ML20248K912

Forwards Preliminary SER for North Anna Nuclear Power Station Isfsi,Per Util 950509 Submittal of Application for ISFSI

ML20248K912
Person / Time
Site:	North Anna
Issue date:	06/08/1998
From:	James Shea NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
TAC-L22113, NUDOCS 9806100338
Download: ML20248K912 (83)

Text

_ _ _ _ _. . ._ _ _ _ _ _ _ - _ - - _ - _ . - _ - _ _ _ _ - _ - _ - - -

l June 8, 1998 Mr. James P. O'Hanlon l Senior Vice President- Nuclear l Virginia Electric and Power Company Innsbrook Technical Cente, 5000 Dominion Boulevard Glen Allen, VA 23060 l

l SUBJEECT: PRELIMINARY SAFETY EVALUATION REPOP.T FOR THE NORTH ANNA l !NDEPENDENT SPENT FUEL STORAGE INSTALLATION (TAC NO. L22113) i

Dear Mr. O'Hanlon:

]

By letter dated May 9,1995, you submitted an application to the Nuclear Regulatory  !

Commission in accordance with 10 CFR Part 72 for the review and approval of a site-specific j license for an independent spent fue! storage installation (ISFSI) at the North Anna Nuclear l Power Station site. i As a result of our review of your application, the staff has prepared a safety evaluation report

- (SER). Enclosed for your review for inaccuracies or omissions is a preliminary copy of SER i Chapters 1-17 only. You are requested to respond within 4 working days of receipt of this letter.  !

Please continue to reference Docket No. 72-16 and TAC No. L22113 in your future correspondence related to this request.

If you have any comment or question concerning this request, please contact Joseph Shea at 301-415-1428 or Sheena Whaley at 301-415-1911.

Sincerely, ORIGINAL SIGNED BY Sheena A. Whaley for /s/ l Joseph W. Shea, Project Manager Spent Fuel Licensing Section Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards l

Dockets'72-16 (50-338/339)

Enclosure:

As stated ,,,., 3 2nvxkL \'

cc: Service List I Distribution: (Control No. 010S)

~ Dockets - NRC File Center PUBLIC NMSS r/f VTharpe i SFPO r# SFLS r# CHaughney SWhaley WReamer, OGC NKalyanam. NRR WGloersen, Ril EMcAlpine, Ril

' {01 l- OFC SFPO , E SFPO [ E SFPO j E NAME JSh VTharpe EJLeeds DATE 06/d/98 - 06/ i /98 06/[/9 6/4/98:dd C = COVER E = COVER & ENCLOSURE N = NO COPY l

t OFFICIAL RECORD COPY G:\ NORTH _ANiDRFTSER.LTR I

9906100338 990608 M7p g PDR ADOCK 05 dish gj {f((] {g

l \

'b l l

i Virginia Electric & Power Ccmoany j

72-2 (50-280/281) Surry Power Station 1 72 16 (50-338/339) North Anna Power Station Units 1 & 2

{

1 cc:

Mr. J. Jeffrey Lunsford Robert 9. Strobe, M.D., M.P.H.

County Administrator, State Health Commissioner Louisa County Office of the Commissioner P.O. Box 160 Virginia Department of Health Louisa, Virginia 23093 P.O. Box 2448 Richmond, Virginia 23218 Michael W. Maupin, Esq.

Hunton and Williams Regional Administrator, Riverfront Plaza, East Tower Region ll 951 E. Byrd Street U.S. Nuclear Regulatory Commission Richmond, Virginia 23219 Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Dr. W. T. Lough Atlanta, Georgia 30303 Virginia State Corporation -

l Commission W. R. Matthews, Manager Division of Energy Regulation North Anna Power Station P.O. Box 11g7 P.O. Box 402 Richmond, Virginia 23209 Mineral, Virginia 23117 Old Dominion Electric J. P. O'Hanlon Cooperative Senior Vice President- Nuclear' 4201 Dominion Boulevard Virginia Electric and Power Co.

Glen Allen, Virginia 23060 innsbrook Technical Center 5000 Dominion Boulevard J. H. McCarthy, Manager Glen Allen, Virginia 23060 Nuclear Licensing and Operations Support Mr. David Christian, Manager Virginia Electric and Power Company Surry Power Station Innsbrook Technical Center Virginia Electric and Power Company 5570 5000 Dominion Boulevard Hog Island Road Glen Allen, Virginia 23060 Surry, Virginia 23883 Office of the Attomey General Chairman Commonwealth of Virginia Board of Supervisors 900 East Main Street of Surry County Richmond, Virginia 23219 Surry County Courthouse Surry, Virginia 23683 Senior Resident inspector North Anna Power Station Mr. R. C. Haag U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1024 Haley Drive Atlanta Federal Center Mineral, Virginia 23117 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Senior Resident inspector Surry Power Station U.S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883

_ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ J

PRELIMINARY

1.0 INTRODUCTION

AND GENERAL DESCRIPTION OF INSTALLATION 1.1 Introduction l This Safety Evaluation Report (SER) documents the U.S. Nuclear Regulatory Commission stafs review and evaluation of the Technical Specifications (TS) and Safety Analysis Report (SAR) for tne proposed North Anna independent Spent Fuel Storage Installation (ISFSI). The

! North Anna ISFSI SAR and app!ication for a 10 CFR Part 72 license were filed by Vircinia l

Electric and Power Company (Virginia Power) and Old Dominion Electric Cooperative (ODEC) on f Aay 9,1995 and were subsequently supplemented from time to time. This SER follows the l format of NUREG-1567, " Standard Review Plan for Spent Fuel Dry Storage Facilities (SRP)."

l The applicants proposed to use a dry cask storage technology in which fuel from the North l

Anna Power Station (NAPS) facility will be stored in cry casks which, in tum, will be emplaced l on a nearby concrete storage pad. The sts#s review of the North Anna ISFSI SAR primar;ly l addresses the safety aspects of cask handling and storage once the casks have left the NAPS I Fuel and Decontamination building. The staff evaluated the North Anna ISFSI SAR and license application against the applicable requirements of 10 CFR Part 72 for spent fuel storage, and 10 CFR Part 20 for radiation protection. The staff also reviewed those aspects of the NAPS design l and operation for transferring spent fuel from the operating reactor facility to the ISFSI which are . I subject to the requirements of 10 CFR Part 50.

l The applicant referenced the TN-32 cask designed by Transnuclear, Inc. as the cask it l proposed to use at the North Anna ISFSI. Tho staff issued a safety evaluation (TN-32 SER) on the Transnuclear Topical Sefety Analysis Report for the TN-32 cask design on November 7, 1996 (TN-32 SAR). The TN 32 is not currently included in 10 CFR 72.214 as approved for use

. under general license. However, as described in this safety evaluation and as conditioned in l License Condition 9 of the North Anna ISFSI license issued to Virginia Power, the TN-32 is

! approved for use at North Anna.

1.2 General Description of Installation The ISFSI will be owned by the applicants and operated by Virginia Power for the purpose of j storing spent nuclear fuel assemblies from NAPS Units 1 and 2 in dry storage casks. The l NAPS spent fuel pool is expected to lose the capacity for single unit full core off-load in 1998, i and additional storage space is necessary for continued operation of NAPS. Virginia Power J

plans to load some of the older assemblies in the spent fuel pool into the dry casks for storage at the ISFSI, thus creating additional pool space for future reactor off-loads. The ISFSI, T6gether with the existing spent fu'el pool, will provide the capacity to store all spent fuel expected to be generated by NAPS Units 1 and 2 during their currert.ly licensed operating periods. The ISFSI will be licensed for an initial term of 20 years, with the possibility of renewal, as stated in 10 CFR 72.42. Storage at the ISFSI is limited to spent fuel assemblies from the NAPS Units 1 and 2 and associated materials related to receipt, storage and transfer where the spent fuel is in the form of UO, clad with zirconium or zirconium alloys as specife' d in License Conditions 6A and 7A.

The ISFSI is located southwest of the NAPS, near the center of the approximately 1043 acres 1-2

l PRELIMINARY which compose the North Anna site. At maximum capacity the facility will consist of three reinforced concrete storage pads; each pad is designed to store up to 28 loaded casks. Based on usage of the TN-32, the facility will be capable of accommodating at least 1824 fuel assemblies, the number of fuel assemblies expected in excess of the capacity of the NAPS spent fuel pool. Each fuel assembly contains approximately 0.46 metric tons of uranium (MTU). 4 Based on the projected number of fuel assemblies to be stored and the uranium content of each assembly, the licensed capacity of the North Anna ISFSI is set at 839.04 MTU. The licensed capacity for the ISFSI is described in Condition 8A of the license. The first storage pad will be constructed in the near term while the second and third pads will be constructed as needed through the life of the ISFSt. The storage pads will be surrounded by a security fence and a perimeter fence. Electricity, provided by the NAPS service system, is the only utility service l necessary for ISFSI operation. Electricity is used for lighting, instrumentation and security ,

I features, but is not required for any safety-related functions. '

The dry storage casks used at the NAPS ISFSI will be right circular cylinders. The model proposed for use at NAPS, the TN-32, is approximately 5 meters (m) high and 2.5 m in

)

diameter, and a single cask can hold 32 assemblies from a pressurized water reactor. The casks weigh nearly 125 tons when fully loaded. The spent fuel is stored in an inert helium gas environment, and baskets within the cask hold the fuel in place. For the TN-32, radiation shielding is provided by a steel shell approximately 20 centimeters (cm) thick, and a borated resin material 11 cm thick. No radioactive materials are released from the casks under any credible accident conditions.

The casks are loaded and prepared for storage inside the Fuel and Decontamination Buildings at the NAPS. Casks are loaded individually under water in the spent fuel pool, then a lid is placed on top and bolted in place. The cask is removed from the pool. The water is then removed from the cask, the interior is vacuum dried and backfilled with helium. After the cask exterior is decontaminated, the cask is carried to the ISFSI by a special transport vehicle.

Casks are placed on the pads with approximately 2.5 m spacing between outer surfaces.

A description of the ISFSI site location and the ISFSI storage features, including proposed use of the TN 32 cask, limit on storage capacity and description of the ISFSI pad are included in Technical Specifications (TS) 4.1 and 4.2. The staff concludes that these TS satisfy the requirement of 10 CFR 72.44(c)(4), Design Features.

1.3 Ider.tification of Agents and Contractors Virginia Power is responsible for the design, engineering, and operation of the North Anna ISFSt. Site preparation and construction will be performed by Virginia Power's Site Services Department, relying on specialty subcontractors as required. Virginia Power will purchase the storage casks from one or more contractors, who design and fabricate the casks under the Virginia Power Quality Assurance Program. Virginia Power presently proposes to use the TN-32 designed by Transnuclear,Inc.

1.4 Materialincorporated By Reference ,

Several documents docketed by NRC serve to support the safety analyses in the North Anna 1-3

l l

PRELIMINARY ISFSI SAR, and are referenced therein. NRC finds all of the following documents suitable for reference in the North Anna ISFSI SAR:

1. Transnuclear, Inc., "TN-32 Dry Storage Cask Topical Safety Analysis Report," Revision 9A, December 1996. (TN-32 TSAR)

2. North Anna Power Station Units 1 and 2 Updated Final Safety Analysis Report, NRC dockets 50-338 and 50-339, submitted July 20,1982. (NAPS UFSAR) as updated .

3. North Anna Power Station Units 1,2,3 and 4, Environmental Repcit, submitted March 1 15,1972.

4. Safety Evaluation Report "TN-32 Dry Storage Cask Topical Safety Analysis Report,"

Revision 9", November 7,1996.

5. Virginia Power Topical Report VEP-1-5A (Updated), Operational Quality Assurance Program Topical Report, submitted July 28,1993, apr oved by NRC on February 28, 1994.

1.6 Evaluation Findings and License Conditions The NRC staff makes the following findings regarding the general description of the ISFSI:

F1.1 The types, state, condition, and aging of radioactive materials to be stored are described ,

in Section 3.1.1 of the North Anna ISFSI SAR. These parameters comply with the limitations given in 10 CFR 72.2 for an 13FSI.

F1.2 The proposed duration of the license is for a fixed period of 20 years, which does not exceed the limit of 20 years for an ISFSI provided by 10 CFR 72.42.

1 l

l I

l l-4

l l

I PRELIMINARY 2.0 SITE CHARACTERISTICS NRC regulations require, at 10 CFR 72.24(a), that each applicant for an ISFSI license provide a description and safety assessment of the proposed ISFSI site. The assessment is to include information regarding the design bases for extemal events as well as an evaluation of the potential for interactions with any co-located nuclear power plant. Detailed siting evaluation factors are specified in 10 CFR 72 Subpart E.

2.1 Site Description 2.1.1 Geography and Demography The North Anna site is in north-central Virginia in Louisa County, approximately 40 miles north-northwest of Richmond. the site is on a peninsula on the southern shore of Lake Anna, a reservoir created by an earth dam approximately 5 miles southeast of the site. The ISFSI location is approximately 2000 ft southwest of the NAPS protected area, and within the boundaries of the North Anna site.

The topography in the site region is characteristic of the central Piedmont Plateau, with a gently undulating surface varying between 200 feet and 500 feet above sea level. The regional vegetation cover is agricultural fields interspersed with forests.

The North Anna site is composed of approximately 1043 acres, excluding the portion of Lake Anna that falls within the site boundary. The ISFSI perimeter fence sections off approximately 11 acres within the site, although the ISFSI controlled area, required in 72.106(a), consists of  ;

the entire 1043 acres within the site boundary. The minimum distance from the ISFSI to the '

controlled area boundary is approximately 2500 feet, much greater than the 100 m minimum required by 72.106(b). The area inside the ISFSI perimeter fence will be graded level, and drainage will be provided by channels to a small creek to the south and west. Therefore, only minimal erosion potential exists at the ISFSI. No trees will stand within the ISFSI perimeter, although existing forest will remain outside of the ISFSI perimeter fence. The threat of forest fire within the ISFSIis thus minimal.

In 1990, the resident population within 10 miles of the North Anna site was about 11,900.

Projected populations within the 10 miles radius for the years 2000,2010,2020, and 2030 are, respectively,14,500,16,500,18,600, and 20,600. A detailed discussion of population, including transient population associated with Lake Anna State Park, is presented in the North Anna ISFSI Environmental Report which was attached to the May 9,1995 license application.

2.1.2 Land and Water Use The area within 5 miles of the North Anna site is largely rural and characterized by farmland and ,

wooded tracts of land. Nearby Lake Anna State Park is used for a variety of recreational activities, such as camping, biking, picnicking, in addition to boating on Lake Anna. Lake Anna is used for recreation, downstream flood control, and as a source of cooling water for the NAPS.

Seven groundwater well provide domestic water for the North Anna site. The closest well to the 2-1 l

PRELIMINARY l l ISFSI site is approximately 1500 feet to the west. The closest offsite well is in a residential area approximately 3500 feet south of the site. A tributary to Sedges Creek lies between this well and the ISFSI, which effectively serves as a hydrologic barrier preventing groundwater movement between the ISFSI and this well.

2.1.3 Nearby industrial, Transportation, and Military Facilities Aside from the NAPS, there are presently no industrial, transportation, or military facilities within 5 miles of the ISFSI site. This includes manufacturing plants, chemical plants and storage facilities, military bases, airports, major water transportation routes or oil and gas pipelines. No expansion of industrial activity within 5 miles of the site is expected within the foreseeable l future. There are no mining activities within 5 miles of the site.

The nearest rail main line passes approximately 5.5 miles from the at its closest point of approach. A spurline connects the site to the main line.

I US Route 522 and Virginia Route 208, both passing within 5 miles of the sito, are the major '

transportation routes in the srea, but no data exist on the types of materials transported over these roads. Virginia Route 700 ends at the NAPS site boundary, and allindus+ rial materials transported on this road are either destined for or originating from the NAPS.

l Three airports lie within 11 mi!es of the site, but they serve only light aircraft.

2.1.4 Hydrology.

2.1.4.1 Surface Hydrology l The preeminent surface hydrologic feature is Lake Anna, created by an earth dam across the

, North Anna River,5 miles southeast of the site. Lake Anna extends approxima.tely 17 miles northwest upstream from the dam. The lake and the NAPS waste heat treatment facility have a surface area over 13,000 acres and contain approximately 100 billion gallons of water.

The headwaters of the North Anna River are in the eastern slopes of the southwester mountains in the Appalachian Range. The North Anna watershed above the dam is 343 square i

miles. The dam is the only control structure on the North Anna River. Downstream of the Lake Anna dam, the river meetc the South Anna River to form the Pamunkey River. Through 1997, the North Anna River had a stream gauge at the bridge where Route 601 crosses the river, about 0.5 miles downstream of the dam. Previously operating gauges were about 15 miles downstream of the dam at Doswell and Hart Comer, Virginia. Table 2.4-1 of the NA ISFSI SAR summarizes discharge data from these stations. The Bear Island Paper Company,26 miles downstream of the NAPS,is the sole industrial user of water below the Lake Anna dam. No other known industrial users draw from this water source until a paper manufacturing plant located 60 miles downstream of the NAPS, after the Pamunkey River merges with the Mattaponi River to form the York River. The only known potable water withdrawal from the North Anna River is the Hanover County treatment plant,24 miles downstream of the NAPS.

l 1

2-2 L___---_----__----------------------------------------------------- ---

PRELIMINARY 2.1.4.2 Subsurface Hydrology The ISFSI site lies within a fairly limited groundwater domain. This domain is bounded by a Sedges Creek tributary on the south and west, the NAPS discharge canal on the east, and Lake Anna on the north. NA ISFSI SAR Figure 2.4-3 shows the ISFSI in relation to these boundaries.

The surface soil, largely saprolite, is a weathering product of the igneous and metamorphic rocks in the region, and the soil thickness ranges from 0 to 125 feet. Groundwater exists under water table conditions, with recharge by precipitation. Water infiltrating beneath the ISFSI site exits the ground as springs within this groundwater domain, or enters Lake Anna directly. Two permanent groundwater monitoring wells are installed down-gradient (south) of the ISFSI site, and one well is installed up-gradient (north). The up-gradient well has an average water table elevation of 296.3 ft above mean sea level, while the down-gradient wells have average elevations of 289.0 ft and 280.3 ft. These averages reflect only a three month period of measurement, so some seasonal variation may not be captured in the readings. The water tab!e gradient to the southwest of the site is approximately 0.01 ft#t., and the gradient to the southeast is approximately 0.02 ft#t. Groundwater infiltrating beneath the ISFSI tends to migrate toward springs in the Sedges Creek tributary, and into Lake Anna.

Water for domestic use at the NAPS is taken from seven wells in the area. The nearest well is l about 1500 ft west of the ISFSI site, outside the groundwater domain containing the site. The nearest off-site water well is in a residential area approximately 3500 ft across the Sedges 4 Creek tributary and well outside the site's groundwater domain. l 2.1.5 Meteorology The regional climate of the site is essentially continental, with warm, humid summers and cool l winters. Temperatures rarely exceed 95 'F or fall below 10 'F. Average annual rainfall is approximately 44 inches, and precipitation is. distributed fairly evenly throughout the seasons.

July and August have the highest average rainfall due to thunderstorm activity. Nearby Richmond, Virginia averages 37 days per year with thunderstorms. Snowfalls in excess of 4 '

inches occur on average once per year, and accumulation rarely remain more than several l days. Richmond averages 14.6 inches of snow per year, Tomadoes are infrequent in the l region. The area within 50 miles of the site experiences on average less than one tomado per l year. As described in Section 2.3.1.3.2 of the North Anna Updated Final Safety Analysis Report  ;

l (UFSAR), the annual probsbi'ity of a tomado striking a given point within the 50 mile radius is l 3.25 x 10-5, or a recurrence interval of 30,800 years.

1 Temperature data for Richmond is considered to adequately represent conditions at the NAPS.

The mean daily average temperature at Richmond has a minimum of 37'F in January, and peaks at 89 'F in July. Richmond temperature extremes are 107 'F in 1918, and -12 'F in 1940. l Frequency distributions of wind speed anel horizontal and vertical atmospheric stability are presented in Tables 2.3-9,2.3-10, and 2.3-11 of the NAPS UFSAR. Local topography is characterized by gently undulating terrain cut by the North Anna River, rising to an average height of 50 feet to 150 feet above the level of Lake Anna.

2-3

I PRELIMINARY 2.1.6 Geology and Seismology The ISFSI site is within the NAPS site boundary, so regional geologic investigations performed and cited during the NAPS licensing process are applicable to the ISFSI. The North Anna ISFSI SAR makes reference to this earlier work, as well as additional geologic investigations conducted since the reactors were licensed. The site lies within the Piedmont Plateau, which is l characterized by undulating topography with as much as 100 feet of relief in the site area. The l Piedmont Plateau is bounded by the Atlantic Coastal Plain,15 miles east-southeast of the site,

, and by the Blue Ridge Province 40 miles to the northwest. Bedrock within the Piedmont is generally metasedimentary and metavolcanic, with some plutonic graniti rocks. The bedrock is typically weathered into a saprolitic cover up to 100 feet thick.

2.1.6.1 Geologic Setting of Site and Surrounding Region l Lithologies in the site region include the Central Virginia Volcanic-Plutonic Belt, the Ta River and Po River Metamorphic Suites, and interlayered mafic and felsic metavolcanics. The volcanic-plutonic belt includes the Fa! mouth Intrusive Suite and the Quantico Formation. The Falmouth Suite is strictly igneous intrusives dated between 300 and 325 million years before present (Ma). The Ordovician Quantico Formation is largely state and porphyroblastic schist, with metamorphic grade increasing to the southwest. The Cambrian Ta River Suite contains a variety of high-grade metamorphic rocks, including amphibolite, gneiss, quartzite, and schist.

As with the Quantico Formation, the grade increases to the southwest. The Po River Suite, east of the Ta River Suite, is primarily gneiss and schist, with subsidiary pegmatoid and granitoid dikes. Based on stratigraphic relationships, the Po River Suite appears to be Proterozoic Z or Early Paleozoic in age. North Anna ISFSI SAR Figure 2.5-1 shows the bedrock lithology of the i ISFSI site. The site is within a unit mapped as an interbedded sequence of homblende gneiss, biotite granite gneiss, and granite gneiss, part of the Ta River Metamorphic Suite.

The site is within a portion of the eastem North American craton that has undergone extensive l tectonic activity since Precambrian time. The region has experienced both compressional and extensional deformation, resulting in a complex pattern of folding and faulting in the bedrock.

There are multiple models explaining the Paleozoic tectonic history of the region, as described in North Anna ISFSI SAR Section 2.5.1.3.2 and UFSAR Section 2.5.2.4 Most recently, the Late Triassic to Early Jurassic continental rifting created numerous down-faulted basins within the Piedmont and Coastal Plain from Connecticut to Georgia. The site is on the northwest flank of a northeasterly trending, gently north-plunging antiform. Boundaries between the lithologic units at the site were affected by flexural slip during Paleozoic compressional events, and l deformation along one of these boundaries formed the Zone A Chlorite Seam studied l thoroughly in 1973 during NAPS construction. Details on this investigation appear in UFSAR Section 2.5.2.4. Several recent borings were drilled at the ISFSI to explore the bedrock l characteristics; the findings confirmed the interpretations made during initial NAPS site investigations and revealed no new structural features. North Anna ISFSI SAR Table 2.5-1 contains details on rock quality values from the borings, and the boring logs are in Appendix l 2.5A.

2-4 l

l.

PRELIMINARY 2.1.6.2 Specific Structural Features of Significance The closest fault to the site is approximately 6 miles west near the tewn of Mineral, Virginia.

The fault has no surface expression. The known fault length is approximately 1000 feet, although projections indicate it could 'se

. as long as several miles, approaching within 4.5 miles of the site.

The Hylas zone, south-southeast of the site and 15 miles west of Richmond, is a group of mylonitic rocks produced by Late Paleozoic ductile shearing. At about 220 Ma, high-angle faulting was superimposed over the Hylas shear zone. This was synchronous with the Triassic rifting along the eastem seaboard.

The Spotsylvania lineament is a northeast-trending aeromagnetic anomaly separating the Ta River metamorphic suite to west and the Po River metamorphic suite to the east. This l lineament, approximately 10 mikes southeast of the NAPS, is most likely a fault formed during or prior to the regional metamorphism. The lineament is directly on strike with the Stafford fault system, but it is not believed to be structurally related. The minimum age of any slip along the lineament is 100 Ma.

The Stafford fault system is a series of en echelon, high angle reverse faults displacing both the Piedmont Paleozoic rocks and the overlying Coastal Plain sediments. The fault system strikes northeast, extending more than 33 miles along the Virginia Fall Line and the northeast-trending portion of the Potomac River. In Virginia, the system is aligned with the Spotcylvania magnetic

l. lineament. The Stafford system makes its closest approach to the site 14 miles northeast, near Fredericksburg, Virginia. Slip along the fault system began in the Early Cretaceous, and offsets as young as Late Pliocene have been reported. However, a detailed mapping and trenching study in 1976 identified the youngest slip on the fault system as pre-mid-Miocene, so the system is not considered capable by the definition of Appendix A to 10 CFR Part 100.

The Mountain Run fault zone is a northeast-trending physiographic feature, taking the form of a fault scarp in the Unionville, Virginia quadrangle. The fault zone is thought to be a suture between a Cambrian island arc and its back-arc basin against ancestral North America. Some reactivation of this zone may have occurred as recently as post-Pliocene time.

Recently, a series of extensional faults were discovered in Giles County, Virginia, about 220 i miles west-southwest of the site. Seismicity related to the Giles County fault zone is ongoing,  !

although ground motion at the NAPS from this fault zone is extremely unlikely given the l distance from the site.

l 2.1.6.3 Site Investigations l

Eight borings were drilled at the ISFSI site; locations are shown in North Anna ISFSI SAR  !

Figure 2.5-2. In addition, seven shallow borings were drilled along the transporter route to the j ISFSI pad. Boring logs showing elevation and depth of samples, penetration resistances, soil

{

stratum description and Uniform Classification, and groundwater data are contained in North i Anna ISFSI SAR Appendix 2.5A. Several undisturbed soil samples were also collected for laboratory testing. Logs of wells drilled for groundwater monitoring are also contained in 2-5

L.

PRELIMINARY Appendix 2.5A. Rock core samples were collected below levels where soil boring was ineffective. Boring logs in North Anna ISFSI SAR Table 2.5-1 contain the percentage of core recovery and rock quality designation values.

Geophysical surveys and studies were performed to evaluate bedrock structure and stratigraphy  :

in the area prior to licensing the NAPS, and the results are summarized in UFSAR Section 2.5. I 2.1.6.4 Geologic Profiles l

The typical soil profile at the ISFSI site consists of surface clay minerals chemically weathered from foldspars, micas, and mafic minerals in the parent metamorphic rock. At depth these minerals become less weathered, retaining their inter-particle bonding. There is a gradual transition from fine-grained to more granular soils with depth. In addition, the boundary between

• soil and rock is transitional. Rock depth in the ISFSI borings, as defined by auger or spoon refusal, ranges from 245 feet to 272 feet in elevation. The bedrock encountered in the cores j confirms the previous bedrock interpretations made in 1973. No slickensides have been L

observed on any fractures in retrieved core, suggesting an absence of fault slip in the immediate area. North Anna ISFSI SAR Figure 2.5-3 provides a profile of soil and rock l stratigraphy across the site.

I l 2.1.6.5 Engineering Properties of Soil and Rock i

i The following tests were performed on selected soil samples, and the results are found in North L Anna ISFSI SAR Appendices 2.5A and 2.5B: particle size analysis: Atterberg limits; natural l

moisture content; moisture density determination; Califomia bearing ratio; consolidation test; l triaxial shear test; unconfined compression test; and constant head permeability. The properties of the soil samples collected during ISFSI site investigation are very similar to those i documented in the UFSAR from initial NAPS site investigations. No tests were performed on l rock samples collected during ISFSI site characterization. The rock physical properties are not important to ISFSI stability, as the rock lies at least 30 feet below the surface, and the incremental load on the rock from the concrete pads and storage casks will be very small. No additional dynamic analyses were performed during ISFSI investigation, since the data from borings and laboratory tests are so similar to those gathered during construction of the dam and g the NAPS. Dynamic soil and rock properties for the NAPS are in Section 2.5 of the UFSAR. A l shear modulus of 1g,800 psi and Poisson's ratio of 0.3 were used in the design of the storage

pads.

l 2.1.6.6 Analysis techniques and Calculated Results The design minimum safety factor against a soil bearing capacity failure is 3.0. The factor of safety calculated for an ISFSI pad bearing on stiff residual soil is significantly greater than 3.0.

Settlemer:t estimates were derived from immediate elastic and long-term consolidation j settlement of underlying residual soil. Such estimates have a record of inaccuracy when  !

compared with actual measured subsidence, so calculations were performed using empirical equations as well. Based on results of the two methods, total pad settlement is estimated to be less than 1.5 inches under a full load. The estimate assumes no more than 5 feet of overburden will be removed prior to construction, wheraas the actual overburden removed for l

2-6 l

PRELIMINARY the first pad may be as much as 10 feet (greater overburden removal equates with less settlement). The 1.5 inch estimate is also conservative in that it assumes the total load on the pad will be placed in a single increment, whereas casks will actually be placed incrementally over several years.

2.1.6.7 Vibratory Ground Motion The NAPS is located in the north-central portion of the Piedmont Plateau, a northeast-trending belt of metamorphic rocks extending from Alabama to New Josey. Earthquakes occur with less frequency in this province in comparison with the Blue Ridge and Valley and Ridge Provinces to the west. Within the Piedmont Plateau and the Coastal Plain Province to the east, seismic activity tends to cluster in three areas: the South Carolina-Georgia region; the Fall Zone in the Delaware-New Jersey areti, and central Virginia. The NAPS lies on the northem boundary of the central Virginia zone of activity. The majority of this activity lies in an east-west zone 30 miles south of the NAPS. Historically, the central Virginia seismic zone has experienced 2-10 events per decade, with most earthquakes having Modified Mercalli (MM) intensity between lli and V. The largest historical earthquakes affecting the NAPS site were in 1774'near the Richmond Basin (MM intensity VI-Vil), and in 1875 near the Arvonia Syncline (MM Vil). The 1875 event likely caused ground motion at the NAPS site of MM intensity V, in other words ground motion adequate to break windows and cause fragile objects to fall. A complete description of the seismic history of the site area is in Appendix 2G of the UFSAR.

The fault zone underlying the NAPS reactor buildings is of limited extent, and it dnes not meet the criteria of a capable fault found in Appendix A of 10 CFR Part 100. An extensive micro-earthquake monitoring system was deployed in the Lake Anna area in the ig70s for the purpose of studying possible micro-earthquakes associated with this fault or the impoulxhent of Lake Anna. A reduced monitoring effort is ongoing, and no historic seismic activity can be

! shown to have any direct tectonic relationship to the fault zone underlying the NAPS site.

The design earthquake ground motion for the NAPS assumes that the largest historical earthquake associated with the Arvonia Syncline occurs close to the NAPS. Such a MM intensity Vil event would cause a peak horizontal acceleration of 0.12 g at a rock surface.

Amplification effects increase the design acceleration to 0.18 g at the surface of saprolite ,

greater than 18 feet thick. Eight to ten pulses of strong ground motion is a conservative I estimate for the design earthquake at the NAPS. Response spectra appear in Figures 2.512 through 2.5-15 in the UFSAR. Additional investigations and seismic data since the licensing of the NAPS reactors do not suggest any need to modify the original design eenhquake ground l accelerations for the site. i 2.1.6.8 Surface Faulting No evidence suggests that any of the historic earthquakes in tfw Piedmont Plateau or the entire Appalachian region have caused faulting at or near the surface.

2.1.8.9 Subsurface Stability Earth materials encountered at the North Anna Power Station (NAPS) were categorized into five 2-7 i

! PRELIMINARY zones based on the general structural characteristics of each. Zone llA saprolite appeared to contain zones of soil that were potentially liquefiable. Main plant structures were partially supported by the zone llA saprolite and partially founded on sound rock or compacted granular l backfill. According to the exploratory borings performed by Dames and Moore (D&M) in 1968, l the average thickness of saprolite across the NAPS site was approximately 40ft.

l The applicant did not specifically calculate factors of safety against liquefaction under the ISFSI pad. Rather, the applicant submitted an analysis of liquefaction, entitled " Soil Failure /

Liquefaction Susceptibility Analysis for North Anna Power Station (NAPS) - Seismic Margin Assessment, December 1994) (Liquefaction Report) which was performed for the NAPS site to support conclusions regarding liquefaction under the ISFSI pad.

The NUREG/CR-0098 soil spectrum normalized to 0.3g zero period acceleration was used in the liquefaction analysis for the NAPS facilities. However, since the ISFSI is a new facility, the staff determined that the standards in Reguistory Guide (Regulatory Guide (RegGuide)) 1.60, i

" Design Response Spectra for Seismic Design of Nuclear Power Plants," based on the North Anna site design earthquake (0.18g) were the appropriate licensing standards. NUREG/CR-l 0098 entitled " Development of Criteria for Seismic Review of Selected Nuclear Power Plants" published in 1978, was primarily intended for the review of seismic issues for plants under the Systematic Evaluatior. Program.

To justify the conservatism of the liquefaction analysis using the NUREG/CR-0098 and a 0.3g PGA, the applicant submitted, by letter dated December 16,1998, a study which compared the

, amplified response spectrum values for NUREG/CR-0098 horizontal spectrum normalized to L 0.3g PGA and RG1.60 horizontal spectrum with a 0.18g PGA. Both cases used 5% damping.

l The study showed that the NUREG/CR-0098 response spectrum itself was less conservative than the Regulatory Guide 1.60 response spectrum. However, due to the big margin of 0.3g over the 0.18g as seismic input, the combined amplified response spectrum values using i-NUREG/CR-0098 spectrum envelope those using the RG 1.60 response spectrum. Therefore, the liquefaction analysis was conservative and therefore acceptable with respect to licensing l

under 10 CFR Part 72.'

In the Liquefaction Report, the applicant assumed a Review Level Earthquake (RLE) with a peak horizonts! ground acceleration of 0.3g and seismic characteristics consistent with the seismic design spectrum described in NUREG\CR-0098,

• Development of Criteria for Seismic Review of Selected Nuclear Power Plants." The Liquefaction Report, which was generated to  ;

support the applicant's responsa to Generic Letter 88-20, Supplement 4, specifically evaluated  !

liquefaction susceptibility under main plant structures such as the main steam valve house, auxiliary building, service building and turbine building and under the service water reservoir area.

Three approaches were used in the liquefaction assessment of the soils at NAPS site: (1) a  !

l l

I No statements made in this Safety Evaluaten Report regarding the use of NuREG-0098 and the applicants Liguefacten i Report should be taken as a staff conclusion regarding the acceptatulily of the applcant's response to l Genenc Letter 86 20, Supplement 4.

• individual Plant Examsnaten for External Emnts " 1 2-8

)

O PRELIMINARY simplified procedure based on Standard Penetration Testing (SPT), (2) threshold shear strain analysis, and (3) cyclic triaxial testing. Approaches (1) and (2) were used for the main plant area and approach (3) was used for the Service Water Reservoir area. All the three approaches are current state-of-practice techniques. For the main plant structures, the resulting factors of safety ranged from 1.54 to 3.51 against liquefaction, showed no liquefaction damage or related effects, and showed that significant pore pressure generation was not likely to occur. For the Service Water Reservoir area, Cyclic Triaxial Tests were performed on the undisturbed samples l in the vicinity of the pump house and in the general area. The liquefaction resistance 1

associated with these samples was used to estimate the factors of safety. The resulting factors of safety ranged from 1.51 to 1.99.

Although an evaluation of safety margins to soil liquefaction for the ISFSI pad was not i specifically performed, all evaluated North Anna Power Station facilities were shown to have l high factors of safety against liquefaction. Therefore, it was reasonable to conclude that liquefaction would not occur for the ISFSI.

2.2 Safety Assessment of Site 2.2.1 Industrial and Transportation Events The largest credible rail or highway transportation accident is the explosion of an 8,500 gallon gasoline tank truck at the closest approach of Virginia Route 652,1.5 miles from the ISFSI site.

Based on the application of Regulatory Guide 1,91 and the information provided by the licensee regarding equivalent TNT weight of gasoline, the staff agrees that the expected over pressure from such an explosion would be less than 1 psi at the ISFSI site. In the TN-32 SER for the TN-32, the staff previously acknowledged that the TN-32 is designed to withstand a 25 psi over pressure. Thus, the staff concludes that the postulated gasoline tank truck explosion 1.5 miles from the North Anna ISFSI would have negligible effect on any TN-32 in use at the ISFSI.

2.2.2 Flooding The potential for flooding of the ISFSI site is evaluated below for several flood initiating events.

2.2.2.2 Precipitation Events '

The ISFSI general site grade is 311 ft. above mean sea level; the top elevation of the storage pads will be 311.5. The ISFSI access road west of the facility is graded from 332 ft. down to 311 ft. into the site. The area outside the ISFSI boundary generally slopes to the south toward a tributary of Sedges Creek, which feeds into Lake Anna. North Anna ISFSI SAR Figure 2.4-2 shows the grading plan for the ISFSI site.

During heavy precipitation events, the ISFSI site will be drained by a gradual, fine grading away from the storage pads, and a combination of earthen and concrete channels. These channels, which appear in North Anna ISFSI SAR Figure 2.4-2, are designed to accommodate runoff from a 100-year precipitation event. Hydrodynamic loading and flooding of the storage pads is not credible based on the 100-year storm.

2-9

PRELIMINARY Due to the ISFSI site elevation relative to Lake Anna, and the conservative design of the storm drainage facilities in the site area, the staff concluded that site is flood-dry.

2.2.2.2 Probable Maximum Flood (PMF) on Streams and Rivers As discussed in the NAPS UFSAR Section 2.4.1, the normal water level of the North Anna I

reservoir is 250 feet. As discussed in Section 2.4.3 of the NAPS UFSAR, and in the NA ISFSI SAR, the maximum calculated water level at the plant site for the PMF is 267.3 ft mal. The staff previously reviewed and found acceptable these calculated water levels as documented in the l OL-SER and in Supplement 2 to the OL-SER (Reference X). Accordingly, based on the ISFSI l grade level being established at 311 ft mst, which is 60 feet above normal water level and 45

! feet above PMF lake level, the staff concludes that the ISFSI site is adequately protected from j the affects of floods on nearby lakes and rivers.

2.2.2.3 Potential Dam Failures (Seismically induced)

! The Lake Anna dam is the only dam on the North Anna River. The only water impoundments l that may be upstream of the dam are small farm ponds. Failure of such structures would produce no noticeable effect on the Lake Anna water level. The staff concludes that because the ISFSI elevation relative to the elevation of Lake Anna, and because of the lack of significant upstream impoundments, the ISFSI site would be unaffected by flood levels due to the seismically induced failure of dams.

2.2.2.4 Probable Maximum Surge and Solche Flooding The ISFSI site is 311 feet above mean sea level, and approximately 76 miles upstream of tidal influence. Therefore, the staff concludes flooding from a storm surge is not credible.

Furthermore, as the site is not near a semi-enclosed bay or harbor, the staff concludes that seiche flooding due to water oscillation is impossible.

2.2.2.5 Probable Maximum Tsunami Flooding l l Due to the inland location of the ISFSI site, the staff concludes that tsunami flooding is not credible.

2.2.2.8 Ice Flooding The ISFSI site is approximately 60 feet above the normal level of Lake Anna. Based on this elevation above the lake, the staff concludes that no credible build-up of ice on Lake Anna could have an effect of the ability of the ISFSI site to drain properly.

2.2.2.7 Flooding Conclusions and Requirements Based on the discussion in Sections 2.2.2.2 through 2.2.2.6 above, the staff concludes that the design and location of the North Anna ISFSI is adequate to preclude flooding, meets the requirements of 10 CFR 72, Subpart E as it pertains to flooding, and is therefore, acceptable.

2-10

PRELIMINARY 2.2.3 On-site Meteorological Measurement Program The NAPS has a meteorological monitoring station which will provide monitoring for the ISFSI.

The monitoring program is described in detail in NAPS UFSAR Section 2.3.3. The primary meteorological tower is approximately 3500 feet northeast of the ISFSI site. This distance, in addition to the intervening topography, heat sources, and service water reservoir, prevents the heat source in a fully loaded ISFSI from affecting tower readings.

The on-site meteorological data will not be used to estimate off-site effluent concentrations, as no credible mechanism for the release of airbome effluents from the ISFSI ha:, been postulated.

j However, X/Q dispersion values have been calculated, in accordance with Regulatory Guide 1.145, for use in the dose assessment of airbome releases during accident scenarios. These values appear in Table 2.3-1 of the North Anna ISFSI SAR. The maximum site boundary X/Q value is in the southeast sector,1100 m from the ISFSI site.

2.2.4 Groundwater Contamination Groundwater in the local domain will not be affected by operation of the ISFSI, as the facility produces no liquid, solid or gaseous effluents.

I 2.3 Evaluation Findings and License Conditions The NRC staff makes the following findings regarding the site characteristics of the ISFSI:

l F2.1 The SAR provides an acceptable description and safety assessment of the site on which

!. the ISFSI is to be located, in accordance with 10 CFR 72.24(a).

F2.2 The proposed site complies with the criteria of 10 CFR 72 Subpart E, as required by 10 CFR 72.40(a)(2).

l l

l 2-11 )

1 \

l l l

i

PRELIMINARY l 3.0 PRINCIPAL DESIGN CRITERIA NRC regulations require, at 10 CFR 72.24(c), that 0 ch spp!! cant for an ISFSI license provide a l description of the proposed ISFSI design, including design criteria and applicable codes and l standards. The presentation is to address the design criteria specified in 10 CFR 72 Subpart F l including any additions to or departures from the criteria in Subpart F.

l 3.1 MaterialTo Be Stored The applicant has proposed to store fuel which has been used at the North Anna Power Station at the North Anna ISFSI. The applicant proposed that stored fuel be limited to intact fuel l assemblies, which do not have gross cladding defects and which do not have visible physical damage which precludes insertion or removal from an SSSC. In a letter dated April 1,1998, the applicant proposed that these limitations be included as Technical Specification 2.1.1. In a

! letter dated May 28,1998, the applicant poposed that TS 2.1.1 be further revised to specifically l l

exclude the loading of burnable poison rod assemblies and thimble plugging devices. In Table 3.1-1 of the North Anna ISFSI SAR, the applicant provided detailed information on the design of the fuel assemblies which are to be stored.

i The applicant also proposed specific limits on certain design and operational variable associated with each assembly. Specifically, the applicant proposed the following limits:

i j Parameter Limit (1) Maximum initial enrichment S 3.85 weight %

(2) Average bumup 540,000 MWD /MTU l

(3) Maximum decay heat per assembly 5 0.847 kw/ assembly (4) Post discharDe cooling time 17 years (5) Gamma source per cask 5 2.31 X 10" photons /second (6) Neutron source per cask 54.83 X 10' neutrons /second l (7) Fuel assembly design Westinghouse 17 x 17 Standard Westinghouse 17 x 17 Vantage 5H The applicant proposed that the limits on these variable be documented in the Table 2.1-1 o the ISFSI Technical Specifications as referenced in 1.1(c). The applicant also proposed a TS requirement, TS 2.2, specifying the actions to be taken if one of the Functional and Operating Limits of TS 2.1.1 were violated. Those actions include obtaining NRC approval to resume loading and transport activities after the violation.

3.2 Classification of Structures, Systems and Components (SSCs) 3-1 L _ ----- - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _

PRELIMINARY In 10 CFR 72.3, the term "SSCs important to safety" is defined as follows:

Those features of the ISFSI...whose function is :

(1) To maintain the conditions required to store spent fuel.... safely, (2) To prevent damage to the spent fue!...during handling and storage, or (3) To provide reasonable assurance that spent fuel...can be received, handled, i packaged, stored and retrieved without undue risk to the health and safety of the public.

In Section 4.5 of the North Anna ISFSI SAR and in a letter dated May 28,1998, the applicant stated that the SSSCs (i.e., the TN-32 cask) and the handling equipment used during loading and unloading (cask lift beam and cask lid lifting toois) are considered important to safety. The applicant stated that the Virginia Electric and Power Company Operational Quality Assurance

- Program Topical Report program, discussed further in Section 16 of this SER, apply to that {

equipment. The applicant states that none of the other systems including the storage pad, i fence, monitors (i.e., pressure monitors), wiring and lights perform a safety function. The l applicant further states that the transporter is not considered important to safety because the SSSCs are designed to withstand the failure of the transporter. The applicant stated that the cask handling crane and auxiliary crane are to be included under the programmatic control of the NAPS "NUREG 0612 Heavy Loads" program.

l Based on its review of the North Anna ISFSI SAR and previous experience with dry cask loading and the TN-32, the staff concludes that the applicant has adequately identified those SSCs which are important to safety.

3.3 Design Criteria for SSCs That Are important to Safety in Chapters 3 and 4 of the North Anna ISFSI SAR, the applicant specified the design criteria for various SSC's associated with handling and storage of spent fuel at North Anna. Table 3.4-1 of  !

the SAR lists the design criteria used by the applicant in selection of an SSSC. Table 4.2-1 summarizes the applicants proposed means for complying with the individual design criteria  !

specified in Subpart F. The staff's evaluation of the applicant's design criteria against the requirements of Subpart F is presented below.

3.3.1 Quality Standards l The applicant proposed that the standards in its existing Quality Assurance (QA) program i

. regarding the design, fabrication and delivery of safety related equipment be applied to design, fabrication and delivery of the SSSC's and handling equipment. The staff has previously '

reviewed the applicant's QA program pursuant to 10 CFR 50.54. Because of the p comprehensive nature of the applicant's QA program and the applicant's experience with that program, the staff concludes that the proposed application of the existing QA program to ISFSI SSCs is acceptable for demonstrating compliance with the requirements of 10 CFR 72.122(a).

A more detailed review of the Quality Assurance program applied to the ISFSI is described in j Section 15 of this SER.

3-2

PRELIMINARY 3.3.2 Protection Against Environmental Conditions and Natural Phenomena The applicant proposed design criteria for the SSSC related to seismic considerations, high ambient temperature, exposure to sunlight and extreme winds and missiles as listed in Table

,14-1 of the North Anna ISFSI SAR.

For solar heat load, the applicant proposed a design criteria of 800 g-cal /cm' for flat surfaces r

and 400 g-cal /cm for curved surfaces. This criteria is equivalent to the criteria of 295C 3TU#t and 1475 BTU #t* for flat and curved surfaces previously reviewed by the staff during its review of the TN-32 TSAR and is therefore acceptable.

For ambient temperature, the applicant proposed a criteria of -20'F to 115Y. This is identical to the criteria previously reviewed by the staff during its review of the TN-32 TSAR and is therefore acceptable.

For seismic peak acceleration, the applicant proposed maximum peak acceleration values of 0.18g for horizontal motion and 0.12g for vertical motion. An analysis of cask performance under seismic conditions is provided in Section 6 of this SER.

With regard to wind loading, the applicant nroposed tomado wind design criteria of combined l rotational and transnational wind speed of 360 mph. This value was equal to the combined wind L speed of 360 mph contained in and approved for TN 32 SAR. The combined tomado wind

speed criteria in the NA ISFSI SAR is equivalent to the criteria evaluated in the TN-32 SAR and is therefore acceptable.

For wind driven missiles, the applicant proposed to use the design basis missiles from the NAPS UFSAR as the design basis missiles for the North Anna ISFSI. These missiles differ from those used in the TN-32 TSAR. In a letter dated May 18,1998, the applicant summarized the

' effects of the North Anna design basis missiles with respect to three phenomena. Those l phenomena are cask sliding, cask tipping and cask penetration. The summary showed that the TN 32 missile analysis bounded the consequences for the worst case North Anna design basis l missile. The staff concluded therefore, that the design basis missiles proposed by the applicant  ;

l are acceptable.

With respect to flooding, the applicant described that the ISFSI site is flood free. Therefore, the applicant did not propose any additional design criteria for the ISFSI with regard to floods. As discussed in Section 2 of this SER, the staff accepts the licensee's analysis with regard to the

ISFSI site being flood dry and therefore finds agrees that no further design criteria are

! necessary to protect against flooding.

l With respect to snow and ice loadings, the licensee concluded that snow and ice loading did not pose a credible challenge to the spent fuel SSSCs. The applicant stated that decay heat from the stored spent fuel would cause expected snow and ice to melt on contact with the SSSC.

Therefore, the applicant stated that no further design criteria for the ISFSI were necessary to address the effects of snow and ice loading. As discussed in Section 2 of this SER, the staff accepts the applicant's analysis with regard to snow and ice loading and therefore agrees that no further design criteria are necessary to protect against snow and ice loading.

3-3

_ _ _ -_ _ _ _ _ . . . _ _ ~ . _ _ __ _ . . _ _ __ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

PRELIMINARY Based on the above discussions on flooding, seismic conditions, tomado and wind driven missiles, and snow and ice loadings, and temperature extremes, the staff concludes that the applicant has proposed sufficient design criteria for protection against environmental conditions and environmental phenomenon as required by 10 CFR 72.122(b)(1) and (b)(2). The meteorological data collection facilities described in the NAPS UFSAR satisfy the requirements of 10 CFR 72.122(b)(3).

In Section 3.3.2.1, the applicant proposed to use SSSCs whose confinement integrity is assured under credible she conditions (the TN-32) as the means for precluding the transport of radioactive material into the environment via a major water sources. The staff finds this enteria consistent with the requirement of 10 CFR 72.122(b)(4).

3.3.3 Fires and Explosion The applicant proposed criteria to ensure that SSC's important to safety are able to perform their safety function under credible fire conditions. The applicant proposed that design features be used to ensure that a fuel fire associated with the backup diesel generator located within the ISFSI security fence is prevented from propagating to the ISFSI (i.e., to the pad and the SSSCs). Satisfaction of this criteria is further discussed in Section 11 of this SER. The staff finds the proposed use of design features that preclude the propagation of a fire to the ISFSI important to safety SSCs consistent with the criteria of 10 CFR 72.122(c).

With regard to explosions, the applicant discussed potential sources of explosions in Chapter 2 of the North Anna ISFSI SAR. The applicant stated the siting of the ISFSI ensured that the peak over pressure from the maximum credible explosion remained less than the design pressure for the selected SSSC. The staff concluded that the combination of site location and design pressure for the selected SSSC are sufficient criteria to be consistent with the criteria of 10 CFR 72.122(c) with regard to explosions.

3.3.4 Sharing of Structures, Systems and Components To address the effect of sharing of ISFSI SSC, the applicant proposed the criteria that all ISFSI activities be performed without jeopardizing the safe shutdown capability of the North Anna Units 1 and 2 reactors. The staff considers this an acceptable criteria for the sharing of SSC consistent with the criteria of 72.122(d).

3.3.5 Proximity of Sites The applicant proposed to show that, consistent with 72.122(e), the design and operation of the NA ISFSI result in minimal additional risk to public health and safety. ,

3.3.6 Testing and Maintenance of Systems l

The licensee proposed to use an SSSC that requires no periodic maintenance other than minor adjustment of instruments or minor touch-up of the SSSC outer coatings. The licensee indicated that certain periodic surveillance of the selected SSSC would be performed. The staff finds these criteria consistent with the criteria of 72.122(f).

l 3-4 l

PRELIMINARY 3.3.7 Emergency Capability in a letter dated May 18,1998, the applicant indicated that access to the ISFSI the ISFSI is adequate for emergency responders who may be required to respond to the ISFSI. This is consistent with the criteria of 10 CFR 72.122(g).

3.3.8 Confinement Barriers and Systems 10 CFR 72.122(h) requires that the spent fuel must be protected against degradation that leads to gross ruptures or the fuel must be otherwise confined such that degradation of the tuel will not pose operational problems with respect to removal from storage.

The applicant proposed to use an SSSC for which it considers no path for release of radioactive material to be credible under all conditions for the duration of the license. The applicant proposed to backfill the SSSC with helium and establish a minimum backfill pressure to protect against long term degradation of the fuel under normal storage conditions.

The staff considers these criteria consistent with 72.122(h)(1) and (h)(5). Establishment of these criteria negates the need for ventilation criteria pursuant to 72.122(h)(3). Since the licensee has not proposed to store the fuel in a pool, criteria pursuant to 72.122(h)(2) are not applicable. The applicant proposed a continuous monitoring system for the confinement consistent with 72.122(h)(4). However, since the applicant proposed to use a SSSC whose confinement is leak tight under all credible conditions, the applicant proposed the monitoring system be considered not important to safety. The staff concludes the design criteria proposed by the applicant are consistent with the criteria of 10 CFR 72.122(h).

3.3.9 Instrumentation and Control The applicant proposed to use SSSC for which no instrument or control systems are required to perform the intended safety functions. The staff finds this consistent with the requirements of 10 CFR 72.122(l).

3.3.10 Control Room The applicant proposed that no control room or control area are necessary to monitor or contml the safe operation of the ISFSI. To the extent that the proposed SSSCs are designed to passively perform their safety functions under normal and accident conditions, the staff finds the applicants proposed criteria regarding the absence of an ISFSI control room is allowed by 72.122(j).

3.3.11 Utilities or Other Services The applicant proposed to use SSSCs that do not rely on utility supplies and systems (such as electrical or water systems) to ensure that safety functions are performed under normal and accident conditions. The applicant proposed to install non important-to-safety electric power for the purpose of lighting, general utility and SSSC sealinstrumentation. These functions are not necessary to ensure that the SSSC can perform its safety function. Therefore, the applicant 3-5

PRELIMINARY proposed that utility systems be neither redundant nor able to withstand a single failure. To the extent that the TN-32 has been previously reviewed and found a:ceptable by the staff in this regard (TN-32 SER Section 11.3), the staff concludes that the proposed ISFSI utility systems design criteria are consistent with 72.122(k).

3.3.12 Retrievability The applicant proposed to use an SSSC, the TN-32, whose fuel can be unloaded in the North Anna spent fuel pool and retrieved for further handling consistent with 72.122(l).

3.3.13 Criticality Safety The applicant proposed a design criteria that subcriticality be maintained at all times with the assumption of s single active failure or credible passive failure. The applicant proposed that the effective neutron multiplication factor be maintained less than 0.95. The staff considers this consistent with the criteria of 72.124(a).

3.3.14 Methods for Criticality Control The applicant proposed to rely on the criteria for criticality control provided for the selected SSSC and did not propose additional design criteria or features of its own. The staff finds use of the SSSC specified design criteria acceptable and consistent with 72.124(b).

3.3.15 Criticality Monitoring The applicant proposed to perform all spent fuel handling under water in the spent fuel pool and to store the fuel dry in the selected SSSC. Therefore, consistent with 72.124(c), criteria for criticality monitoring were not required. 1 3.4 Design Criteria for Other SSCs Subject To Ap,,roval 3.4.1 Concrete Storage *ad l

Codes and standards used in the design and analysis of the pad include:

(1) ACl 349," Code Requirements for Nuclear Safety Related Concrete Structures (2) ANSI /ANS 57.9," Design Criteria for an Independent Spent Fuel Storage Insta!!ation (Dry Storage Type)"

(3) BOCA,"The BOCA National Bu!! ding Code" (4) ASCE 7, " Minimum Design Loads for Buildings and Other Structures

• Material properties were referenced to ASTM standards. The above cited codes and standards are commonly used commercial standards and are considered acceptable by the staff.

3-6 w______________________- _

PRELIMINARY 3.4.2 Transporter Codes and Standards used in the design of the transporter include various ASTM standards as listed in Table 4.3-1 of the North Anna ISFSI SAR. These are commonly used commercial codes and are considered acceptable to the staff.

3.5 Evaluation Findings

F3.1 As described above, the SAR includes design criteria in sufficient detail to support a finding that the criteria are consistent with the criteria of 10 CFR Subpart 72 Subpart F, except whers noted, in compliance with 10 CFR 72.24(c). This finding is based on a review which considered the regulatory requirements, appropriate Regulatory Guides, applicable codes and standards and accepted engineering practices.

I l

3-7

PRELIMINARY 4.0 INSTALLATION FUNCTION AND OPERATING SYSTEMS 4.1 Regulatory Requirements Requirements regarding the overall function of the ISFSI and the operation of certain separate functional subsystems are detailed in the design criteria in 72.24,72.40(a),72.122(h)-(l),

72.124(c),72.126(b)-(d) and 72.128(a). Functions and functional subsystems reviewed in this chapter of the Safety Evaluation include those associated with receipt, preparation, loading, trmsfer, storage, maintenance and retneval of the stored spent fuel.

This review was performed according to Chapter 4 of NUREG-1567, Standard Review Plan for Spent FuelDry Storage Facilities.

4.2 Operation Description i

In Chapter 5 of the North Anna bFSI SAR, the applicant describes two primary operations associated I with storage of spent fuel at the ISFSI. These operations are cask loading and cask unloading. Although I operations to load the cask in the spent fuel pool, prepare it for storage, and transfer the cask to outside the Decontamination Building are subject to the requirements of Part 50 and subject to the conditions of the NAPS Part 50 operating license, those activities are integral with spent fuel dry storage activity.

Thus, those activities are recounted in Chapter 5 of the North Anna ISFSI SAR and are recounted here.

De applicant's narrative description and itemized sequence ofloading operations in Chapter 5 of the North Anna ISFSI SAR encompass the major tasks associated wPh dry cask storage including (1) receipt of the empty cask from the manufacturer, (2) preloading inspection and cask preparation, (3) transfer of the empty cask into the spent fuel pool (SFP), (4) loading and verification of spent fuel assemblies, (5) removal of the cask from the SFP and removal of water from the cask, (6) sealing, vacuum drying and helium backfill of the loaded cask, (7) decontamination of the cask exterior, (8) transport of the cask to the ISFSI pad, and (9) verification of adequate surface radiation measurements and verification of confinement integrity.

In Table 5.1-1 of the North Anna ISFSI SAR, the applicant provided a tabular flowsheet listing the significant steps needed to load a cask. The applicant also referenced the cask loading flowsheet in the specific SAR for the chosen cask which in this case is the TN-32. The staff reviewed the narrative descriptions of the cask loading operation and, based on previous staff observation of TN-32 cask loading ,

operations, concluded they were acceptable. '

The applicant also described potential unloading operations including (1) transport from the ISFSI pad to the Decontamination Building, (2) sampling of the cask atmosphere to test for fuel degradation,(3) placement of the cask into the SFP, (4) reflooding of the rask,(5) removal of the cask lid, (5) removal of the spent fuel back to the SFP and (6) removal and decontamination of the cask. In a letter dated April 14,1997, the applicant described that it would closely monitor cask internal pressure during the reflood -

process. The applicant specifically stated that steps would be taken to test for indication of fuel failure l prior to loosening the lid bolts during an unloading operation.

Based on the above, the staff concludes that the descriptions of the proposed functions and operaiing i

4-1

i l

PRELIMINARY systems with regard of stored radioactive material from storage are acceptable and comply with 10 CFR l 72.122(l).

j 4.2 Fuel Handling Systems l

The NAPS and North Anna ISFSI include systems and components necessary to handle the storage cask during the loading phase and during transport to or from the ISFSI pad.

4.2.1 NAPS Cask Handling Equipment

! As described in the NAPS UFSAR, a 125 capacity trolley crane is installed in the Fuel and Decontamination Buildings and is capable of lifting a loaded TN-32 cask from the spent fuel pool to the concrete surface outside the Decontamination Building. The trolley is designed to the standards of ANSI-832.2.01967, Safety Code for Overhead and Gantry Cranes and Specification for Electric Overhead Traveling Cranes for EOCl Service Class A.

As described in the soplicant's letter dated April 14,1997, a lift beam is used for lifting and moving the cask to vs.,ious station areas, including to the spent fuel pool. The lift beam

, attaches to the 125 ton trolley crane using pins through a hole in the crane hook. The lift beam l attaches to the upper trunnions of the cask with two air operated arms. A locking mechanisms l ensures that the arms remain firmly attached to the trunnions during lifts. Movement of the arms and engagement of the locking mechanism is accomplished with a remote control unit.

The lift beams are made from carbon steal and stainless steel components. The carbon steel components are painted to prevent corrosion from immersion in the pool. The lift beam assembly contains a test device to allow performance of necessary lift tests.

i 4.2.2 Transporter System

]

- The applicant proposed to use a towed transporter frame vehicle to move the cask from the Decontamination Building laydown area to the ISFSI storage pad. The transporter consistent of a large A-frame assembly equipped with fixed and cteerable tires as well as braking and cask lifting systems. The transporter is to be towed by a pull vehicle through the use of a towing bar assembly.

The transporter lifts the cask through use of a configuration of hydrau!!cally driven lifting arms

, which lift the cask via the cask trunnions. The hydraulic system is powered by an electrically

! driven hydraulic pump. Flow control valves in the hydraulic system control the rate at which the cask can be lowered. Hydraulic lock valves prevent the cask from being accidentally lowered during transport. In a letter dated April 23,1998, the applicant described that the cask is

! prevented from being lifted more than 15" above the ground surface by mechanical stops

~ internal to the hydraulic control system. In addition, the applicant proposed a Technical Specification (TS 3.1.5) limiting the lifting height of the cask to no more than 18" above the ground.

With regard to functions important to safety, the TN-32 is analyzed for end drops of up to 18" and for cask handling tip over events onto a concrete storage pad. The cask was analyzed for the impact of such drops on the ability to maintain a subcritical configuration, the ability to 4-2 l

PRELIMINARY remove fuel from the cask after the event and the ability to maintain confinement. In the TN 32 SER for the TN-32, the staff concluded that the cask will perform adequately for cask drops of not more than eighteen inches provided the pad is not more than 3 feet thick, with a concrete strength not greater than 4,000 psi and for a soil modulus of elasticity not more than 40 kai.

Actual North Anna ISFSI pad conditions are evaluated in Section 11 of this SER.

l Based on the applicant's proposed design features and Technical Specification controls which

! ensure the not lifted more than eighteen inches while in the transporter, the staff concludes that

the North Anna transporter will adequately assure the design drop analytical assumptions are satisfied. The staff further concludes that the proposed design and operation of the transporter is in compliance with 10 CFR 72.128(a) with regard to ensuring adequate safety under normal and accident conditions.

4.3 Operation Support Systems Although the casks proposed by the applicant, the TN-32, is designed to maintain confinement integrity under normal and accident conditions through the period of the license, the inter-seat region is monitored by a pressure monitoring transducer system. As described in the North Anna ISFSI SAR and as further described in a letter dated May 18,1998, the system includes two pressure switches per cask wired to provide separate inputs to a programmable logic controller (PLC). When the interlid pressure falls below at preset value, due to either a leak of the inner seat or a leak of the outer seal, the PLC will provide output to an annunciator display panel via a fiber optic modem and to the NAFS Central Alarm Station (CAS) via a relay. The PLC includes self checking features that will provide indications to the annunciator panel and the CA. The annunciator panel provides indication of which cask and which pressure switch is in an alarm state and provides indication for a faulted PLC condition. Upon loss of power to a particular pressure switch the annunciator will show an alarm condition for the affected cask and switch. Upon loss of power to the PLC, the annunciator panel will show all pressure switches in an alarm condition. Upon loss of power to the Annunciator Panel, the panel will be blank. All low pressure conditions or loss of power conditions described above will cause a single ISFSI cask status alarm in the CAS. Although not important to safety itself, tne pressure menitoring system provides an acceptable capability to test and monitor components important to safety and satisfies the requirements of 10 CFR 72.128(a)(1).

In order to minimize of prevent fuel degradation while in long term storage, the cask cavity is evacuated and then backfilled with helium during the loading process. As described in the NAPS UF3AR, the applicant has installed a vacuum drying system and a helium system in the Osontamination Building. The vacuum system consists of two parallel vacuum pumps along with necessary filters and monitoring equipment. The helium system consists of a rack for l helium bottles, regulating equipment and monitoring equipment.

Electric power is provided for area lighting, receptacles, security equipment and the pressure monitnring system. The electric power supply is not considered important to safety since power is not required to satisfy any safety functions at the ISFSI. The electric power supply is not connected nor shares components with the NAPS Class 1E power system. A backup diesel j generater is provided at the ISFSI to supply power in the event of an extended power loss.

4-3

PRELIMINARY The utility systems described above are not required during any accident conditions to perform a safety function. By implementing a cask design that does not rely on utility services to perform a safety function under emergency or accident conditions, the applicant has satisfied the requirements of 10 CFR 72.122(k).

4.4 Control Room or Control Area The cask pi oposed by the applicant, the TN-32, does not require continuous surveillance and monitorir,g to ensure its safety functions are performed during normal, off normal or postulated l accident conditions. Therefore, the applicant has proposed not to install a control room or i

control area at the ISFSIitse!f.

As discussed above, the applicant has indicated that the seal function of the TN-32 will be continuously monitored by pressure instruments which monitor the pressure between the inner and outer cask seals. These instruments will alarm at a local alarm panel which is located at the ISFSI site. In its April 14,1997 submittal, the applicant stated that an alarm at the local alarm panel will activate an alarm within the Station Security Central Alarm Station and Secondary Alarm Station. Upon receipt of an alarm, security staff will notify the Control Room Shift Supervisor who will direct operators to check the cause of the alarm including potential electronic fault, failed sensor or actual failed cask seal and will initiate appropriate corrective action.

Normal loading and unloading operations will take place in the North Anna Fuel Building and l Decontamination Building under local control in coordination with the NAPS control room staff.

Based on previous review of the design of the TN-32 and review of the North Anna ISFSI SAR information described above, the staff concluded that a specific control room for the ISFSI is not i necessary and that operations to control and monitor cask conditions as proposed by the applicant are adequate to meet the requirements of 10 CFR 72.122(j).

4.5 AnalyticalSampling.

As described in the ISFSI SAR, no gaseous or liquid effluents are expected from the operation of the ISFSI during either normal or o#-normal operation. Therefore, provision of means of l monitoring and measuring the amount of radio nuclides in effluents during normal operation or accident conditions, to comply with 72.122(h)(3), are not required. Nevertheless , the applicant stated that the count room, portable instrumentation, personnel monitoring instruments and support facilities associated with the North Anna Power Station health physics lab will be available to support operation of the ISFSI. The applicant stated that the above facilities meet the guidance of Regulatory Position 4 of Regulatory Guide 8.8. Use of Reg Guide 8.8 facilities at NAPS to support the ISFSI will provide sampling and analysis capability for normal and off l normal operation of the ISFSI over and above that required by the regulations and is therefore l acceptable to the staff.

4.6 Cask Repair and Maintenance The licensee has proposed to use a cask, the TN-32, which requires no scheduled maintenance 4-4

PRELIMINARY during its operating life. The applicant has stated that the cask will be inspected in detail during the receipt process prior to loading. In addition, the applicant stated that the machine shops associated with the North Ann Power Station are available to perform any necessary minor repairs.

Once placed in service, the TN-32 does not require periodic maintenance other than touching up defects in the outer coatings and adjustments of the seal monitoring instruments (which are not required to assure a safety function) on an as-needed basis.

I L

4.7 Evaluation Findings

l The NRC makes the following findings with regard to installation functions and functional subsystems:

l F4.1 The North Anna ISFSI SAR includes acceptable descriptions and discussions of the l projected operating characteristic, in compliance with 10 CFR 72.24(b).

l F4.2 By implementing a cask design that does not rely on utility services to perform a safety l function under emergency or accident conditions, and by implementing utility systems l

that do not share components with the NAPS, the applicant has satisfied the requirements of 10 CFR 72.122(k).

! F4.3 The descriptions of the proposed functions and operating systems with regard of storect .

radioactive material from storage are acceptable and comply with 10 CFR 72.122(l). l l F4.4 The pressure monitoring system provides an acceptable capability to test and monitor I components important to safety and satisfies the requirements of 10 CFR 72.128(a)(1).

l l F4.5 The operating procedures and schedules for operation for the ISFSI acceptably provide i for control during storage operations to be accomplished from the NAPS control room ,

[ facility and for control during loading, transfer and unloading to be maintained in the Fuel l and Decontamination buildings for which there are acceptable provisions included in the design. This is considered to acceptably comply with 10 CFR 72.122(j).

l 4-5

l PRELIMINARY 5.0 Wat,te Confinement and Management Requirements regarding the safe confinement and management of any radioactive waste

generated by the facility and the management of the release of radioactive materials in effluents l to the environment are detailed in 10 CFR Part 20 and 10 CFR 72.104,72.106,72.122,72.126 l and 72.128. The ISFSI must be designed to limit the levels of radioactive materials released in effluent to as low as reasonably achievable. In addition, the design must minimize the quantity of radioactive wastes generated.

i This review was performed according to Chapter 6 of NUREG-1567, StandartiReview Plan for l SpentFuelDry Storage Facilities 1

[ 5.1 Waste Sources j

! . I As described in Chapter 6 of the NA ISFSI SAR, some amounts of liquid and solid radioactive j wastes will be generated during loading, decontamination and other preparatory actions prior to  !

storage. Contaminated spent fuel pool water used to fill the cask during the loading operation will be drained back to the spent fuel pool (SFP) prior to moving the cask from the fuel pool area j to the decontamination area. As described in the NAPS UFSAR, SFP water contaminants are removed through a series of filters and ion exchangers connected with the fuel pit cooling and purification system.

1 A detergent / water mixture is used decontaminate exterior surfaces of the cask subsequent to  !

removing the cask from the SFP. This decontamination activity results in the generation of  !

small amounts of liquid waste. This liquid waste is directed to the NAPS Fluid Waste Treatment System and is subsequently transferred to the NAPS liquid waste disposal system.

l During the loading and decontamination activities, a small amount of low-level solid waste may l

be generated as well. The solid waste would consist in part of anti-contamination clothing, rags, plastic sheeting and tape. As described in Chapter 11.5 of the NAPS UFSAR, such solid waste j material is compacted into 55 gallon drurns, and retained on the NAPS site until it is shipped for  ;

l final disposal either by incineration or by burial at a disposal site. The staff concludes that use of NAPS facilities for the processing of solid and liquid wastes generated during cask loading and decontamination activities satisfies the requirements of 10 CFR 72.128(b). .

During transport to the ISFSI pad and during storage at the ISFSI, no radioactive waste material l is generated by the use of the TN 32 cask. The cask is a passive design, requiring no active

! systems to assure adequate decay heat removal and to assure adequate confinement. The I proposed cask, the TN-32, requires no intrusive periodic maintenance. The only periodic  ;

maintenance involves examination of the cask surface for surface imperfections and possible maintenance of the pressure monitoring system components. This passive design greatly minimizes the volume of radioactive waste that could be generated by the operation of the ISFSI compared to other potential ISFSI designs. The staff concludes that the applicants proposed use of the TN-32 cask satisfies the requirements of 10 CFR 72.128(a)(5). The SAR description of solid and liquid radioactive waste management satisfied the requirements of 10 CFR 72.24(1).

5.2 Offgas Treatment and Ventilation 5-1

PRELIMINARY As described in the NA ISFSI SAR, potentially contaminated air and helium will be purged from the cask during vacuum drying, helium backfilling and leak testing activities. Such ,

contaminated vented gas will be processed by the Fuel and Decontamination Building '

- ventilation systems. As described in the NAPS UFSAR, this ventilation system has in-series particulate and charcoal filter banks to scrub radioactive contaminants from the exhaust i

ventilation stream.

As part of the cask loading operation, the loaded cask is lifted from the spent fuel pool to the j decontamination area in the decontamination building. This lift is performed using the cask handling crane. Once cask decontamination is accomplished, the cask is lifted to outside the Decontamination building using the cask handling crane. The applicant recognized that the cask crane rigging equipment (slings, cables and hook) would be immersed in the spent fuel pool during cask loading becoming potentially contaminated in the process and would traverse to the outside environment during the course of a cask loading operation. In letters dated April 23,1998 and May 29,1998, the applicant addressed the spread of potential contamination from the cask crane rigging equipment. The applicant proposed to construct a crane enclosure outside the Decontaminating Building to shelter the cask crane from the weather thereby limiting the means by which contamination could be spread from cask handling equipment to the environment. The applicant proposed to complete construction by December 31,1999. This commitment is identified as License Condition 16. In the interim, the applicant proposed to use temporary measures, including procedural limitations to prevent crane use outside of the Decontamination Building during adverse weather conditions; decontamination of the crane hook, lift beam, and cables prior to moving cask outside; and follow-up surveys of the outside ana.

Once removed to the storage pad, the TN-32 cask is designed to be leak tight under all normal and accident conditions. Thus, no gaseous effluents are expected during storage operations at the ISFSI. The confinement capability of the ISFSI is further described in Chapter 10 of this SE.

Based on the above, the staff concludes that the applicant has provided sufficient design features and controls to ensure the confinement of airborne radioactive particulate during normal and off normal conditions in compliance with 10 CFR 72.122(h)(3). In addition, based on the above, the staff concludes that the proposed design and operation of the NA ISFSI satisfies the requirements of 10 CFR 72.126(d). Because no effluents are expected under normal or accident conditions, the requirements of 10 CFR 72.126(c)(1), regarding measurement and dilution of effluents, are considered not applicable 5.3 Waste Treatment and Retention l

The processing of liquid and solid radioactive wastes generated during loading and decontamination activities was described in Section 5.1 above and was found to satisfy the requirements of 10 CFR 72.128(b).

6.4 RadiologicalImpact of Normal Operations Although the North Anna ISFSI is located next to a major water resource, no liquid radioactive 5-2

PRELIMINARY materials will be present at the ISFSl. As described in Chapter 2 of the SER, the site is not susceptible to any surface flooding. Further, as described in Chapters 10 and 11 of this SER, there are no credible scenarios by which liquid or gaseous effluents could be released from the storage casks. Therefore, the staff concludes that the requirements of 10 CFR 72.122(b)(4) are met.

5.5 Evaluation Findings

F5.1 The North Anna ISFSI SAR adequately describes acceptable features of the ISFSI design and operating modes that reduce to the extent practical the radioactive waste volume generated by the installation, in compliance with 10 CFR 72.24(f) and 10 CFR 72.128(a)(5).

FS.2 The North Anna ISFSI design and procedures provide acceptable measures to preclude the transport of radioactive materials to the environment through aquifers,in compliance with 10 CFR 72.122(b)(4).

FS.3 Use of NAPS facilities for the processing of solid and liquid wastes generated during cask loading and decontamination activities satisfies the requirements of 10 CFR 72.128(b).

F5.4 The design of the ISFSI provides acceptable means to limit to levels as low as is aasonably achievable the release of radioactive materials in effluents during normal operation and to control the release of radioactive materials under accident conditions, in compliance with 10 CFR 72.126(d).

F5.5 The waste confinement and management activities described in the SAR suppor+ a conclusion that the activities authorized by the license can be conducted without endangering the health and safety of the public, in compliance with 10 CFR 72.40(a)(13).

5-3

PRELIMINARY 6.0 INSTALLATION DESIGN AND STRUCTURAL EVALUATION Requirements regarding the safe confinement and management of any radioactive waste generated by the facility and the management of the release of radioactive materials in effluents to the environment are detailed in 10 CFR Part 20 and 10 CFR 72.104,72.106,72.122,72.126 and 72.128. The ISFSI must be designed to limit the levels of radioactive materials released in effluent to as low as reasonably achievable. In addition, the design must minimize the quantity of radioactive wastes generated.

NRC staff acceptance criteria for structural design are detailed in Chapter 7 of the SRP.

6.1 Summary Description l The applicant proposed to use an array of TN-32 cesks placed on a reinforced concrete pad for storage of spent fuel from the NAPS. The staff conducted a review of the structural design of the NA ISFSI reinforced concrete pad as described in Section 6.3 below. The staff previously performed a detailed review of the TN-32 structural design as summarized in Section 6.2 below.

The staff did not perform a specific structural analysis of cask handling equipment such as lifting beams and the transporter vehicle. For the cask handling equipment, the staff reviewed previous analyses in the NAPS UFSAR which bounded the consequences of the failure of cask

, handling equipment within the NAPS facility. For the transporter, the staff reviewed the l applicant's proposed design and administrative controls in the NA ISFSI application which  ;

ensured that the TN-32 would not be handled in excess of analyzed parameters during I

transport. The staff concluded that the applicants description of the structural design for the ISFS! satisfied the requirements of 10 CFR 72.24(a), (b), (c) and (d).

6.2 Confinement Structures, Systems and Components The applicant has selected the TN-32 as the cask it will use upon initial licensing of the ISFSI.

The detailed structural analysis of the TN-32 cask including the cask body and basket are l presented in Chapter 3 and Appendices 3A,3B and 30 of the TN-32 TSAR. The staff .

! performed a detailed review of the structural analysis. The staff's evaluation and conclusion are i presented in Section 3 of the TN 32 SER. In the TN-32 SER, the staff made the following summary findings regarding the structural analysis of the TN-32:

. [The TN-32] storage systems are designed to allow ready retrieval of spent fuel for further processing or disposal. No accident or natural phenomena events analyzed will result in damage that will prevent retrieval of the fuel.

l The cask is designed and fabricated so thSt the spent fuel is maintained in a suberitical I

condition under credible conditions. The configuration of the fuel is unchanged.

The cask and its systems important to safety are evaluated to demonstrate that they will reasonably maintain confinement of radioactive material under normal, off normal, and credible accident conditions.

6-1

PRELIMINARY The staff concludes that the structural design of the TN-32 is in compliance with 10 CFR Part 72 and that the applicable design and acceptance criteria have been satisfied. The structural evaluation provides reasonable assurance that the TN-32 will enable safe storage of spent fuel. This finding is based on a review that considered the regulation  :

itself, appropriate regulatory guides, applicable codes and standards, accepted practices, and staff confirmatory analysis.

By letter dated May 28,1998, the applicant submitted a revised lid bolt analysis for the TN-32.

The analysis was revised to correct errors identifed by the cask vendor such as incorrect stress intensity values and stress comparisons, and uses the same methodology as was employed in the approved TN-32 TSAR. Therefore, the staff did not undertake a specific review of the revised analysis. The revised analysis concludes that the code allowable stresses on the bolts are not exceeded for both normal and accident conditions. As stated above the staff previously concluded that the structural design of the TN-32 is in compliance with 10 CFR Part 72 and that the applicable design and acceptance criteria have been satisfied.

6.3 Reinforced Concrete Structures The North Anna ISFSI includes three concrete storage pads, each 224-by 32 feet in area, on which the loaded casks will be placed. Forty feet long concrete ramps on each end of the pad are installed to enable the cask transporter to gain access to the pad. The overall area of the pad is 304'x32'. Each storage pad is designed to accommodate 28 TN 32 casks arranged in fourteen rows of two casks with a center-to-center spacing of 16 feet in both directions. The pad is a 24" thick reinforced concrete slab. The concrete is to be of the normal weight with a compressive strength (fc') of 3000 psi. The re-bars are to be ASTM materials with a yield strength (fy) equal to 60 ksi.

6.3.1 Static Analysis In a letter dated February 17,1998, the applicant forwarded calculations which supported the design of the reinforced concrete ISFSI pad. The static analysis of the storage pad was performed to ensure that the pad has been designed to adequately support the static load of the stored casks. The storage pad design was analyzed using the images-3D finite element computer program. Codes and standards used in the design and analysis of the pad included:

(1) ACI 349, " Code Requirements for Nuclear Safety Related Concrete Structures (2) ANSI /ANS 57.9,' Design Criteria for an Independent Spent Fuel Storage Installation (Dry Storage Type)"

(3) BOCA, "The BOCA National Building Code' l

l

(# ASCE 7, " Minimum Design Loads for Buildings and Other Structures

• Material properties were referenced to ASTM standards. The above cited codes and standards i '

are commonly used commercial standards and are considered acceptable by the staff.

6-2 i

I

PRELIMINARY In the computer analysis, the soil stiffness was modeled as vertical transnational springs placed at each node of the model. Each cask weight (250 kips) was modeled as five 50-kip leads at five nodes based on tributary area of the model. Loads, load combinations and design limits for the pad were in accordance with ANSI /ANS 57.9 which included wind load and tomado wind load. Loads from cask transporter were also cor sidered. All the cask loads and transporter loads were treated as live loads in the analysic, which carried a load factor of 1.7 in the load combinations. The load factors helped increase the design loads and hence the design stresses for the concrete and the re-bars. -

The storage pad was analyzed for five cask loading pattems in order to determine the maximum bending stress in the pad and for re-bar design. The maximum concrete stress occurred with the pad loaded with two center casks. Similarly, in evaluating the effect of cask transporter loads, the pattem with the transporter at the edge of the storage pad yielded the maximum stress in the pad among all the transporter load cases. Still, it was the loading with two center casks that produced the maximum bending stresses in the pad.

Design wind load was determined at a 100 year recurrence level in accordance with ASCE 7-88, with a speed of 70 MPH. The design tomado wind load with a maximum speed of 360 MPH was used to determine loads on the casks, cask sliding and overtuming, and the effect on the pad. Both the design wind load and the design tornado wind load conditions were separately analyzed and calculated, their results were determined to be not critical.

The potential for cask sliding and overturning was also analyzed. The sliding and overtuming analysis assumed a 7' cask diameter instead of 8', the actual cask diameter. This yielded conservative results for the factors of safety against sliding and overtuming. ,

As a result of the analyses and the calculations, the final re-ba, layouts was to be #10 at 12" each way at top and bottom of the slab. The maximum concrete bending stress was determined to be 350 psi resulting from the load case of two center casks at the pad center.

The static analysis for the North An.N ISFSI has been reviewed. The staff determined that the ISFSI pad design appeared to satisfy the design bases with adequate margin of safety. The codes and standards used were appropriate, thus meeting the requirements of CFR 72.24 (c)(3), and (c)(4). Also, the pad was designed to quality standards commensurate with the safety of function which meet the requirements of CFR 72.122(a). The pad was designed to accommodate normal and postulated accident conditions, and to withstand the effects of natural phenomena which meet the requirements of CFR 72.122 (b)(1) and (b)(2).

The methodologies, loads and load combinations, calculations and site evaluations for the pad statical analysis appeared to be in compliance with the pertinent requirements defined in CFR 72.40(a)(i; and (a)(2). Therefore, the structural analysis demonstrated that the pad is capable of supporting the static ^ cask loads.

6.3.2 Dynamic Analysis A dynamic analysis was performed to determine the effect of the 0.18g desigri earthquake (DE) on the stored casks and the concrete pad. A finite element model using the computer code 6-3

l l PREOMINARY SASSI was developed. The reinforced concrete slab was modeled by plate elements and the casks by rigid beams with their masses lumped at their center of gravity. Due to the symmetry of the pad, only a quarter of the pad was modeled.

The best estimate of soil profile was developed based on the soil boring logs underneath the l pads. The soil time- histories corresponding to the DE motion for the North Anna Power Station

) were used as the seismic input for the soil-structure interaction analysis (SSI) defined at l elevation 310'.

l As described below, the applicant evaluated the potential for sliding or overtuming of the casks as well as the stresses generated in the pad by seismic motion.

l 6.3.2.1 Cask Sliding and Overturning From the time-history analysis, the accelerations and forces in the three directions for each node (cask) at each time increment were computed. The cask stability was analyzed using the three directional accelerations. As a result, the lowest factor of safety for sliding was slightly higher than one, and the lowest factor of safety for overturning was 1.6 based on the three l components of accelerations. However, since the three components of the input were uncoupled, estimate of the factors of safety for sliding and overtuming were re-calculated by l using the 100%,40%,40% of the maximum responses for each direction as recommended in j ASCE Standard 4-86, Seismic Analysis of Safety-Related Nuclear Structures and Commentary  :

l I

on Standard for Seismic Analysis of Safety-Related Nuclear Structures". The factors of safety i for sliding and overturning obtained using the ASCE Standard 4-86 approach were 1.17 and l

2.04 respectively, which are larger than the recommended value of 1.1 specified in NUREG-1535, " Standard Review Plan for Dry Cask Storage Systems" and are therefore acceptable to the staff. l l

6.3.2.2 Stress Calculation Computer module STRESS was used to calculate the seismic axial forces, in-plane shear l forces and bending moments at all plate elements (pad) and in the beam elements (casks). The

, seismic maximum stresses due to each of the threo components of the input motion were calculated and combined using the SRSS techniques as recommended in Regulatory Guide

! .1.92. However, the moments and forces at the concrete pad were small and did not control the design of the slab.

6.3.2.3 Verification of SASSI Code l A model consisting of beam and plate elements was selected for SASSI code verification.

j SASSI code and CLASSI code, a QA verified soli structure interaction computer code were used to analyze the same model. The results showed that for in-structure accelerations at the foundation; in-plane stresses , plate bending moments in plate elements; and the axial and shear forces, and bending moments in beam elements; both computer codes yielded very close results for the duration of the time histories.

The approach used and the results obtained for verifying SASSI computer code is acceptable.

6-4 l

I PRELIMINARY 6.3.3 SollLiquefaction Earth materials encountered at the North Anna Power Station (NAPS) were categorized into five zones based on the general structural characteristics of each. Zone llA saprolite appeared to contain zones of soil that were potentially liquefiable. Main plant ctructures were partially suppor+ed by the zone llA saprolite and partially founded on sound rock or compacted granular ,

backfill. According to the exploratory borings performed by Dames and Moore (D&M) in 1968, l the avorage thickness of saprolite across the NAPS site was approximately 40ft.  ;

l The applL ant did not specifically calculate factors of safety against liquefaction under the ISFSI l pad. Rather, the applicant submitted an analysis of liquefaction, entitled " Soil Failure /

i Liquefaction Susceptibility Analysis for North Anna Power Station (NAPS) - Seismic Margin Asussment, December 1994) (Liquefaction Report) which was performed for the NAPS site to support conclusions regarding liquefaction under the ISFSI pad.

The NUREG/CR-0098 soil spectrum normalized to 0.3g zero period acceleration was used in the liquefaction analysis for the NAPS facilities. However, since the ISFSI is a new facility, the staff determined that the standards in RegGuide 1.60, " Design Response Spectra for Seismic Design of Nuclear Power Plants," based on the North Anna site design earthquake (0.18g) were the appropriate licensing standards. NUREG/CR-0098 entitled " Development of Criteria for Seismic Review of Selected Nuclear Power Plants" published in 1978, was primarily intended for the review of seismic issues for plants under the Systematic Evaluation Program.

To justify the conservatism of the liquefaction analysis using the NUREG/CR-0098 and a 0.3g PGA, the applicant submitted, by letter dated December 16,1998, a study which compared the amplified response spectrum values for NUREG/CR-0098 horizontal spectrum normalized to l 0.3g PGA and R.G.1.60 horizontal spectrum with a 0.18g PGA. Both cases used 5% damping.

The study showed that the NUREG/CR-0098 response spectrum itself was less conservative than the Regulatory Guide 1.60 response spectrum. However, due to the big margin of 0.3g over the 0.18g as seismic input, the combined amplified response spectrum values using NUREG/CR-0098 spectrum envelope those using the RG 1.60 response spectrum. Therefore, the liquefaction analysis was conservative and therefore acceptable with respect to licensing under 10 CFR Part 72.2 l In the Liquefaction Report, the applicant assumed a Review Level Earthquake (RLE) with a l peak horizontal ground acceleration of 0.3g and seismic characteristics consistent with the l

seismic decign spectrum described in NUREG\CR-0098, " Development of Criteria for Seismic Review of Selected Nuclear Power Plants." The Liquefaction Report, which was generated to support the applicant's response to Generic Letter 88-20, Supplement 4, specifically evaluated liquefaction susceptibility under main plant structures such as the main steam valve house, auxiliary building, service building and turbine building and ursder the service water reservoir 2

No statements made in this Safety Evaluation Report grding the use of NuREG-0098 and the appicants Liquefaden Report should be taken as a stafr conclusion regarding the acceptabihty of the apphcant's response to Generic Letter 88-20, Supplement 4. individual Plant Examination for Extemal Events.*

6-5

PRELIMINARY area.

Three approaches were used in the liquefaction assessment of the soils at NAPS site: (1) a

! simplified procedure based on Standard Penetration Testing (SPT), (2) threshold shear strain analysis, and (3) cyclic triaxial testing. Approaches (1) and (2) were used for the main plant area and approach (3) was used for the Service Water Reservoir area. All the three approaches are current state-of-practice techniques. For the main plant structures, the resulting factors of safety ranged from 1.54 to 3.51 against liquefaction, showed no liquefaction damage or related effects, and showed that significant pore pressure generation was not likely to occur. For the l Service Water Reservoir area, Cyclic Triaxial Tests were performed on the undisturbed samples

! in the vicinity of the pump house and in the general area. The liquefaction resistance I associated with these samples was used to estimate the factors of safety. The resulting factors L of safety ranged from 1.51 to 1.99.

Although an evaluation of safety margins to soil liquefaction for the ISFSI pad was not {

! specifically performed, all evaluated North Anna Power Station facilities were shown to have high factors of safety against liquefaction. Therefore, it was reasonable to conclude that liquefaction would not occur for the ISFSI.

The dynamic analysis for the North Anna ISFSI has been reviewed The staff determined that  !

the requirements of CFR sections 72.102 (c), (d) and (f)(1) regarding geological and i

! seismological characteristics, and natural phenomena protection were met. In addition, the staff l concluded that the requirements of 10 CFR sections 72.122 (b)(2) and (b)(3) regarding the i

aMdy of structures, systems and components to withstand natural phenomena were met. The

(= tors of safety for sliding and overtuming met the recommended values of 1.1 specified in l NUREG-1535, " Standard Review Plan for Dry Cask Storage Systems". The finite element l modeling and computer codes used were satisfactorily benchmarked for various types of l structural analyses.

l The loads, load factors and load combinations, the structural analyses and the design were in generalin accordance with ANSI /ANS-57.9, ASCE 7, and ACI 349.

Seismic stress combinations were consistent with RG.1.92. The recommendations defined in ASCE 4-86 " Seismic Analysis of Safety-Related Nuclear Structures and Commentary on Standard for Seismic Analysis of Safety-Related Nuclear Structures for combining the three directional accelerations were acceptable.

l The prediction methods used for liquefaction analysis were within commonly used industrial l practice. Since the NAPS site facilities were shown to have high factors of safety against l liquefaction, it is reasonable to judge that liquefaction is not likely to occur for the ISFSI which is on the same site with other NAPS facilities.

6.4 Other SSC Important to Nuclear Safety As stated in Section 4.5 of the NA ISFSI SAR, certain cask handling equipment used during loading and unloading is considered important to safety because the cask are not designed to withstand their failure. The cask handling equipment under consideration is operated within the 6-6

\ .

PRELIMINARY confines of the North Anna Power Station structures up to the point that the cask is placed in the transporter for removal to the ISFSI (i.e. to the concrete pad).

The staff did not undertake a specific structural review of the cask handling equipment used within the NAPS because the consequences of a cask drop accident within the NAPS are analyzed and presented in Chapter 15A of the NAPS UFSAR.

Chapter 15A of the North Anna UFSAR describes an analysis of the consequences of drcpping a loaded TN-32 outside the cask loading area of the NAPS. The applicant revised the NAPS UFSAR to reflect an analysis of the drop of a loaded TN-32. The staff did not review the applicant's calculations. The applicant concluded that the radiological dose consequences for a dropped cask are less tilan one rem whole body and less than one rem thyroid. These results appear consistent with the results of a hypothetical total loss of confinement described in l

Chapter 8 of this SER. The calculations supporting the UFSAR change remain subject to review under the provisions of the NAPS Part 50 license.

6.5 Findings

l F6.1 The design, design bases, layout and relation to the site conditions of the ISFSI are adequately described in the NA ISFSI SAR and are acceptable in compliance with 10 CFR 72.24.

F6.2 The applicant's proposed design complies with the requirements of 10 CFR Subpart F, l

as required by 10 CFR 72.40(s)(1).

l l

6-7

i PRELIMINARY 7.0 THERMAL EVA1.UATION The objective of the thermal review is to ensure that the temperatures of the stored fuel material and of SSCs important to safety remain within the allowable values or criteria for normal, off-normal, and accident conditions consistent with the regulatory requirements of 10 CFR 72 Subpart F. The applicant proposes to use the TN-32 spent fuel sterage cask at the North Anna ISFSI. To perform its review, the staff comparea the key thermal assumptions, bounding site characteristics and environmental conditions, and cask-ISFSI interface requirements identified in the TN-32 TSAR sections applicable to the North Anna ISFSI design and environmental conditions.

This review was performed according to Chapter 8 of NUREG-1567, Standard Review Han for Spent FuelDry Storage Facilities.

7.1 Heat Removal System The TN 32 thermal design criteria for normal conditions is specified in Section 2.3.2.2 of the TN-32 TSAR. Section 4 of the TSAR describes the heat removal system as completely passive.

The decay heat is transferred from the fuel assemblies to the outer environment by conduction, convection, and radiation. The helium in the cask cavity aids in the transport of decay heat from the fuel assemblies to the cask inner wall. The TSAR considered casks stored on unenclosed concrete pads with a 16 foot center-to-center spacing.

In chapter 4 of the TN-32 SER, the staff found that the SSCs important to safety were described in sufficient detail to enable evaluation of the effectiveness of their thermal performance. The j ,

staff also concluded that the TN 32 is designed with a heat removal capability having testability l and reliability consistent with its importance to safety, as required by 10 CFR 72.24 (c)(3) and 72.128(a)(4).

The North Anna ISFSI is a passive mstallation consisting of an unenclosed concrete pad.

Section 4 of the North Anna ISFSI Technical Specifications (TS) specifies certain desigr features of the ISFSI. The TS specify that the nominal center-to-center spacing for the storage casks is sixteen feet. The only design change to the TN 32 proposed by the applicant is the use of shims between the inner vessel flange and the outer gamma shield. This change was described in the applicant's letter dated May 18,1998. The shims do not affect the TN 32 thermal analysis. The staff concluded that the TN 32 is designed with a heat removal capability having testability and reliability consistent with its importance to safety and that the North Anna ISFSI does not adversely impact the heat removal capability; in compliance with 10 CFR 72.128(a)(4).

i 7.2 Thermal Loads and Environmental Conditions Section 2.1 of the TSAR describes the design basis fuel characteristics and the design basis extemal environmental conditions. The design basis fuel characteristics include (1) an initial maximum average decay heat per spent fuel assembly of 0.847 kW (27.1 kW total per cask) and (2) a 7-year minimum cooling time. These characteristics are consistent with an ir;tial enrichment of 3.85% and a maximum everage burnup of 40,000 MWD /MTU. The bounding 7-1 V

PRELIMINARY extemal environmental storage conditions are listed in table 2.5-1 of the TN-32 TSAR.

Minimum and maximum ambient temperatures of -20*F to 115'F were assumed respectively.

Maximum solar heat loads for flat and curved surfaces of 2950 and 1474 BTU /ft respectively were assumed. Section 11.2.4 of the TN-32 TSAR states that the cask is designed to withstand 25 psi extemal pressure. Section 11.2.5 of the TSAR also describes the extemal conditions assumed for the TN-32 accident condition of a fire. The only fire considered is a 200 gallon fuel fire from the transporter. The analysis demonstrated that the assumed fire does not compromise the containment integrity of the TN-32.

In Section 4 of the TN-32 SER, the staff concluded that the spent fuel cladding is protected against degradation that leads to gross ruptures by maintaining the cladding temperature for 7-year cooled PWR fuel below 348' C and by maintaining an inert helium environment. The staff found that these measures, along with the basket structural design features protect the cladding against degradation which will allow retrieval of spent fuel for further processing or disposal.

This is in compliance with 10 CFR 72.122(h)(1).

The bounding extemal environmental storage conditions for the North Anna ISFSI are listed in Table 3.4-1 of the North Anna ISFSI SAR. The minimum and maximum assumed environmental temperatures are -20*F and 115' F which are the same as those considered in the TN-32 TSAR. Additionally, the heat loads for flat and curved surfaces (direct exposure to sunlight) are also the same as those considered in the TN-32 TSAR. With respect to fuel characteristics, Table 2.1-1 of the North Anna ISFSI TS lists the fuel functional and operating limits. These limits as the same as those considered in the TN-32 TSAR.

The ISFSI includes a backup diesel generator and its associated monitored, double walled fuel tank within the ISFSI security fence. This combustible source was not considered in the TN-32 TSAR. However, this tank has a maximum capacity of 200 gallons which is the same size as what was considered for the transporter fuel fire above. Additionally, Section 8.2.5 of the North Anna ISFSI SAR considers a small electrical fire at the ISFSt. This fire is bounded by the fuel  !

fire analyzed in the TN-32 TSAR. No other combustibles or explosives are stored at the ISFSt.

I Since the containment integrity of the TN-32 is not breached during the postulated fire, no fire protection system other than portable fire extinguishers is located at the ISFSt. Also, the fire fighting equipment and personnel at the North Anna Power Station would be available if  :

needed  !

No explosion hazards are identified at the ISFSt. Explosion hazards due to vehicular traffic are discussed in Chapter 2 of this SER and have a minimal effect on the ISFSI, therefore no '

explosion detection systems are necessary.

The staff concludes that the applicant has provided an acceptable basis for the ISFSI design and location of safety related structures and systems to minimize the effect of fire and explosions; has used noncombustible and heat resistant materials whenever practical; has provided fire detection and fire fighting systems of appropriate capacity and capability to minimize adverse effects of fire on systems important to safety; and does not require explosion detection systems; and therefore, is in compliance with 10 CFR 72.122(c).

7-2

~

l PRELIMINARY l

7.3 Thermal Analysis Section 4.4 of the TN-32 TSAR describes the thermal model used to evaluate thermal performance. The model considers the spent fuel assemblies, the basket, the cask body, and the concrete storage pad. The concrete storage pad was modeled as a 36 inch thick cylinder extending radially 36 inches beyond the outer diameter of the bottom of the cask. The bottom of the pad is in contact with the soil and is assumed to be isothermal. The bottom of the storage cask is assumed to be in contact with the storage pad. The thermal accident scenario (fire) described in Section 11.2.5 of the TN-32 TSAR uses the same model as is used in Section 4.4 of the TN-32 TSAR.

The material properties of the cask are given in section 4.2 of the TN-32 TSAR. These reflect the accepted values of the thermal properties of the materials specified for the construction of the cask. The calculated maximum temperatures for normal and accident conditions are less than the maximum allowabie temperatures specified in the cask design criteria. The calculated maximum cask cavity pressures for normal and accident conditions are below the design pressure of 100 psig specified in Section 2.2.5.3.3. of the TN-32 TSAR.

The staffs confirmatory analysis is discussed in Section 4.3.4.4 of the TN-32 SER. The TN-32 l SER states that the staffs confirmatory analysis for the normal and accident storage conditions l

demonstrated substantial agreement with the TN-32 TSAR results. The staff also concluded l that the maximum temperatures of the cask components and spent fuel clad are less than the i TN-32 vendor's design criteria. Finally, the staff concluded that the cask pressure resulting from the average cavity temperature coupled with the failure of all of the spent fuel rods is less than the specified design criteria.

As described in Section 4 of the TN-32 SER, the staff found the thermal systems and components important to safety had been analyzed and evaluated to assess their adequacy for j protecting the health and safety of the public. The staff concluded that the TN 32 cask is able to i safely store fuel for a minimum of 20 years with an adequate margin of safety, i

l The North Anna ISFSI is a 2 foot thick concrete pad which is bounded by the three foot thick l concrete pad analyzed in the TN-32 TSAR. The applicant did not propose any design or operational changes to the TN-32 which affect the thermal analysis. Based on its review of the North Anna ISFSI SAR, the TN-32 TSAR and the TN 32 SER, the staff concludes that the description cf the thermal systems and components important to safety and the evaluation of l those systems satisfies the requirements of 10 CFR 72.24(d). The staff further concludes that the spent fuel cladding will be protected against degradation during the period of the license in compliance with the requirements of 10 CFR 72.122(h)(1) and that the ISFSI is des;gned to

. effectively perform its safety function effectively under credible fire and explosion conditions in j compliance with 10 CFR 72.122(c).

L

7.4 Evaluation Findings

The following findings are based upon review of the TN-32 TSAR and the North Anna ISFSI SAR.

7-3 L_ __ - - - - - - - - _ - - - - _ - - -

c _ _ .

t

( PRELIMINARY F 7.1 The staff concludes that thermal SSCs important to safety are described in sufficient detail to enable an evaluation of their effectiveness; in compliance with 10 CFR 24(c)(3).

F7.2 The staff concludes that the site specific fire and explosion hazards, as described in the l

North Anna ISFSI SAR, are acceptable and that the fire protection program's design )

criteria and bases are acceptable and meet the requirements of 10 CFR 72.122(c). l l F7.3 The staff concludes that the spent fuel cladding is protected against degradation that

! leads to gross ruptures by maintaining the cladding temperature for 7-year cooled PWR I

fuel below 348 degrees C in a helium environment. Protection of the cladding against degradation will allow ready retrieval of spent fuel for further processing or disposal; in compliance with 10 CFR 72.122(h)(1).

l l- F7.4 The staff concludes that the TN-32 is designed with a heat removal capability having testability and reliability consistent with its importance to safety, as required by 10 CFR 72.128(a)(4).

I I

I l

{

l 7-4

PRELIMINARY 8.0 RADIATION PROTECTlON EVALUATION The regulatory requirements for having a radiation protection program commensurate with licensed activities and which provides a means for controlling radiation exposures are found in 10 CFR 20.1101,10 CFR 72.24 and 72.126. Other regulatory requirements for limiting exposure to occupational workers and the offsite public are found in 10 CFR Part 20, Subpart C and Subpart D, and 10 CFR 72.104 and 72.106.

This review was performed according to Chapter 9 of NUREG-1567, Standard Review Plan for SpentFuelDtv Storage Facilities.

8.1 Satisfaction of ALARA Objectives As described in the North Anna ISFSI SAR, the program to ensure radiological doses are "as I low as is reasonably achievable" (ALARA) for the North Anna ISFSI will be the same as the  !

ALARA program for the NAPS and is referred to as the Virginia Power ALARA Program. The basic principles of the ALARA program are described in Virginia Power administrative procedures and implemented by North Anna health physics technical procedures.

The North Anna Power Station ALARA program follows the guidance in Regulatory Guide 8.8,

'Information Relevant To Ensuring That Occupational Radiation Exposures At Nuclear Power Stations Will Be As Low As is Reasonably Achievable" and Regulatory Guide 8.10, " Operating Philosophy For Maintaining Occupational Radiation Exposures As Low As is Reasonably Achievable." The ALARA program include the following elements:

s 1. Identification of specific individuals with specific responsibility for and authority to !'

implement the ALARA program;

2. An ALARA committee with re wsibility to coordinate the station ALARA program and to advise the Station Mans' .1 matters which involve ALARA;

3. Requirements for pre-job measures which include ALARA evaluations of proposed work, pre-job meetings, and tiered levels of review based on projected person-rem;

4. Monitoring and control on-going work through an exposure tracking system, ALARA hold points, and ALARA radiation work permit re-evaluation meetings; l 5. - Post-job reviews of completed work; and '

l 6. ' An ALARA review of engineering design changes prior to implementation  !

l The site of the ISFSI was chosen because it was centrally located on the North Anna Power Station site and will thus minimize any off-site exposures. The ISFSI site is also removed from the buildings and occupied sites in order to reduce the exposure to station personnel. The layout of the ISFSI itself is designed to minimizo personnel exposures. Finally, the surveillance  ;

and maintenance requirements for the cask are minimal which reduces radiological dose to station maintenance personnel.

I 4

8-1 l

PRELIMINARY Based on a review of the above information, the staff concluded the applicants description of the ALARA program satisfied the requirements of 10 CFR 72.24(e).

8.2 Radiation Sources As part of the cask loading process, the exterior surface of the cask will be decontaminated prior to transfer to the ISFSI. During the storage period, the casks will not be opened after i placement at the ISFSI. Therefore, the only source of radioactivity from normal operations will

[ be the direct radiation from the fuel stored in the casks.

The spent fuel to be stored at the ISFSI must have an initial enrichment $3.85 %, a maximum average bumup of $40,000 MWD /MTU, and a cooling time 27 years. Cask-specific analyses were performed for representative North Anna Power Station fuel. Neutron and gamma source l terms for the stored spent fuel were generated using the OREST (ORIGEN ll) computer code.

8.3 Radiation Pn*ction Design Features The ISFSI will consist of three concrete storage pads on which the loaded storage casks will be placed. The storage pads will be constructed one at a time, as needed.

Access to the ISFSI is limited to personnel needed during operations at the ISFSI. The ISFSI will be surrounded by a security fence and a perimeter fence. Types of operations to be conducted at ISFSI include periodic inspections of the facility, placement of loaded casks, and routine security checks. The perimeter fence will have a locked gate and control of the keys will be in accordance with security and health physics polices and procedures.

Currently, the Transnuclear, TN-32 Dry Storage System is the only system proposed for use at the North Anna ISFSI. The major components of the TN-32 include a carbon steel cylindrical contair: ment vessel with an integrally welded carbon steel bottom closure, bolted carbon steel lid closure, steel gamma shield and borated polyester resin compound neutron shield. The evaluation of the TN-32 shielding design in the TN 32 SER states, " design of the shielding system is in compliance with 10 CFR Part 72 and the applicable design and acceptance criteria have been satisfied. The evaluation of the shielding design provides reasonable assurance that the TN-32 will enable safe storage of spent fuel." In a letter dated May 18,1998, the applicant described a change to the TN-32 design to fill the gap between the inner vessel flange and the gamma shield with steel shims. The gap that remains between the shim and the cask components is very small (maximum 0.03") and occurs at the top of the cask. There is no line of sight path from a radiation source. Therefore, no significant increase in dose rate is expected. Based on the proposed controls described above and on the applicant's proposed .

use of the TN-32, the staff concludes the applicant has satisfied the requi,ements of 10 CFR '

72.126(a) and 72.128(a)(2).

There is no forced ventilation of the casks. Natural air flow around the storage casks provides sufficient cooling for the spent fuel. As described in Section 11 of this SER, the TN 32 is not expected to leak under normal or accident conditions. Therefore, the staff coreludes that airborne radioactivity monitors described in 10 CFR 72.126(c)(1) are not required at the ISFSI.

I

! 8-2

V d

PRELIMINARY 8.4 Estimated On-Site Collective Dose Assessment Cask specific analyses were performed for representative North Anna Power Station fuel to  !

determine the gamma and neutron doses. ANISN and DOT or similar computer codes were  !

used by cask vendors to ca!culate the surface fluxes. The flux-to-dose-rate conversion factors used were from ANSI /ANS 6.1.1. From the analyses, the design basis side surface dose rate would be 11.9 mrem /hr from neutron and 117.5 mrem /hr from gamm's. The design basis top surface dose rate would be 2.1 mrem /hr from neutron and 52.8 mrem /hr from gamma.

The dose rates at various distances from the loaded casks were calculated. For neutron doses, scattering and cask surface neutron leakage were included in the calculations. Skyshine was included in the calculations for the gamma dose. Based on these calculations the maximum dose rate (neutron plus gamma) at the ISFSl fence line would range from 0.16 mrem /hr at the north fence to 1.02 mrem /hr at the east fence.

Occupational exposures to station personnel have been evaluated for ISFSI operations. The design basis surface dose rates were used in the evaluations. The estimated dose from loading, transport and emplacement of a single cask is 1.46 person-rem. Based upon  ;

experience gained by Virginia Power at the Surry Power Station ISFSI, the estimated dose from '

loading, transport, and emplacement is conservative and the dose w]uld actually be approximately 0.25 person-rem The annual occupational exposures from routine maintenance activities such as visual surveillance of casks, operability tests, calibration and repair of instrumentation, and repair of defects was evaluated. The evaluation used the design basis surface dose rates and assumed the ISFSI was filled to design capacity. The estimated annual exposure of maintenance activities would be 0.30 person-rem.

The estimated annual exposures from ISFSI related activities is a small percent of the average annual occupational exposure from all operations associated with operating the North Anna Power Station. The estimates are also a small fraction of the annual occupational limit of 5 rem specified in 10 CFR 20.1201.

The applicant proposed Technical Specifications to ensure design basis dose rates are not exceeded and to ensure that 10 CFR Part 20 requirements are met. TS 3.3.1 provides specific limits on top and side neutron and gamma dose rates for the casks and provides an acceptable surveillance requirement. The values provided in TS 3.3.1 are consistent with the design basis l and are therefore acceptable. TS 3.3.2 provides specific lim lts on cask exterior surface loose i contamination levels and provides an acceptable surveillance requirement.

Based on the above, the staff concluded that the North Anna ISFSI satisfies the requirements of 10 CFR 72.128(a)(2).

8.5 Health Physics Program The current health physics (HP) program for the NAPS has been modified to incorporate activities at the ISFSt. The HP organization described in administrative procedures will also be 8-3

I l

\

PRELIMINARY l

responsible for health physics activities at the ISFSt. Virginia Power personnel qualifications and experience for power plant operations are adequate for ISFSI operations.

NAPS health physics equipment, instrumentation and facilities will be used for ISFSI operations and surveys. Available equipment includes count room equipment, portable radiation measuring instruments, personnel monitoring equipment, and protective equipment. The bioassay program for plant personnel in use at the NAPS will be the same for the ISFSI.

Current HP procedures for the power station will be revised to reflect the activities to be conducted at the ISFSt. All radiation surveys conducted at the ISFSI will be conducted in accordance with approved HP procedures in effect for the power station. Testing guidance, rejection criteria, and use of dosimeters will be the same for the ISFSI as for the NAPS.

Requirements to have HP and ALARA procedures are specified in TS 5.4.1.1.

8.6 Direct Dose to the Offsite Public As further discussed in Chapter 10 of this SER, there will be no gaseous or liquid radioactive effluents from normal operations of the ISFSI, so the dose to the offsite public is due to direct radiation from the spent fuel stored in the casks. The minimum distance from the ISFSI to the site boundary is approximately 2500 feet in the southwest sector. The nearest resident is located approximately 2800 feet away from the ISFSI. An Environmental Assessment (EA) was l performed by NRC staff to evaluate the impact to the environment from construction and I operation of the ISFSt. Based upon the EA, the radiological impact to the nearest resident from routine operations would be about 10 Sv/yr (1.0 mrom/yr). The cumulative dose the nearest resident would receive from the North Anna Power Station and the ISFSI would be about 58 Sv/yr (5.8 mrom/yr), which is well below the limits specified in 10 CFR 20.1301,10 CFR 72.104, and 40 CFR Part 191. As the estimate of the cumulative effects of the ISFSI and NAPS combined operation are well below applicable regulatory limits, the staff concludes the proposed ISFSI satisfies the requirements of 10 CFR 72.122(e) and 72.126(d).

Based on the description of potential dose to an individual outside the controlled area from direct radiation described in the North Anna ISFSI SAR, the staff concludes the applicant l

satisfied the requirement of 10 CFR 72.24(m) for ISFSI operation.

The applicant has also proposed use of thermo-luminescent detectors (TLDs) placed on the ISFSI perimeter fence to monitor direct gamma radiation doses from the ISFSI . The applicant has proposed TS limits on the ISFSI perimeter radiation levels to ensure that regulatory i requirements on radiation dose to the general public from the ISFSI are met. Proposed TS l 3.3.3 includes limits on perimeter radiation levMs and an acceptable surveillance requirement.

l The staff concludes that the use of the TLD and the periodic TS surveillance are adequate for l - compliance with the requirements of 10 CFR 72.126(c)(2).

G.7 Findings F8.1 The design and operating procedures of the ISFSI provide acceptable means for j controlling and limiting occupational radiation exposures within the limits given in 10 i CFR Part 20 and for meeting the objective of maintaining exposures ALARA, in 8-4 4 I

l 1

l

l PRELIMINARY compliance with 10 CFR 72.24(e).

F8.2 The North Anna ISFSI SAR includes an acceptable analysis of the potential dose equivalent or committed dose equivalent to an individual outside the controlled area from direct radiation from the ISFSI in compliance with 10 CFR 72.24(m).

F8.3 The proposed ISFSl is to be on the same site as the North Anna Power Station. The cumulative effects of the combined operations of these facilities will not constitute and unreasonable risk to the health and safety of the public, in compliance with 10 CFR  ;

72.122(e).

F8.4 The North Anna ISFSI SAR provides information showing that releases to the general environment during normal operations and anticipated occurrences will be within the exposure limit given in 10 CFR 72.104 thus satisfying the requirements of 10 CFR 72.126(d) for normal operation.

F8.5 The design of the ISFSI provides suitable shielding for radiation protection under normal and accident conditions, in compliance with 10 CFR 72.128(a)(2).

F8.6 The staff concludes that the use of the TLD and the periodic TS surveillance are i adequate for compliance with the requirements of 10 CFR 72.126(c)(1) and 72.126(c)(2).

l l

l I

i 8-5 1

PRELIMINARY 9.0 CRITICALITY Requirements for the prevention of criticality in independent spent fuel storage installations are detailed in the design criteria in 10 CFR Part 72.124.10 CFR 72.124 includes requirements that spent fuel storage systems must be designed to maintain suberitical conditions with margins of safety that account for uncertainties in the data ar,d methods used in the criticality calculations. Storage system designs mv 1 ensure that before a criticality accident occurs, at least two unlikely, independent and concurrent er sequential changes have occurred in conditions essential to criticality. Methods of criticality control must be based on favorable geometry or fixed neutron absorbers or both.

NRC staff acceptance criteria for criticality control design features are detailed in Chapter 10 of the SRP. ,

9.1 Design Features and Operations to Snsure Suberiticality The applicant has proposed to use the TN 32 storage cask for storage of spent fuel at North Anna. Criticality design evaluations for the TN 32 are described in Chapter 6 of the TN-32 TSAR. The TN-32 incorporates several design and operational methods to prevent criticality.

The design incorporates neutron absorbing materialin the form of borated aluminum plates in the basket. From an operational standpoint, it is assumed that a minimum dissolved boron concentration of 2000 ppm in the spent fuel pool is present during cask loading and unloading )

activities. It is also assumed that operational controls are implemented to prevent fresh water j from entering a cask loaded with spent fuel. In addition, it is assumed that the initial l enrichment of the fuel is limited to no more then 3.85 % wt. The design analysis took into l consideration these design and operational assumptions along with the geometry of the fuel I inside the loaded cask, in a letter dated January 30,1998, the applicant proposed to load only two specific fuel assembly types, the Westinghouse 17x17 Standard and the Westinghouse 17x17 Vantage SH assembly into the TN-32 casks at North Anna. The applicant proposed to include in the Technical Specifications limitations on the initial enrichment (TS 2.1.1; 5 3.85 % wt) and fuel assembly design (TS 2.1.1; Westinghouse 17x17 Standard or 17x17 Vantage SH) and on the i boron concentration in the spent fuel pool (TS 3.2.1; E 2000 ppm). In a letter dated May 28, '

1998, the applicant revised the N osed TS 3.2.1 to include a requirement for two independent l samples of boron concentration aswciated with cask loading and unloading activties. This satisfies the requirements of 10 CFR 72.124(a).

9.2 Criticality Analysis in the TN 32 TSAR, the criticality e aluation of the TN 32 was performed for two fuel assembly types, a Westinghouse 15x15 assembly and a Westinghouse 17x17 OFA assembly. As described in the Chapter S of the TN-32 SER, the staff found that for both the 15x15 and 17x17 OFA PWR assemblies, the calculated value of k,, was less than 0.95, taking into account 9-1 l

l E_____ _ _ _ _ _ . _ . _ . _ _ . _ _ _ _ _ . _

PRELIMINARY statistical uncertainties and biases. The staff concluded that TN-32 cask was designed to remain suberitical under all credible conditions and that the fixed neutron poisons in the cask design would remain effective for the proposed twenty year storage period. The staff concluded that the criticality design of the TN-32 was in compliance with 10 CFR Part 72 and that applicable design and acceptance enteria were satisfed.

In the January 30,1998 letter, the applicant noted it intended to load only Westinghouse 17x17 Standard and Watinghouse 17x17 Vantage 5H assemblies into the TN-32 casks. The applicant observed that further analysis by TN showed that the 17x17 Standard assembly was not bounded by the criticality analysis of the 17x17 OFA presented in the TN-32 TSAR. The results of the further analysis showed that for the 17x17 Standard assembly with fuel assemblies centered in each fuel compartment, k, = 0.g225. For the 17x17 Standard assemblies, a calculation was also performed assuming the fuel assemblies were all shifted toward the center of the cask. In this case, k,was calculated to be 0.9222. The applicant stated that the Vantage 5H model differed from the 17x17 Standard in the use of some materials for the fuel assembly hardware. For example, the 17x17 Standard design has eight inconel grid spacers whereas the Vantage 5H assembly has six zirconium alloy spacers and two inconel spacers. However, the applica;% stated that all dimensions important to criticality (e.g., fuel pellet diameter, fuel rod diameter, fuel rod pitch and fuel stack height) were the same for the Standard and Vantage SH assemblies. The applicant concluded these fuel assembly differences had no effact on the criticality analysis. The staff confirmed that dimensions important to criticality were the same for the Vantage 5H and the Standard assemblies and agreed that the assemblies were the same for criticalh considerations.

Based on the information provided by the applicant regarding specific planned use of the TN 32 at North Anna and the proposed Technical Specification controls, the staff concludes that the proposed North Anna ISFSI design and operation meets the requirements of 10 CFR 72.124(a) and (b) with the exception of the requirement to periodically verify neutron absorber efficacy.

The staff has granted an exemption from this requirement as detailed in Chapter 13 of this SER.

Because the spent fuel at North Anna will b handled underwater and stored dry and packaged in a licensed configuration, pursuant to 10 CFR 72.124(c), criticality monitoring is not required. .

9.3 Findings

On the basis of (1) the TS proposed by the applicant, (2) the information provided by the applic, ant and (3) the analysis and review of the TN-32 cask design documented in the TN-32 TSAR and TN-32 SER, the staff finds that:

Fg.1 The designs and proposed use of the North Anna ISFSI, using the TN-32 storage cask and associated systems, for the handCng, packaging, transfer and storage for the radioactive material to be stored acceptably ensure that the materials will remain suberitical and that, before a nuclear criticality accident is possible, at least two unlikely, independent and concurrent or sequential changes must occur in the conditions essential to nuclear criticality safety. The North Anna ISFSI SAR analyses and January 30,1998 submittal and the TN-32 TSAR analysis adequately show that I acceptable margins of safety will be maintained in the nuclear criticality parameters, 9-2

- _ _ _ _ . _ . _ _ _ ____._U

1 i PRELIMINARY commensurate with uncertainties in the data and methods used in calculations, and demonstrate safety for the handling, packaging, transfer and storage conditions in the nature of the immediate environment under accident conditions; in compliance with 10 CFR 72.124(a) and (b) except for the requirement to periodically verify neutron absorber efficacy.

9-3

PRELIMINARY 10.0 CONFINEMENT EVALUATION NRC regulations, st 10 CFR 72.122(h) and 72.128(a) provide requirements for confinement barriers and systems including requirements for the prevention of gross fuel ruptures, ventilation systems where necessary, monitoring of confinement integrity and retrieval of stored fuel.

General requirements regarding adequacy of the description of confinement systems in the application are specified in 10 CFR 72.24. Because the proposed ISFSI is not a pool type facility, the requirements of 10 CFR 72.122(h)(2) are not applicable.

This review was performed according to Chapter 11 of NUREG-1567, Standard Review Plan for SpentFuelDry Storage Facilities.

10.1 Confinement Design The applicant has elected to use the TN-32 cask for initial licensing and storage operations at

- the North Anna ISFSI. The TN-32 confinement boundary includes the inner shell, the shell bottom plate and top flange, the bolted lid assembly outer plate with an inner metallic O-ring, '

and the bolted vent / drain port covers with inner O-rings. The only penetrations in the primary confinement are the opening for the lid assembly and the vent and drain ports. The penetrations are closed by the lid assembly outer plate and the vent / drain port covers, all of which are sealed by two metallic O-rings. The TN-32 is backfilled with helium to protect the fuel against degradation during storage. The TN-32 casks are designed, fabricated and examined to the maximum extent practical in accordance with ASME Boiler and Pressure Vessel Code Section ill, Division 1, Section NB.

In Section 3.3.2.1 and Appendix A of the North Anna ISFSI SAR, the applicar t references the TN-32 confinement design. The staff concluded that this reference and the confinement description in the TN-32 TSAR satisfy the requirements of 10 CFR 72.24(c) and (d) with regard to confinement.

l 10.2 ConfinementMonitoring The region between the inner and outer seats of the cask lid is pressurized with helium to an initial pressure greater than the pressure inside the sealed cask. The regions betw; en the inner and outer seals of the vent and drain ports are connected to the region ietween the tid seals by l

paths drilbd into the cask lid. This is done so that in the event of an unanticipated failure of any of the inner (or primary) confinement seals, the helium will leak into the cask cavity or the vent port.

The inter seal region is monitored by a pressure monitoring transducer system. When the intertid pressure falls below at preset value, due to either a leak of the inner seal or a leak of the outer seal, the pressure transducer and switch will cause an alarm to activate at a local alarm panel and in the NAPS Central Alarm Station. Upon receipt of an alarm, security staff will notify the NAPS Control Room Shift Supervisor who will direct operators to check the cause of the l alarm and will initiate appropriate corrective action.

10-1

l PRELIMINARY The applicant proposed a Technical Specification requirement (TS 3.1.4) to verify seal integrity every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> using the installed pressure monitoring and alarm system.

Based on the above description of the pressure monitoring system and proposed Technical Specification requirements, the staff concludes the design and operation of the North Anna ISFSI is in compliance with the requirements of 10 CFR 72.122(h)(4) and is therefore acceptable. The staff also concludes that the confinement monitoring provided by the pressure monitoring system is sufficient to satisfy the requirements of 10 CFR 72.122(l) as it pertains to confinement.

10.3 Confinement Analysis A confinement analysis was provided in the TN-32 TSAR to demonstrate compliance with the applicable dose limits in 10 CFR Parts 20 and 72 and shielding requirements in 10 CFR Part 72.

Under design basis normal and accident conditions, the TN-32 provides a primary and redundant sealing confinement boundary. However, for purposes of demonstrating compliance with applicable dose limit requirements, an event was postulated which assumed a breach of the cask seal barriers and removal of the closure lids and which assumed failure of both the fuel pellets and cladding such that "K, *l and tritium are released to the environment. Such an event is not considered credible and is beyond the design basis of the ISFSI. An evaluation of y the postulated event is provided in the TN 32 TSAR which demonstrates the calculated dose at the controlled area boundary is significantly less than the limit specifed in 10 CFR 72.106(b).

The TN-32 confinement system has been evaluated to demonstrate that it will reasonably maintain confinement of radioactive material under normal, off-normal, and accident conditions.

In the TN 32 SER, the staff stated that the evaluation of the TN-32 confinement system design provides reasonable assurance that the TN 32 will enable safe storage of spent fuel.

The North Anna ISFSI applicant has evaluated the dose from the loss of confinement accident using site specific information. Site specific meteorological information, source term, and fuel characteristics were used in the calculation of the dose at the nearest site boundary. The staff reviewed the applicant's analysis of a postulated loss of confinement. For the hypotheticalloss of confinement accident with the release of l*, Kr", and tritium, the total effective whole body dose and thyroid dose are a small fraction of the 5 rem limit in 10 CFR 72.106(b). l Based upon the information provided in the North Anna ISFSI SAR and the TN 32 TSAR, doses to the public from normal operations and anticipated occurrences will be within the limit in 10 CFR 72.104. Projected releases from accident scenarios will be within the limit in 10 CFR 72.106(b). On the basis of the applicant's proposed use of the TN-32 cask and the confinement evaluation presented above, the staff concludes that the North Anna ISFSI confinement features i meet the requirements of 10 CFR 72.122(h)(5). Based on the sealed nature of the cask design and the staffs conclusion that confinement integrity will be maintained for the duration of the license, the staff concludes that ventilation and offgas systems discussed in 10 CFR 72.122(h)(3) are not necessary. Based on the sealed nature of the cask design and the staffs conclusion that confinement integrity will be maintained for the duration of the license, the staff concludes that the design is sufficient to preclude transport of radioactive material to any mejor water resources as required by 10 CFR 72.122(b)(4).  ;

10-2

PRELIMINARY 10.4 Estimated Offsite Collective Dose Assessment

/ s discussed above, there will be no gaseous or liquid radioactive effluents from normal operations of the ISFSI, so the dose to the offsite public is due to direct radiation from the spent fuel stored in the casks. The minimum distance from the ISFSI to the site boundary is approximately 2500 feet in the southwest sector. The nearest resident is located approximately 2800 feet away from the ISFSI. An assessment was performed by NRC staff to evaluate the impact to the environment from construction and operation of the ISFSI. Based upon the assessment, the radiological impact to the nearest resident from routine operations would be about 10 Sv/yr (1.0 mrem /yr). The cumulative dose the nearest resident would receive from the North Anna Power Station and the ISFSI would be about 58 uSv/yr (5.8 mrem /yr), which is

well below the limits specified in 10 CFR 20.1301,10 CFR 72.104, and 40 CFR Part 191..

10.5 Protection of Stored Material From Degradation After the cask is loaded with fuel, the cask lid is bolted in place engaging the double seal rings -

in the process. The cask is vacuum dried and back filled with helium and leak tested. The inert helium backfill is provided to prevent air inleakage to the cask cavity which could damage the fuel cladding during the period of storage. In the TN-32 TSAR, a leakage rate acceptance

! criteria was calculated to ensure that the helium pressure in the inner seal space was always greater than the pressure inside and outside the cask, thus preventing escape of radioactive gases or in leakage of air. The calculated leak rate was 1x104 std cc/sec.

The applicant proposed a Technical Specification control on the cask seal leakage rate (TS l 3.1.3 ) of 1X104 mbar-liter /sec, which is equivalent to the value calculated in the TN-32 TSAR.

The staff concluded this value is acceptable.

In the TN 32 TSAR, the vendor evaluation of cask helium pressure over a twenty year storage period assumed an initial cask cavity pressure of 2.2 atm. The applicant proposed a Technical Specification control (TS 3.1.2) on helium backfill pressure. The applicant proposed a TS limit j for helium back pressure for the TN-32 at the North Anna ISFSI is 2230 mbar, which equivalent to the value assumed in the TN 32 TSAR, and which the staff thus concludes is acceptable.

L in Section 8.1.3 of the TN-32 TSAR, the vendor describes the vacuum drying process which ensures that all liquid water has evaporated and been removed from the cask cavity after the cask is loaded with fuel and the lid is installed. This process serves to minimize degradation of the fuel cladding while in storage. The vendor established cask vacuum pressure as a dryness l

criteria and established an acceptance criteria where cask pressure must be less than 3 mbar for at least ten minutes. The applicant proposed a TS control on vacuum drying pressure (TS j 3.1.1) with the same limiting values described in the TN-32 TSAR which the staff thus concludes l is acceptable.

I Based on the applicant's proposed use of the TM-32 as designed and as described in the TN-3 TSAR and based on the acceptable TS controls proposed by the applicant, the staff concludes that the proposed North Anna ISFSI complies with the requirements of 10 CFR 72.122(h)(1).  !

10-3 i

l 3

i

! PRELIMINARY

! 10.8 Evaluation Findings F10.1 The design and proposed operation of the ISFSI include acceptable measures that preclude the transport of radioactive materials to major water resources in accordance with 10 CFR 72.122(b)(4).

l F10.2 The design and proposed operation of the ISFSI acceptably provide measures for protection of the cladding of the material to be stored, in compliance with 10 CFR 72.122(h)(1).

F10.3 The design of the ISFSI acceptably provides for continuous monitoring of the effectiveness of confinement, in compliance with 10 CFR 72.122(h)(4).

F10.4 The design and proposed procedures of the ISFSI acceptably provide for packaging the material to be stored without the release of radioactive materials to the environment or radiation exposures in excess of Part 20 limits, for the duration of the license, in compliance with 10 CFR 72.122(h)(5).

F10.5 The ISFSI includes the TN-32 cask as its important to safety confinement system which warrants monitoring ove* anticipated ranges for normal and off normal operation. The pressure monitoring system satisfies the requirements of 10 CFR

'72.122(l) with respect to confinement.

F10.6 The North Anna ISFSI SAR demonstrates that releases to the general environment during normal operations and anticipated occurrences will be within the exposure limit I given in 10 CFR 72.104, and that releases to the general environment resulting from 1 l design basis accidents and accident level events and conditions will be within the l exposure limits given in 10 CFR 72.106, thus satisfying the requirements of 10 CFR l

72.126(d) and 10 CFR 72.128(a)(2) and (a)(3) for accident conditions.

F10.7 The SAR includes an acceptable analysis of the potential dose equivalent or committed dose equivalent to an individual outside the controlled area from direct <

radiation from the ISFSI in compliance with 10 CFR 72.24(m).

10-4 I

r_ _

PRELIMINARY

11. ACCIDENT ANALYSIS 11.1 Introduction

' The staff revows the accident analysis to ensure that off-normal, and accident-level events and conditions have been identified, and their potential safety consequences considered to meet the following regulatory requirements; 10 CFR 20.1201,10 CFR 72.2410 CFR 72.26,10 CFR 72.40(a)(13), and Subparts E and F. The applicant proposes to use the TN 32 spent fuel storage cask at the North Anna ISFSI. Therefore, the TN-32 TSAR key assumptions, bounding site characteristics, environmental conditions, and cask /ISFSI interface requirements applicable to the accident analyses review are compared to the ISFSI design and environmental conditions.

This review was performed using the acceptance criteria listed in Chapter 12 of NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities.

11.2 Off-Normal Events and Conditions Off-normal conditions are Design Event ll as defined in ANSI /ANS 57.9-1984. These events can be expected to occur with moderate frequency or on the order of once per year. The applicant established that the North Anna ISFSI site parameters are within the bounds of the TN-32 TSAR. The staff concurs that all off-normal conditions and those other events being bounded, and their potential safety consequences considered.

11.2.1 Loss of Electric Power The North Anna ISFSI SAR identifies one off-normal event which is loss of electric power to the ISFSt. This event was also assessed in the TN-32 TSAR. There were no differences between I the ISFSI SAR and the TN 32 TSAR with respect to the effects, consequences and radiological impacts of a loss of power event.

The power is used only for area lighting, receptacles, security equipment and the pressure monitoring system (PMS). The PMS monitors the cask seat integrity; it is not used to maintain cask seal integrity. The cask seal integrity, which is verified during loading operations as l' specified in the North Anna ISFSI Technical Specifications (TS), is not affacted by a loss of power. Thus, a temporary interruption of the PMS function is of no consequence. .

~ Loss of power could be caused by natural phenomena or an undefined disturbance in the non-safety related North Anna electric power system. A power loss to the ISFSI would be detected and indicated at the North Anna Central Alarm Station via the ISFSI Cask Status Alarm.

Maintenance personnel are available at the North Anna site to restore normal power. In addition, a backup diesel generator is available to provide power to affected ISFSI equipment upon a loss of normal power.

l There is no adverse impact on the cask integrity from this event since power is not relied on for maintaining cask integrity. Since cask integrity is maintained, there are no radiological or safety effects or consequences.

Il Al

PRELIMINARY 11.2.2 One Set of Seals and PMS Fall Simultaneously l

During the staff's review of the TN-32 TSAR, the TN-32 vendor provided a supplemental '

analysis of an event in which one set of cask seats for a single cask is assumed to fail simultaneously with a failure of the PMS on that same cask. The results of that analysis are described in Sections 7.3.4,10.3.4.1, and 11.3.1.2 of the TN-32 SER. This event was evaluated to assess the importance of the PMS. In the TN-32 SER, site boundaries are assumed to be at 100 and 200 meters from the ISFSI. It was assumed that the failed seals and PMS would be repaired or replaced upon detection of this event.

The analysis assumptions and resulting radiological effects and consequences are discussed in ,

Sections 7.3.4 and 10.3.4.1 of the TN-32 SER. The staff found that the dose at the postulated site boundary from this event is negligible compared to the regulatory limits in 10 CFR 72.104(a). 4 The applicant did not repeat this analysis for the North Anna site. However, the staff notes that the distance from the North Anna ISFSI to the site boundary is approximately 770 meters (2500 ft). therefore the analytical results presented in the TN-32 SER for this event are conservative for the North Anna ISFSI and no further analysis is required for the North Anna ISFSI.

11.3 Accident-Level Events and Conditions Accident level events and conditions are Design Events ill and IV as defined in ANSI /ANS 57.9-1984. They include natural phenomena and man-induced low probability events. The applicant established that the North Anna ISFSI site parameters are within the bounds of the TN-32 TSAR, or provided additional analyses to demonstrate design adequacy. The staff concurs that all accident-level events and conditions and those other events being bounded, have been identified and all potential safety consequences considered.

11.3.1 Earthquake Sections 2.5.2 and 3.2.3 8.2.1 of the North Anna ISFSI SAR describe the design earthquake (DE). The DE has a ground acceleration of 0.18 g in the horizontal direction and 0.12 g in the vertical direction. The TN-32 TSAR evaluated the TN-32 cask response tc sn earthquake with the same ground acceleration as the NA ISFSI DE.

There are no radiological or safety effects or consequences resulting from this event. Section ,

4.2.1.4 of the North Anna ISFSI SAR evaluated the ISFSI response to the DE. The concrete l pad remains intact and the cask does not slide, tip over or become damaged. Therefore, the fuel is not damaged and the confinement integrity is maintained for the DE.

11.3.2 Wind and Tornado missiles Section 8.2.2.1 of the North Anna ISFSI SAR evaluated the natural phenomena design basis wind (DBW) and design basis tornado (DST) accidents. The wind loads were determined using ASCE 7-88 and the DBW frequency is once every 100 years. The DBW is shown on North Il-2 '

PRELIMINARY Anna ISFSI SAR Figure 2.3-3 and is 80 mph. The DBT, described in Sections 2.3.1 and 3.2.1.1, occurs less than once every 30,800 years, has a rotational wind velocity of 300 mph, a transnational velocity of 60 mph and a pressure drop of 3 psiin 3 seconds.

The ISFSI and cask design criteria are discussed in Section 3 of this SER. The ISFSI is an unenclosed concrete pad, therefore there are no structures that could collapse onto the cask.

The applicant has proposed sufficient design criteria for protection against the wind and tomado missile environmental phenomena as required by 10 CFR 72.122. The concrete pad is not damaged and the cask doeg not slide or tip over .

In a letter dated May 18,1998, the applicant provided the results for an analysis of the North Anna design basis tomado missiles. The analysis demonstrated that the containment integrity is not breached during these events but minor damage to the cask exterior and neutron shield may be sustained. However, the consequences of minor damage to the neutron shield are bounded by the consequences of resulting site boundary dose was evaluated for loss of all the neutron shield analyzed in the TN-32 TSAR and found to be below the regulatory limits in 10 CFR 72.106(b); refer to Section 11.3.7 below. If damage to the neutron shield was found or suspected, the cask would be repaired or unloaded.

11.3.3 Flood Flooding is not a credible design basis event for the North Anna ISFSt. The ISFSI site is flood-dry since it is 45 feet above the Probable Maximum Flood elevation for Lake Anna. Additionally, the storm drainage design of the ISFCI site is designed to accommodate a 100-year precipitation event. Refer to Section 2.2 of this SER for a discussion of flooding events. The North Anna ISFSI meets the requirements of 10 CFR Subpart E with respect to flooding.

11.3.4 Explosion No explosion hazards are identified at the ISFSI. Explosion hazards due to vehicular traffic are discussed in Chapter 2 of this SER and have a negligible effect on the ISFSI. The TN-32 is designed to withstand an extemal pressure of 25 psi, which is greater than any over pressure from the identified vehicular traffic explosion hazards. The largest credible rail or highway transportation accident is the explosion of an 8,500 gallon gasoline tank truck at the closest approach of Virginia Route 652,1.5 miles from the ISFSI site. Based on the application of Regulatory Guide 1.91 and the information provided by the licensee regarding equivalent TNT weight of gasoline, the staff agrees that the expected over pressure from such an explosion would be less than 1 psi at the ISFSI site. In the TN-32 SER, the staff previously acknowledged that the TN-32 is designed to withstand a 25 psi over pressure. Thus, the staff concludes that the postulated gasoline tank truck explosion 1.5 miles from the North Anna ISFSI would have negligible effect on any TN-32 in use at the ISFSI, the fuel is not damaged and that the ,

containment integrity of the TN-32 is not breached. Therefore, there are no radiological or I safety effects or consequences. '

Il-3

)

i

PRELIMINARY 11.3.5 Fire Fire accidents are discussed in Chapter 7 of this SER. The hypothetical fire accidents considered have a minimal effect on the ISFSI. The containment integrity of the TN-32 is not breached however, the neutron shielding may be damaged. As described in Section 11.3.7 below, the boundary dose was evaluated for a single cask without any neutron shielding and found to be within the regulatory limits of 10 CFR 72.106(b). If damage to the neutron shield was found or suspected, the cask would be repaired or unloaded.

11.3.6 Storage of Unauthorized Fuel Assembly Section 8.2.6 of the North Anna ISFSI SAR evaluated the storage of an unauthorized fuel assembly due to operator error or failure of fuel handling operation administrative controls. The SAR considered loading of an unirradiated fuel assembly and loading of damaged assemblies.

The applicant stated that loading of ar unauthorized assembly with gross cladding defects would not cause further damage to the clad or release of radioactive material. Loading of an unauthorized fuel assembly with gross structural damage is assumed to be prevented by administrative controls. Loading of an unauthorized unirradiated assembly is bounded by the criticality evaluation in the TN-32 TSAR which considers that all fuel assemblies are unirradiated and demonstrates suberiticality is maintained.

The North Anna ISFSI include specifications on the fuel assembly parameters for fuel that is to be stored ib the casks. The North Anna ISFSI SAR describes the administrative steps that will be taken to verify that only authorized fuel assemblies are loaded into the cask. The identity of each fuel assembly is checked again prior to installing the cask lid. Since there are multiple checks prior to sealing the lid and removing the cask from the spent fuel pool, unauthorized fuel in the cask after removal from the spent fuel pool was not evaluated. The staff concurs that the administrative controls are sufficient to preclude a loading error that remains undetected prior to removing the cask from the spent fuel pool.

I 11.3.7 Loss of Neutren Shield i Total loss of the neutron shielding is not considered credible but is evaluated for one cask in Chapter 5 of the TN-32 TSAR and Chapter 10 of the TN-32 SER, respectively. The staff found that the resulting dose at the site boundary meets the requirements of 10 CFR 72.106(b). Since the minimum distance from the ISFSI to the site boundary is approximately 770 meters (2500 ,

ft), the staff concludes that the TN-32 SAR evaluation bounds the ISFSI. Therefore, the North I Anna ISFSIis compliance with 10 CFR 72.106(b) under loss of neutron shield accident conditions.

11.3.8 Seal Leakage The TN-32 cask has redundant seals and a PMS to detect a decrease in pressure.

Simultaneous failure of one set of seals and the PMS was evaluated above and found to be in compliance with 10 CFR 72. Loss of both sets of seats is not a credible event and is bounded by the loss of confinement barrier evaluated in Section 11.3.11 below.

I f

Il-4 l

l

PRELIMINARY 11.3.9 Bottom end Drop I

The cask handling accidents inside the Fuel and Decontamination Buildings (F&DBs) are addressed in the North Anna Power Station UFSAR. The bottom-end drop was evaluated in Section 8.2.9 of the ISFSI SAR as the only credible handling accident outside the F&DBs. The applicant determined that a cask drop higher than 15" would not be credible due to the transporter design and administrative controls. The transporter is designed such that the lifting height of the jackinD towers cannot be changed without disassembling the towers. The North Anna TS limits the cask lifting height to less than 18 inches.

Sections 3 and 11 of the TN-32 TSAR qualify the cask for an bottom-end drop deceleration of 50 g. In the safety evaluation of the TSAR, the staff accepts, for an 18-inch drop, a maximum deceleration of 50 g if the storage pad bounding parameters are limited to: 1)a thickness of 3 ft,

2) a concrete strength of 4 ksi, and 3) a soil modulus of 40 ksi. The North Anna concrete storage pad parameters differ from those listed above. The depth of the concrete pad is 2 ft, the concrete strength 5.06 ksi, and soil modulus 30 ksi, in a response to staffs request for additional information, the applicant performed an as-built reconciliation analysis of pad parameters. The staff reviewed the assumptions made in the analysis and agreed with the conclusion that the reduced pad thickness and increased concrete strength or elastic modulus effectively cause a net reduction in pad flexural rigidity, thereby, lowering the applicable cask deceleration g-loads.

On the above basis, the staff concurs that, for the North Anna ISFSI application, the TN-32 cask will not experience a bottom-end drop deceleration greater than the level the cask has been evaluated in the TN-32 TSAR. This assures that cask confinement and spent fuel retrievability from the basket will not be compromised after a 15-inch bottom-end cask drop accident. If dropped, site personnel would assess the damage and if significant damage is noted or suspected, then cask would be returned to the fuel building and unloaded.

11.3.10 Tip-over As discussed in Section 6 of this SER, the applicant evaluated the potential for cask tip-over and determined that conservative factors of safety exist against cask overtuming. However, the consequences of cask tip-over were evaluated in the TN 32 TSAR. The TN-32 TSAR analyzes the cask for tipover as bounding condition during handling operations. For the most severely stressed regions, the fuel compartment was analyzed for a quasi-static force of 88 g at the basket top and 52 g at the basket center. These forces envelop the corresponding g-loads resulting from a staff confirmatory analysis in which the storage pad bounding parameters are limited to: 1) a thickness of 3 ft,2) a concrete strength of 4 ksi, and 3) a soil modulus of 40 ksi.

The North Anna concrete storage pad parameters differ from those listed above. The depth of the concrete pad is 2 ft, the concrete strength 5.06 ksi, and soil modulus 30 ksi. In a response to staffs request for additionalinformation, the applicant performed an as-built reconciliation analysis of pad parameters. The staff reviewed the assumptions made in the analysis and agreed with the conclusion that the reduced pad thickness and increased concrete strength or elastic modulus will effectively cause a net reduction in pad flexural rigidity, thereby, lowering the applicable cask deceleration g-loads.

I1-5

~

l t I l . I l

l PRELIMINARY I On the above basis, the staff concurs that, for the North Anna ISFSI application, the TN 32 cask j l will not experience tipover deceleration g-loads greater than the levels the cask has been {

l evaluated in the TN-32 TSAR. This assures that cask confinement and spent fuel retrievability i l

from the basket will not be compromised after a hypothetical cask tipover accident. There could be localized damage to the neutron shield. The staff concurred with the TSAR conclusion that

{

the increased site boundary dose is below the requirements of 10 CFR 72.106(b) even if total l

loss of the neutron shield for a single cask is assumed as discussed in Section 11.3.7 above. If, in the event of a hypothetical cask tipover event, significant damage is noted or suspected, then the cask would be retumed to the fuel building and unloaded.

{

i l

11.3.11 Loss of Confinement Barrier i

As discussed in Chapter 10 of this SER, the loss of the confinement barrier is considered a non-credible event. The loss of the confinement barrier is evaluated as a non-mechanistic event in Section 8.2.10 of the North Anna ISFSI SAR. For the hypotheticalloss of confinement accident with the release of l*, Kr", and tritium, the total effective whole body dose and thyroid dose are a small fraction of the 5 rem limit in 10 CFR 72.106(b).

11.3.12 Borated Water Replaced by Fresh water i Section 6.4 of the TN-32 TSAR evaluated fresh water replacing the borated water in the spent fuel pool. The criticality model assumed 1.8 weight percent U-235 instead of 3.85 weight 1 percent U-235 (i.e., spent fuel instead of fresh fuel) and the borated aluminum plate thickness

]

was increased from 0.04 inches thick to 0.075 inches thick. The maximum calculated keff +20 (

is 0.9441, including bias, the maximum calculated keff is 0.9523. While this calculation j demonstrates acceptable results for this accident, the North Anna ISFSI TS also include l l requirements for two independent samples of boron concentration for water that is being added to the cask cavity.

11.4 Evaluation Findings The following findings are based upon review of the TN-32 TSAR and the North Anna ISFSI SAR.

l The staff concludes that the SAR includes acceptable analyses of the design and performance of SSCs important to safety under off-normal and accident scenarios. The analyses show acceptable maximum levels of possible impact on public health and safety resulting from potential off-normal conditions and accident-level events during the life of the ISFSI, and l acceptable capability of SSCs for the prevention of accidents and the mitigation of the i consequences of accidents and accident-level conditions;in compliance with 10 CFR 24(d).

The staff concludes that the analyses of off-normal and accident-level events and conditions  ;

and reasonable combinations of these and normal conditions show that the design of the ISFSI will acceptably meet the related requirements without endangering the health and safety of the public, in compliance with 10 CFR 72.40(a)(13) and 72.122(b).

The staff concludes that the analyses of design basis accidents and anticipated occurrences I 11-6

PRELIMINARY show that releases of radiation to the general environment will be below the exposure limits of 10 CFR 72.106 and 72.104, respectively; in compliance with 10 CFR 72.126(d).

The staff concludes that the applicant has provided a systematic approach to the identification of off-normst and accident level events that is thorough and comprehensive such that there is reasonable assurance that the analyses and results bound all credible accident scensrios.

1 l

l l

11-7 l

PRELIMINARY L

12.0 CONDUCT OF OPERATIONS The objective of the conduct of operations review is to ensure that applicant has the appropriate infrastructure to manage, test, and operate the ISFSI and to conduct effective training for ISFSI operation consistent with the requirements of 10 CFR Part 72.

L This review was performed according to Chapter 13 of NUREG-1567, Standard Review Plan for SpentFuelDry Storage Facilities.

12.1 Organizational Structure and Technical Qualification Virginia Power is a regulated utility that has assembled an organization and installed a l management system for operating the North Anna Power Station. Virginia Power has proposed to use the same organization and management system for the ISFSI, with modifications l necessary to accommodate the needs of the ISFSI. Elements of the applicant's organization l and individual responsibilities are described in VEP-1 5A (Updated) " Operational Quality I

Assurance Program Topical Report." (Updated). In Technical Specification (TS) 5.1.1, the North Anna plant manager is designated overall responsibility for ISFSI operation and is required to l approve, prior to implementation, each proposed test, experiment or modification to systems

that affect nuclear safety. TS 5.2.1 provides general requirements for assigning and defining l lines of authority and responsibility and specifically requires that responsibilities assigned to i individual positions or organization be documented. The staff concludes that the North Anna ISFSI SAR and TS include an acceptable plan for the conduct of operations, in compliance with 10 CFR 72.24(h). The staff also concludes that the application includes an adequate, acceptable description of the applicant's operating organization, delegations of responsibility

! and authority and the minimum skills and experience qualifications relevat to the various levels l of responsibility and authority, in compliance with 10 CFR 72.28(c). l l In Technical Specification 5.3.1, the applicant to require that each member of the facility staff l meet or exceed minimum qualification requirements I ANS 3.1-1979 for comparable positions l with exceptions as specified in the QA Program Topical Report. The Supervisor of Radiological l

Protection is required to meet or exceed the qualifications of Regulatory Guide 1.8 -1975.

In the License Application, the applicant described its experience with nuclear facility operations which include construction and operation of the North Anna and Surry Power Stations and Surry ISFSI dating back into the late 1960s. The staff acknowledges this significant experience.

Based on the applicant's previous experience as well as the satisfactory nature of the  ;

information provided in the SAR and supplemental submittals, the staff concludes that applicant i

has demonstrated acceptable technical qualifications, for the applicant to engage in the proposed activities, in compliance with 10 CFR 72.28(a).

l 12.2 Pre-OperationalTesting and Operation  !

In Section 9.2 of the North Anna ISFSI SAR, the applicant described the scope and objectives l of its pre-operational testing program. The applicant described planned testing of physical facilities including the cask pressure monitoring system, electrical systems and communications and security systems. The applicant also described the operational testing that is to be done for 12-1

l PRELIMINARY each cask design, including loading and unloading operations. In addition, each new cask design is subjected to testing with the transporter to ensure proper function of the transporter.

In a letter dated April 14,1997, the applicant stated that preoperational testing acceptance criteria are the same as those that will be used during loading, transport and unloading operations and include Technical Specification acceptance criteria where applicable. The applicant also stated that when preoperational testing is completed, changes to procedures or equipment are made based on lessons leamed from the testing. Based on the above, the staff concluded the SAR and supplemental submittals include an acceptable description of the program covering preoperational testing and initial operations, in compliance with 10 CFR 72.24(p).

12.3 Training Programs Pursuant to 10 CFR Section 72.192, the applicant must establish a program of training,

, proficiency testing and certification of ISFSI personnel. In its license application, the applicant l stated that it planned to maintain an adequate complement of trained certified personnel prior to the receipt of spent fuel for storage. in Section 9.1.3 and 9.3 of the SAR, the applicant described the personnel qualification and training programs which will serve to ensure an adequate complement of trained personnel are available. in's~ letter. dated May.XX,(1998, the applicant provided copies ofl draft training implementation procedures; As described by the applicant, the existing North Anna training and qualification programs have been augmented with information and training procedures pertinent to design and operation of the ISFSI. Elements of ISFSI training are provided to operations personnel, notably fuel handlers, instrumentation and control, health physics and security personnel. The training program includes classroom lessons and self study modules for information related to ISFSI l layout, technical specifications, communication systems and procedures. The training program also incorporates job performance measures for on-the-job training for cask functional areas

). including cask loading and transport.

Qualifications for personnel involved in management and operation of the !L'SI are described l

in the applicant's Job Classification Summary. The staff reviewed the qualification program procedures complete' based on response'to Mapj8 RA_l Pursuant to 10 CFR 72.190, the licensee ensures that operation of equipment and controls important to safety is limited to personnel trained and certified under the training and qualification program described above. The licensee implements this requirement through complete this based on; response to;.MaM821998JW_.

l' Pursuant to 10 CFR 72.194, the licensee ensures that the physical condition and general health i of personnel certified to operate equipment and controls important to safety are not such as l

might cause errors that would endanger other plant personnel or public health and safety. The

~

licensee implements this requirement bomplets thispasedfon licensees response tolMayj8 W

Based on the above, the staff finds the licensee's training and certification program meets the rooW oments of 10 CFR Part 72, Subpart I (72.190,72.192 and 72.194). Further, the staff 12-2

PRELIMINARY concludes that the applicant will have and maintain an adequate complement of trained and l

certified installation personnel before receipt of spent fuel for storage, in compliance with 10 CFR 72.28(d).

12.4 NormalOperation Normal activities to store spent fuel from the NAPS at the NAPS ISFSI include fuel loading and handling activities inside NAPS facilities. Activities inside the NAPS facilities are subject to the requirements of the NAPS license including the NAPS Technical Specifications as specified in License Condition 17 of the ISFSI license. Notwithstanding, certain procedures and processes to be used by the applicant in loading and transporting spent fuel out of the NAPS were considered by the staff in addition to the procedures and controls associated solely with the North Anna ISFSI.

12.4.1 Record Keeping The applicant described procedures and processes for record keeping related to the inventory, disposal and transfer of spent fue!. In a letter dated April 23,1998, the applicant stated that accountability records for all fuel assemblies transferred to, stored in or removed from the ISFSI will be maintained for as long as the fuel assemblies are stored on the North Anna site and for five years after its transfer off the site. The applicant specifically stated that such records will include information on (1) fuel manufacturer, (2) Date of Delivery to the Station, (3) reactor exposure history, (4) burnup, (5) calculated special nuclear material content, (6) inventory control number, (7) pertinent data on discharge and storage at the reactor, transfer to the ISFSI, storage at the ISFSI and disposal, and (8) other information as may be required by Technical Specifications. This satisfies the requirements of 10 CFR 72.72(a)

The applicant stated that records of the current physical inventory at the ISFSI will be retained until the ISFSIlicense is terminated. This satisfies the requirements of 10 CFR 72.72(b). The applicant stated that material control and accounting procedures will be retained until the !SFSI license is terminated. This satisfies the requirements of 10 CFR 72.72(c).

In a lette' dated April 29,1998, the applicant requested an exemption from the requirements of 10 CFR 72.72(ct) to maintain records in duplicate at physically separate locations. The staff has reviewed and approved this exemption as discussed in detailin Chapter 13 of this SER.

In a letter dated April 23,1998, the applicant stated that records of spent fuel transferred out of the ISFSI will be preserved for a period of five years after the date of transfer. This satisfies the remaining requirements of 10 CFR 72.72(d).

12.4.2 Administrative Procedures in the North Anna ISFSI SAR, the applicant committed to develop and implement administrative procedures to provide instruction regarding various matters including personnel conduct and control, organization and responsibility. The commitment to establish and implement administrative control procedures is captured in Technical Specification 5.4.1.a. Technical Specifications 5.4.1.e,5.4,1.g,5.4.1.j,5.4.1.m,5.4.1.n and 5.4.1.o require procedures for administrative matters such as design control and facility modifications, control of special 12-3

PRELIMINARY processes, special nuclear material accountability, records management, the Technical Specification Bases Control program and the Radioactive Effluent Control Program. Technical Specification 5.5.1 specifies the requirements for changing the Technical Specification Bases.

12.4.3 Health Physics Procedures in the North Anna ISFSI SAR, the applicant stated that health physics procedures are used to implement the radiation protection plan. The applicant stated that procedures have been

, developed and implemented for various matters including monitoring employee exposure,

[ radiation surveys of work areas, radiation monitoring of maintenance activities and records  !

l maintenance. The applicant committed to revise existing procedures as needed to address l operation of the ISFSI prior to ISFSI operation. The applicant stated that revised procedures i i

will address cask loading, unloading, transport and maintenance. The applicant stated that all l work inside the ISFSI will be controlled by radiation work permit. The commitment to have 1 health physics procedures for the ISFSI, including ALARA practices, is captured in Technical Specification 5.4.1.1.

l l

Technical Specification 5.5.2 provides for the programmatic controls required by 10 CFR l l 72.44(d) for environmental monitoring and effluent reporting. As the ISFSI is not expected to l release any effluents under normal or accident conditions, the requirements of 10 CFR l 72.44(d)(1) are not applicable and related procedures are not required.

12.4.4 Maintenance Procedures In the North Anna ISFSI SAR, the applicant stated that procedures will be developed to control the performance of preventative and corrective maintenance. The commitment to have j maintenance procedures for the ISFSI is captured in Technical Specification 5.4.1.h.

12.4.5 Operations Procedures in the North Anna ISFSI SAR, the applicant committed to developing and implementing operating procedures for cask handling, including loading, unloading sealing, transporting and storage. The applicant also committed to develop and implement procedures for responding to annunciator alarms associated with the casks. The commitment to have procedures for routine operations and annunciator response are captured in Technical Specifications 5.4.1.b and j 5.4.1.c respectively.

l 12.5 Findings F12.1 The SAR and supplemental submittals include an acceptable plan for the conduct of operations, in compliance with 10 CFR 72.24(h).

F12.2 The SAR and supplemental submittals include an acceptable description of the program covering preoperational testing and initial operations, in compliance with 10 CFR 72.24(p).

F12.3 The SAR and supplemental submittals include an adequate description of acceptable 12-4

PRELIMINARY technical qualifications, foi the applicant to engage in the proposed activities, in compliance with 10 CFR 72.28(a).

F12.4 The application and supplemental submittals include an acceptable description of a personnel training program to comply with 10 CFR 72, Subpart 1.

F12.5 The application includes an adequate, acceptable description of the applicant's operating organization, delegations of responsibility and authority and the minimum skills and experience qualifications relevant to the various levels of tasponsibility and authority, in compliance with 10 CFR 72.28(c).

F12.6 The application includes an acceptable program to have and maintain an adequate complement of trained and certified installation personnel before receipt of spent fuel for storage, in compliance with 10 CFR 72.28(d).

F12.7 The applicant's description of record keeping processes that satisfy the requirements of 10 CFR 72.72 except in regard to duplicate record storage. An exemption has been granted from the requirement in 10 CFR 72.72(d) for duplicate record storage.

F12.7 Based on the information provided by the applicant, as discussed in this Chapter, and based on the individual staff conclusions documented in this Chapter, the staff

oncludes applicant is qualified by reason of training and experience to conduct the operations covered by the regulations in 10 CFR 72, in compliance with 10 CFR 72.40(a)(4). The staff further concludes that the application is considered to provide acceptable assurance with regard to the management, organization, and planning for preoperational testing and initial operations, that the activities authorized by the license can be conducted without endangering the health and safety of the public in compliance with 10 CFR 72.40(a)(13).

12-5

l i

+

PRELIMINARY l 13.0 TECHNICAL SPECIFICATIONS Requirements for the inclusion of Technical Specifications in the license application are detailed in 10 CFR Part 72.23. Detailed requirements on the information that must be included in Technical Specifications are specified in 10 CFR 72.44. The technical specifications dofine I

operating limits and controls that ensure safe operation of the North Anna ISFSI.

l NRC staff acceptance criteria for Technical Specifications are described in Chapter 14 of the l

SRP.

l 13.1 Functional and Operating Limits Functional and operating limits are those limits on fuel handling and storage conditions necessary to protect the integrity of the stored fuel, to protect emoloyees against occupational

< exposure and to guard against the uncontrolled release of radioactive materials. The Functional i and operating limits included in the North Anna TS are listed in Table 13-1. The table lists the

! section of this SER which documents the acceptability for each functional and operating limit.

! Table 13-1 TS ITEM FUNCTIONAUOPERATING ASSOCIATED SER LIMIT SECTION

! 2.1 Fuel to be stored at the ISFSI 3.1

! 2.2 Functional and Operating Limit 3.1 l Violations Based on an extensive review of the application, the staff concludes the functional and

operating limits listed in Table 13.1 are those necessary to protect the integrity of the stored l fuel, to protect employees against occupational exposure and to guard against the uncontrolled l release of radioactive materials. The staff concludes therefore, that the North Anna ISFSI TS are in compliance with 10 CFR 72.44(c)(1)(i).

j 13.2 Limiting Conditions / Surveillance Requirements l Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation. Surveillance requirements provide for inspection and test activities to ensure that the necessary integrity of required systems is maintained,  :

confirmation that operation of the ISFSI is within the required functional and operating limits, and confirmation that the limiting conditions required for safe storage are met. The Limiting i Conditions and Surveillance Requirements included in the North Anna TS are listed in Table 132. The table also lists the section of this SER which documents the acceptability for each limiting condition or surveillance requirement.

13-1

l PRELIMINARY Table 13-2 TS ITEM LIMITING CONDITION ASSOCIATED ASSOCIATED SER SURVEILLANCE SECTION REQUIREMENT 3.1.1 Cav'ty Vacuum Drying 3.1.1.1 10.5 Pressure 3.1.2 Helium Backfill Pressure 3.1.2.1 10.5

~

3.1.3 Helium Leak Rate 2.1.3.1 10.5 l 3.1.4 SealIntegrity 3.1.4.1 10.1 l' 3.1.5 Maximum Lifting Height 3.1.5.1 4.3 3.2.1 Dissolved Boron Concentration 3.2.1.1, 3.2.1.2 9.1 3.3.1 Average Surface Dose Rates 3.3.1.1 8.4 l 3.3.2 Surface Contamination 3.3.2.1 8.4 l 3.3.3 ISFSI Perimeter Radiation 3.3.3.1 8.6 Based on its review of the application, the staff concludes the limiting conditions listed in Table

13-2 specify the lowest functional capability for that equipment required for safe operation. In

! addition, the staff concludes that the surveillance requirements listed in Table 13.2 provide for necessary inspection and testing, confirm operation within appropriate functional and operating I

limits and confirm that limiting conditions for safe storage are met. The staff concludes  !

therefore, that the North Anna ISFSI TS are in compliance with 10 CFR 72.44(c)(2) and (c)(3).

13.3 Design Features The Design Features portions of the TS includes items that would have a significant effect on safety if altered or modified such as materials of construction or geometric arrangements. The Design Features included in the North Anna TS are listed in Table 13-3. The table also lists the l section of this SER which documents the acceptability for each design feature.

Table 13-3 TS ITEM DESIGN FEATURE ASSOCIATED SER SECTION  ;

4.1 Site Location 1.2 4.2 Storage Features 1.2 Based on an extensive review of the application, the staff concludes the design features listed in Table 13-3 are those, which if altered, would have a significant effect on safety. The staff 13-2

.w ._ _ _ _ _ _ _ _ _ _ _ ____ _ __ _ _ _ _ _ _ ___

! l l PRELIMINARY concludes therefore, that the North Anna ISFSI TS are in compliance with 10 CFR 72.44(c)(4).

13.4 Administrate;ve Controls l

l The Administrative Controls portion of the TS includes controls on tne organization and i management, record keeping, review and audit and reporting processes necessary to assure l that the operation involved in storage cf spent fuel at the ISFSI are performed in a safe manner. l The Administrative Controls included in the North Anna TS are listed in Table 13-4. The table I also lists the section of this SER which documents the acceptability for each design feature TS.  !

! Table 134 TS ITEM ADMINISTRATIVE CONTROL ASSOCIATED SER SECTION 5.1 Responsibility 12.1 l 5.2 Organization 12.1 5.3 Facility Staff Qualifications 12.1 l 5.4 Procedures 12.4

! 5.5 Programs 12.4 l

l Based on an extensive review of the application, the staff concludes the administrative controls l

l listed in Table 13-4 are those necessary to assure that the operation involved in storage of j

spent fuel at the ISFSI are performed in a safe manner. The staff concludes therefore, that the  ;

l North Anna ISFSI TS are in compliance with 10 CFR 72.44(c)(5) and (d). 1 i

13.6 Changes to Submitted Documents in the original application regarding the North Anna ISFSI, the applicant proposed a set of Technical Specifications. However, the staff undertook an initiative to reformat the proposed TS to adopt the conventions and cestoms developed through the NRC's Technical '

l Specifications improvement Program (TSIP). The TSIP led to the development of a an

! improved set of standard Technical Specification for each of the four operating reactor vendor ,

l types These improved TS are documented in NUREG 1431, NUREG 1432, NUREG 1433 and  !

NUREG 1434. In reformatting the proposed North Anna ISFSI TS, the staff adopted the tabular format, the logic conventions, the use and applications rules and some of the standard I definitions contained in the operating reactor improved TS.

The staff forwarded the draft reformatted TS to the applicant in a letter dated December 4,1997.

l The applicant reviewed the staff's proposal and made several modifications. The applicant

! resubmitted proposed TS in the revised format in a letter dated April 1,1998.

The applicant made several additional revisions to the draft TS in a letter dated May 28,1998.

The staff, in issuing the final TS with the license, revised proposed TS 5.5.2 to correctly reference 10 CFR 72.44(d). The staff leview of the proposed TS described in Section 13.1 -

13-3 L ____ - _____-_____ __________ _ _ _ _ - _ _ _ _ . _ _ _ - -- - - - - - - - - - - - - - - - - - - - - - - - = - - - - -

r- r -

I l

PRELIMINARY  !

l through 13.4 above includes consideration of all revisions to the proposed TS through the May 28,1998.

13.8 License Conditions 10 CFR 72.44 states that each license issued under Part 72 shall include license conditions which may derive from the Safety Analysis Report, which may pertain to design, construction and operation or which the Commission may include as it determines is appropriate. In addition,72.44 specifies certain license conditions which apply to each license issued under Part 72 whether or not they are explicitly stated in the license. Those conditions are specifed in 72.44(b)(1) through (b)(6) and are binding on the North Anna license but are not explicitly restated in the North Anna ISFSI license.  !

l Each of the explicit license conditions in the North Anna license are briefly described in the table i below. l t

LICENSE DESCRIPTION ASSOCIATED SER ,

CONDITION SECTION 6A Nature of Material Stored at ISFSI .1.2 7A Chemical Form of Stored Material 1.2 8A Maximum Amount of Stored Material 1.2 9 Authorized Use and Authorized Cask 1.1 l 10 Authorized Place of Use 2.1 11 Technical Specifications 13 12 Physical Security Plan Controls 15 13 Environmental Related Technical Specifications 13 14 Quality Assurance Program Controls 16 15 Emergency Plan Controls 14 i 16 Crane Enclosure 5.2 17 Design Construction and Operation in - N/A I Accordance with Commission Regulations 18 Relation to Part 50 License 12.4 l '9 Exemptions issued With License 13.7 13-4

l PRELIMINARY l

l l

13.7 Exemptions By letter dated April 29,1998, pursuant to the provisions of 10 CFR Part 72.7, the applicant I requested exemptions from the requirements of 10 CFR 72.44(d)(3) and 72.72(d). The l applicant requested permission to submit a single effluent release report encompassing the l

NAPS and the North Anna ISFSI, by May 1 of each year, instead of submitting a separate report for the ISFSI within 60 days of January 1 of each year, as required by 10 CFR 72.44(d)(3).

Additionally, the applicant requested to maintain a single set of spent fuel storage records at a records storage facility that meets the requirements ANSI N.45.2.9-1974 instead of maintaining duplicate records at separate locations as required by 72.72(d). Separately, the staff identified l

the need for an exemption to 10 CFR 72.124(b) to ensure that the North Anna ISFSI license is consistent with the staff's conclusion that the TN-32 storage cask does not require periodic verification of the neutron poison effectiveness.

The staff evaluated the public health and safety and environmentalimpacts of the proposed exemption and determined that granting the exemptions would not result in any significant impacts as follows:

Duplicate Record Storage (10 CFR 72.72(d))

The applicant stated that, pursuant to 10 CFR 72.140(d), the Virginia Power Operational Quality Assurance (QA) Program Topical Report will be used to satisfy the QA requirements for the ISFSI. The QA Program Topical Report states that QA records are maintained in accordance with commitments to ANSI N45.2.9-1974. ANSI N45.2.91974 allows for the storage of QA records in a duplicate storage location sufficiently remote from the original records or in a records storage facility subject to certain provisions designed to protect the records from fire and other adverse conditions. The applicant seeks to streamline and standardize record keeping procedures and processes for the NAPS and the North Anna ISFSI spent fuel records.

The applicant states that requiring a separate method of record storage for ISFSI records diverts resources unnecessarily.

The staff considered the applicant's request and determined the staff determined that granting the proposed exemptions from the requirements of 10 CFR 72.72(d) is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest. The staff approves the exemption, subject to the following conditions:

a) Virginia Power may maintain records of spent fuel and high level radioactive waste in storage either in duplicate as ;equired by 10 CFR 72.72(d), or altematively, a single set of records may be maintained at a records storage facility that satisfies the standards set forth in ANSI N45.2.9-1974.

13-5

w PRELIMINARY b) All other requirements of 10 CFR 72.72(d) shall be met.

Annual Effluent Release Report (10 CFR 72.44(d)(3))

The applicant is preparing to operate the North Anna ISFSI described in the May 9,1995, l application subject to issuance of an NRC license pursuant to 10 CFR Part 72. The applicant is implementing the necessary processes and procedures to operate the ISFSI and seeks to have those processes make efficient use of resources. With regard to annual effluent release reporting, the applicant already prepares and submits effluent release reports for the NAPS by May 1 of each year pursuant to the NAPS Technical Specifications. The NAPS effluent release report provides the same type of data and is generated by the same licensee program as would the annual effluent release report for the ISFSI. The applicant states that submittal of separate reports for the NAPS and the ISFSI, as would be required without the exemption from 72.44(d)(3) would entail duplication of report preparation and verification data.

The staff considered the applicant's request and determined the staff determined that granting the proposed exemptions from the requirements of 10 CFR 72.44(d)(3) is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest. The staff approves the exemption, subject to the following conditions:

a) Virginia Power shall submit an annual report, as required by 10 CFR 72.44(d)(3), no later than May 1 of each year. This report may be included in the NAPS Effluent Release Report submitted under the North Anna 10 CFR Part 50 license.

b) All other requirements of 10 CFR 72.44(d)(3) shall be met.

Neutron Poison Effectiveness Verification (10 CFR 72.124(b))

n

! With regard to verification of neutron poison efficacy, the exemption is necessary to ensure that the licensing process for the North Anna ISFSI takes into account previous staff conclusions (TN 32 SER) that fixed neutron poisons in the TN-32 storage cask will remain effective over the 20-year period of the license. Periodic verification of neutron poison effectiveness is not j possible for the TN-32 cask and, consistent with the staff's conclusion described above, is not l

necessary.

The staff considered the exemption and determined the staff determinect that granting the proposed exemption from the requirements of 10 CFR 72.124(b) is authorked by law, will not endanger life or property or the common defense and security, and is otherwise in the pubiic interest. The staff approves the exemption, subject to the following conditions:

1 a) Virginia Power is not required to periodically verify the effectiveness of the neutron I absorber material used in the TN-32 storage cask.

b) All other requirements of 10 CFR 72.124(b) shall be met. J For this~actionTan Environmental ~ Assessment arid Finding Of No;Significant impact has been prepared and publishediin thefederal Register _(ij),j 13-6

PRELIMINARY 13.8 Findings F13.1 As described above, the staff concludes that the Technical Specifications for the North Anna ISFSI are in compliance with the requirements of 10 CFR 72.d4(c) and (d).

F13.2 As specified in Section 13.7, exemptions to the requirements of 10 CFR 72.44(d)(3),

10 CFR 72.72(d) and 10 CFR 72.124(b) are granted.

l f

l 13-7 i

PRELIMINARY 14,0 EMERGENCY PLANNING Requirements for a description of plans for coping with emergencies are included in 10 CFR 72.24. Detailed requirements fer emergency planning are specified in 10 CFR 72.32 and include provisions for classifying events, detecting, assessing and mitigating events, assigning  ;

responsibilities, communicating information and exercises.

l This review was performed according to Chapter 13 of NUREG-1567, Standard Review Plan for l

SpentFuelDry Storage Facilities.

14.1 Evaluation Paragraph (c) of 72.32 specifies that for an ISFSI located on the site of or within the exclusion

area of a nuclear power reactor licensed for operation by the Commission, the emergency plan  ;

required by 10 CFR 50.47 shall be deemed to satisfy the requirements of 10 CFR 72.32. The .

applicant does have an Emergency Plan for the NAPS which has been deemed to satisfy the requirements of 10 CFR 50.47. The NRC approved the North Anna Emergency Plan (NAEP) by letter dated July 22,1996. From time to time, the applicant has revised the NAEP pursuant to 10 CFR 50.54(q). On the basis of having an approved emergency plan, the staff concludes the applicant meets the requirements of 10 CFR 72.32(c) and thus satisfies the requirements of 10 CFR 72.32.

l Notwithstanding the provisions of 72.32(c), the staff reviewed the changes the applicant made to the approved plan to incorporate consideration of the ISFSt. These changes are described in Chapter 9.5 of the NA ISFSI SAR. In a letter dated January 23,1998 the applicant submitted Revision 21 of the NAEP which included the changes described in the SAR. In a latter dated April 13,1998, the applicant committed to make several additional administrative changes to the NAEP regarding the ISFSt. The staff reviewed the following changes or change commitments i related to the ISFSI:

(1) Site Description. The applicant committed to revise Section 2.1 of the NAEP to include a description of the ISFSIin the overall site description.

(2) Types and Classification of Accidents: The applicant revised Table 4.1 and Appendix 10.11 l of the NAEP to include two ISFSI events classified as Notice of Unusual Event. These events are (1) cask seal leakage and (2) cask drop or handling mishap. Based on the very low consequences of a loss of cask confinement, the staff concludes that the NOUE classification is appropriate for these events (3) Reference to Part 72 Requirements: The applicant committed to revise Section 2.2 of the L NAEP to incorporate reference to the emergency planning requirement of 10 CFR 72.32(c).

l: (4) Exclusion Area Map: The applicant committed to revise the Exclusion Area Map in l' Appendix 10.3 to depict the location of the ISFSI.

The staff concluded these changes enhanced the implementation of Emergency Plans with respect to the ISFSI and were acceptable. The staff also concluded the SAR description of the 14-1 l

ll

7 l

PRELIMINARY Emergency Plan satisfied the requirements of 10 CFR 72.24(k).

14.2 Findings F14.1 Based on the existence of an approved North Anna Emergency Plan which meets the requirements of 10 CFR 50.47, pursuant to 10 CFR 73.32(c), the requirements of 10 CFR 72.32 are met.

14.3 License Condition Because the Emergency Plan for the ISFSI is based on a program that was approved pursuant l to 10 CFR Part 50, the staff has imposed a license condition requiring that prior to termination of the Part 50 license, the licensee must obtain staff approval of a stand alone ISFSI Emergency Plan that satisfies the requirement.; of 10 CFR 72.32.

1 i

l l

l 9

l 14-2  !

b

4 l

1 PRELIMINARY

! ' 15.0 PHYSICAL PROTECTION l

Requirements for a description of the physical protection design features and prograin are specified in 10 CFR 72.24(o). Requirements for physical protection for the ISFSI are specifW in 10 CFR 72, Subpart H and include requirements for the physical security plan, physica!

security design features and contingency plan. In Subpart H of Part 72, the regulations make reference to applicable requirements of Part 73 to further speedy ISFSI physical security requirements i

L in a letter dated January 29,1998, the applicant subruitted a Physical Secunty Plan l encompassing the existing North Anna and Surry Power Stations, the existing Surry ISFSI and l - the proposed North Anna ISFSI. In a separate letter dated January 29,1998, the applicant l

submitted a letter that itemized the individual requirements in Part 73 applicable to an ISFSI and L described how it plans to comply with those requirements at the North Anna ISFSI. By !stter dated October 2,1997, the applicant submitted the Nuclear Security Personnel Training and Qualification Plan for Surry and North Anna Power Stations, Revision 1.

15.1 Threat The proposed North Anna ISFSI will be located within the owner controlled area of the operating North Anna Power Station site but within a separate protected area (PA). The protection strategy for the ISFSI is currently based on protecting the site from radiological sabotage including the use of explosives to breach the casks and disperse material, in conjunction with the relevant sections of 10 CFR Part 72 and 73.

( 15.2 Physical Security Plan l The ISFSI at North Anna will be an unmanned facility that will store spent fuel in a dry cask storage configuration within its own protected area. When authorized activities are required within the ISFSI, security force members from the operating reactor site will be utilized to f support these operations. The physical security plan commitments for the ISFSI are located within a separate chapter of the North Anna operating reactor Physical Security Plan. All l activities associated with the ISFSI day-to-day operation ( response to alarm annunciations, searches, patrols, access control, etc.) are supported by the security organization at the reactor l

site since activities will be minimal and have no impact on the security program at the operating reactor site. The security procedures for the ISFSI are based on the applicable procedures utilked for the operating reactor site and those specific procedures that apply to the ISFSI site.

l The procedures provide additional detailed information that support the commitments within the security plan.

In reviewing the physical security plan submittals, the staff noted that it contained adequate )

design provisions for physical security, a safeguards contingency plan, provisions for guard training, and provisions for tests, inspections and audits. The staff thus concluded that the applicant met the provisions of 10 CFR 72.180. The staff concluded the Safeguards l

. Contingency Plan satisfied the requirements of 10 CFR 72.184. The staff also concluded that l the design information satisfied the requirements of 10 CFR 72.182.

15-1 I

l

t

[ .

PRELIMINARY 15.3 Physical Safeguards Security Systems The ISFSI security systems are based on a modified version of the 10 CFR 73.55 requirements as described in the applicant's January 29,1998 letter. The site will have a protected area (PA) barrier fence that totally surrounds the spent fuel storage site. An intrusion detection system (105) will be positioned in proximity to the PA barrier so that unauthorized attempts to enter the site will result in an alarm annunciation at a security alarm station. To determine what has l caused the alarm, the site PA will have closed circuit television (CCTV) for assessment l

purposes. These CCTV are positioned to give full coverage of the PA barrier and interior areas of the ISFSI. On either side of the PA barrier, there will be isolation zones which will remain clear of objects so that CCTV assessment is not hindered. The site will be illuminated so that assessment of unauthorized activities can be determined during the hours of darkness. The lighting levels will be sufficient to assess all activities within the PA and the exterior isolation zones. Unescorted access to the ISFSI will be controlled to authorized individuals who are .

! issued a company picture badge. Visitors will be escorted by a trained individual who has

! authorized access to the ISFSI. Prior to entry into the ISFSI, personnel, vehicles, and packages l entering the PA will be searched for unauthorized devices that could be used for radiological sabotage. Tests of the security system equipment will be conducted to determine system effectiveness in accordance with performance and operability requirements. Periodic patrols of

. the ISFSI will be conducted and arrangement with the local law enforcement agency (LLEA) will I be made to support the site should unauthorized activities occur. Based on the information

! described above, the staff concluded that, pursuant to 10 CFR 72.180, the applicant satisfes

( the applicable requirements of 10 CFR Part 73 for an ISFSt.

l 15.4 Findings F15.1 Pursuant to 10 CFR 72.180, the applicant has developed a physical security plan which satisfes the requirements in 10 CFR Part 73 which are applicable to an ISFSI.

F15.2 Based on the information provided by the applicant as described above, the staff concludes the applicant has committed to a protective strategy with objectives to protect the site against the threat of radiological sabotage and that the applicant has satisfied the requirements of 10 CFR 72, Subpart H. The staff further concludes that the storage of spent fuel at this site is not inimical to the common defense and security.

15.5 License Conditions A condition has been included in the license which ensures that changes to the physical security plan, guard training plan and pc:tions of the safeguards contingency plan are made in accordance with the requirements of 10 CFR 72.186.

15-2

O O

PRELIMINARY 16.0 QUALITY ASSURANCE Requirements for a description of the quality assurance (QA) program are specifieki in 10 CFR ,

72.24. Detailed requirements for the quality assurance program are specified in 10 CFR 72, '

Subpart G and include requirements applying to design, purchase, fabrication, handling, shipping, storing, cleaning, essembly, maintenance, inspection , testing, operation, repair and modification of systems structures and components that are important to safety.

This review was performed according to Chapter 15 of NUREG-1567, Standard Review Plan /br SpentFuelDry Storage Facilities.

16.1 Evaluation Paragraph (b) of 72.140 states that each licensee shall establish, maintain and execute a quality assurance program satisfying each of the applicable criteria of Subpart G. Paragraph (d) of 72.140 states that a Commission approved quality assurance program which satisfies the applicable criteria of Appendix B of Part 50 and which is established, maintained and executed with regard to an ISFSI will be acceptad as satisfying the requirements of paragraph 72.140(b).

In Chapter 6 of the North Anna ISFSIlicense application and Chapter 11 of the North Anna ISFSI SAR, the applicant stated that the governing document for the 10 CFR 50 Appendix B quality assurance program was VEP-1 5A (Updated) " Operational Quality Assurance Program j Topical Report? In a letter dated February 28,1994, the NRC found that the program described 1 in VEP-1-5A (Updated) satisfied the requirements of 10 CFR 50 Appendix B. In the North Anna ISFSI license application and in Section 11.1 of the North Anna ISFSI SAR, the applicant stated that VEP-1-5A (Updated) would be applied to all activities associated with the ISFSI considered important to safety and that no changes to VEP-1-5A were required for the ISFSI activities.

In a letter datad April 9,1998, the applicant submitted Revision 33 to the North Anna Power Station SAR which included a revision to VEP-1-5A (Updated). This revision clarified the )

position description for various North Anna management positions by noting responsibilities for j the ISFSl. .

I Based on the existing approved QA program that satisfies 10 CFR 50, Appendix B and the applicant's stated intent to apply that program to the ISFSI, and % clarification included in the April 9,1998 submittal, the staff concludes that the applicant has met the conditions of 72.140(d) and therefore satisfies the requirements of 72.140(b). The staff also concludes that the i

description of the QA program in the SAR satisfies the requirements of 72.24(n).

16.2 Findings As stated above, based on the existing approve d QA program that satisfies 10 CFR 50, l Appendix B and the applicant's stated intent to apply that program to the ISFSI, the staff concludes that the applicant has met the conditions of 72.140(d) and therefore satisfies the requirements of 72.140(b). The staff also concludes that the description of the QA program in the North Anna ISFSI SAR satisfies the requirements of 72.24(n).

16-1

a O

PRELIMINARY 16.3 License Condition f

Because the quality assurance for the ISFSI is based on a program that was approved pursuant to 10 CFR Part 50, the staff has imposed a license condition requiring that prior to termination of i the Part 50 license, the licensee must obtain staff approval of a stand alone ISFSI QA program j that satisfies the requirements of 10 CFR 72, Subpart G.

I i

l 0

l 16-2 l

l L___________-._______________ _ _ _ _ _ _ _ _ _ _ _ _ _ - - --_ _ _ _ _ - . _ _ _ _ _ _ _ _ _ - -

PRELIMINARY

17. DECOMMISSIONING Requirements related to decommissioning of an ISFSI are identified in 10 CFR 72.30, and 72.130.10 CFR 72.30 provides requirements for a site specific decommissioning plan, including decontamination of the site and facilities, disposal of residual radioactive materials after all spent fuel has been removed, the decommissioning funding plan and the cost estimate for decommissioning.

10 CFR 72.130 provides requirements for decommissioning and states, in part, that the ISFSI shall be designed for decommissioning. Among the items to be addressed under this part are the provisions to facilitate decontamination of equipment, the provisions to minimize the quantity of radioactive wastes and contam!nated equipment and the provisions to facilitate the removal of radioactive wastes and materials at the time of permanent decommissioning.

l This review was performed according to Chapter 16 of NUREG-1567, Standard Review Plan fbr Spent FuelDry Storage Ficilities.

17.1 Decommissioning Plan and Decommissioning Facilitation.

In the license application and NA ISFSI SAR, the applicant described potential dispositioning of the stored spent fuel at the time of decommissioning of the ISFSI similar to those described in the TN 32 TSAR. The TSAR states that the SSSC with its load of spent fuel could be placed in a transportation overpack. The TSAR also indicates that the spent fuelin the SSSC could be unloaded and placed in a licensed transportation package for shipment to subsequent storage facility or repository. The applicant did explicitly state in Section 4.6 of the North Anna ISFSI

, SAR that the spent fuel pool would remain functional until the ISFSI is decommissioned, thereby

[ preserving the wet transfer option. The exact method by which the North Anna spent fuel is removed from the ISFSI is beyond the scope of this safety evaluation. However, the staff believes that either loading of the loaded SSSC into a future licensed overpack or unloading of the spent fuel from the SSSC into a licensed transportation package are reasonable assumptions regarding the dispositioning of the fuel prior to the decommissioning of the ISFSI and are acceptable with regard to the requirements in 72.130 that the facility be designed for decommissioning.

At decommissioning, the cask components will be both contaminated and activated. With regard to decontamination, the applicant and vendor both indicated in the TN-32 TSAR that loose surface contamination could be removed with high pressure water sprays. The vendor also described that fixed surface contamination could be removed using chemical etching or electro-polishing. Upon successful decontamination, the applicant stated that SSSC components could be cut up for scrap, or if any components remain contaminated, such components could be shipped as low level waste to a low level waste facility.

With regard to activation of cask components, the applicant referenced the TN 32 TSAR discussion of the issue. Section 2.4 of the TN 32 TSAR describes the cask vendor's evaluation of activation. The TN 32 vendor assumed that (1) the SSSC contained 32 design basis PWR assemblies, (2) the neutron flux remained constant over the twenty year service life of the cask and (3) the neutron spectrum was the same as in a PWR reactor. The vendor calculated that the 17-1 i

D o

PRELIMINARY total activity due to activation after twenty years amounted to less than 0.08 Ci per SSSC. The specific activity of various isotopes in the cask components were compared to the Class A waste limits of 10 CFR 61.55. The specific activity was shown to be a small fraction of the Class A waste limits. Therefore, the applicant concluded that, after surface decontamination, the SSSC could be scrapped. In the TN-32 SER with regard to activation of cask components, the staff agreed with the calculated activity in the TN-32 cask components and agreed with the conclusions that calculated activity is a negligible fraction of the limits for Class A waste.

The applicant stated that, due to the leak tight design of the cask, no residual contamination of the storage pad is expected. The applicant did not specifically quantify activation of the storage pad due to neutron flux from the stored fuel. However, in its submittal dated April 14,1997, the applicant stated that, due to the low neutron flux from the bottom of the cask relative to the cask interior and due to the low activaion potential of the concrete, very little activation of the concrete will occur. The staff agrees that no contamination of the storage pad, fence or peripheral structures is expected. The staff agrees that, because of the material used in the construction of the storage pad and the low neutron flux, the specific activity in the pad materials will also be a negligible fraction of the limits for Class A waste in 10 CFR 61.55 Site specific decontamination procedures will have to be developed at the time of decommissioning. Other than procedure development, the staff notes that there are no other site specific considerations in the decontamination and activation analysis beyond those evaluated in the TN-32 SER. The staff concludes, therefore, that the applicants description of decontamination processes for the SSSC components are acceptable with regard to the requirements in 72.130 that the facility be designed for decontamination.

17.2 Decommissioning Funding Virginia Power provided a decommissioning plan in the license application and a description of the plan in Section 4.6 of the North Anna ISFSI SAR. Additionalinformation was provided by the applicant in a letter dated April 14,1997.

Decommissioning funding assurance for the North Anna ISFSI is addressed in 10 CFR 72.30(c)(5), which in tum references the provisiocs of 10 CFR 50.75(e) for those ISFSI applicants that are " electric utilities." The co-ownere. each of which meets the NRC definition of

" electric utility," have chosen to use the extemal sinking fund method of assuring that funds will be available to decommission the Nodh Anna ISFSI.

Virginia Power projects that the ISFSI will be licensed for twenty years, with operation beginning in 1998. Total decommissioning cost, which will be expended at the time of North Anna reactor facility decommissioning, is estimated to be 516 million. Both Virginia power and Old Dominion Electric Cooperative maintain master trust accounts for their respective shares of all decommissioning related activities, including ISFSI c' commissioning. Each co-owner intends to continue to make annual trust fund contributions until necessary are accumulated at the time of permanent shutdown of the North Anna reactor facility. the Virginia State Corporation Commission and the Federal Energy Regulatory Commission have approved rate allowances for North Anna decommissioning costs including ISFSI costs. In a letter dated January 28,1998, the applicant stated that subaccounts have been established for the Company's nuclear 17-2

PRELIMINARY decommissioning trusts to separately track the amounts related to the North Anna ISFSI.

For the above reasons, the co-owners are expected to have adequate funds in their extemal trust accounts to successfully complete decommissioning the North Anna ISFSI. The staff, therefore, concludes that the co-owners have provided reasonable assurance that the funds will be available in the amounts needed to decommission the North Anna ISFSI.

The staff concludes that the decommissioning f.nancial information included in Virginia Power's application comply with the relevant provisions of 10 CFR 72.22(e),72.30(c)(5) and 50.75(e),

and that, therefore, the co-owners have demonstrated reasonable assurance that funds will be available to decommis'sion the North Anna ISFSI in a manner that protects the public health and safety.

17.3 Record Keeping In a letter dated April 23,1998, the applicant stated that following records related to decommissioning will be retained until the North Anna site is released for unrestricted use:

(1) Records of spills or other unusual occurrences involving the spread of contamination in and around the ISFSI, (2) As built drawings and modifications of structures and equipment at the ISFSI (3) A !ist in a single document and updated no less than every two years of all areas designated and formerly designated as restricted areas as defined by 10 CFR 20.1003 and all areas outside the restricted area requiring documentation per item (1) above.

(4) Records of the cost estimate performed for the decommissioning funding plan and the funding method used for assuring funds.

The staff reviewed the above commitments by the applicant and concluded that they satisfied the requirements of 10 CFR 72.30(d).

17.4 Findings F17.1 The staff has reviewel the proposed Decommissioning Plan documentation submitted by the applicant for the North Anna ISFSI facility in accordance with the standard review plan for spent fuel dry storage facilities, and the description of the plan in the North Anna ISFSI SAR. The staff has determined that the decommissioning plan submitted by the applicant provides reasonable assurance that the decommissioning issues for the North Anna ISFSI facility have been adequately characterized, so that the site will ultimately be available for unrestricted use for any private or public purpose The staff, therefore, concludes that the proposed decommissioning plan complies with 10 CFR Part 72 requirements.

F17.2 The staff has reviewed the decommissioning funding plan documentation submitted by the applicant for the North Anna ISFSI facility in accordance with the standard review 17-3 I

I

y _ _ _ _ _ _ _ _ _ ..

PRELIMINARY l

plan for spent fuel dry storage facilities. The staff has determined that the i

decommissioning funding plan submitted by the applicant is sufficient to provide j reasonable assurance that costs related to decommissioning, as characterized by the l proposed decommissioning plan, have been adequately estimated. The staff, therefore, concludes that the cost estimate in the decommissioning funding plan complies with 10 CFR Part 72 requirements.

F17.3 The staff has reviewed the financial assurance documentation submitted by the applicant, as part of the decommissioning funding plan for the facility, in accordance with the standard review plan for spent fuel dry storage facilities. The staff has determined that the financial assurance mechanisms submitted by the applicant are sufficient to provide reasonable assurance that adequate funds will be available to decommission the facility, so that the site will ultimately be available for unrestricted use for any private or public purpose. The staff, therefore, concludes that the financial assurance mechanisms in the decommissioning funding plan comply with the 10 CFR Part 72.

l I7-4 l

_ _ _ _ _ _ _ _ _ _ _ _ _