.m. - 11:30 a.m.
Location: U.S. Nuclear Regulatory Commission (NRC)
One White Flint North Building Room 6-B-11 11555 Rockville Pike Rockville, Maryland 20852
Purpose:
To discuss the NRC staff's ongoing review of the application for an independent spent fuel storage installation at the Rancho Seco Nuclear Generating Station. The discussion will focus on the staff's next request for additional information, which will to be issued prior to the meeting.
(TAC No. L10017)
Participants:
NRC SMUD SAIC Susan F. Shankman Steve Redeker Steve Mirsky Ross Chappell Ken Miller David Williamson, et al.
James R. Hall, et al. Bob Jones, et al.
NOTE: Meetings between the NRC staff and licensees are open for interested members of the public to attend as observers pursuant to the "Open Meeting Statement of NRC Staff Policy,"
59 Federal Reaister 48340; September 20,1994.
Portions of this meeting may be closed to members of the public due to the sensitive nature of information to be discussed pursuant to 10 CFR 2.790.
Contact:
James R. Hall (301) 415-1336 Note: Attendance at this meeting by other than those listed above should be made known via phone to the above contact by 1:00 p.m. on Tuesday, July 27,1999.
cc: Participants (fax copy)
Service List Docket Nos': 72-11,50-312
%h Distribution: -
NRC f/c DOCKET PUBLIC NMSS r/l SFPO r/f SGagner, OPA
- WBrach SShankman WHodges LKokajko
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PMNS (e-mail) PEng EEaston EJLeeds CFLyon, NRR NJensen. OGC , RDudley NRR SMirsky, SAIC SFLS/SFTR staff (e mail)
VEverett, RIV BSpitzherg, RIV G:\smud\0728mtg n@ wpd -
OFC' SFPO SFPQp E2 SFOf E E NAME JRHall e appell DATE 07// 07/Q/99 07//[ /99 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY 9907230103 990713 PDR ADOCK 05000312 y PDR
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Rancho Seco Nuclear Generating Station Docket Nos. 72-11 (50-312) cc:
Mr. Richard Ferreira Mr. Steve Hsu Assistant General Manager - Energy Radiologic Health Branch Supply & Chief Engineer State Department of Health Services Sacramento Municipal P. O. Box 942732 Utility District Sacramento, CA 94234 6201 S. Street P.O. Box 15830 - Mail Stop 41 Cindy Buchanan, Site Document Sacramento, CA 95813 Control Supervisor Sacramento Municipal Utility District Thomas A. Baxter, Esq. Rancho Seco Nuclear Generating Station Shaw, Pittman, Potts & Trowbridge 14440 T win Cities Road 2300 N. Street, N.W. Herald CA 95638-9799 Washington, D.C. 20037 Mr. Jerry Delezenski Quality & Compliance Superintendent Sacramento Municipal Utility District Rancho Seco Nuclear Station l 14440 Twin Cities Road Herald, CA 95638-9799 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 6* 1 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Sacramento County Board of Supervisors 700 H. Street, Suite 2450 Sacramento, CA 95814 Ms. Helen Hubbard P. O. Box 63 Sunol, CA 94586 Ms. Dana Appling, General Counsel Sacramento Municipal Utility District l i
6201 S. Street P. O. Box 15830 Sacrarnento, CA 95813 I
,