PLA-8109, Supplement to Request for Exemption from Certain Requirements of 10 CR 72.212 and 10 CFR 72.214 Resulting from Fuel Basket Design Control Compliance (PLA-8109)
| ML24081A335 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/21/2024 |
| From: | Casulli E Susquehanna, Talen Energy |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| PLA-8109 | |
| Download: ML24081A335 (1) | |
Text
Edward Casulli Site Vice President March 21, 2024 Attn: Document Control Desk Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3795 Fax 570.542.1504 Edward.Casulli@talenenergy.com Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION SUPPLEMENT TO REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 72.212 AND 10 CFR 72.214 RESULTING FROM FUEL BASKET DESIGN CONTROL COMPLIANCE PLA-8109 TALEN~
ENERGY 10 CPR 72.7 Docket Nos.
50-387, 50-388 and 72-28
References:
- 1) Susquehanna letter to NRC, "Request for Exemption from Certain Requirements of 10 CPR 72.212 and 10 CPR 72.214 Resulting from Fuel Basket Design Control Compliance (PLA-8107)," dated March 19, 2024 (ADAMS Accession No. ML24079A070).
- 2) NRC presentation, "Public Meeting with Holtec, Holtec Users Group, and General Licensees - Path Forward for General Licensees affected by the Continuous Basket Shims basket design change," dated March 06, 2024 (ADAMS Accession No. ML24065Al l 8).
Pursuant to 10 CPR 72.7, "Specific Exemption," Susquehanna Nuclear, LLC (Susquehanna),
submitted, in Reference 1, a request for exemption from certain requirements of 10 CPR 72.212(a)(2), 72.212(b)(3), 72.212(b)(5)(i), 72.212(b)(ll), and 72.214 for the Susquehanna Steam Electric Station (SSES). These regulations require, in part, that a licensee store its irradiated fuel in compliance with the terms and conditions of the spent fuel storage cask's Certificate of Compliance (CoC). This exemption request was specific to the conditions of Holtec International, Inc. (Holtec) CoC Number 1032 (hereafter, CoC No. 72-1032). CoC No.
72-1032 is issued for the Holtec International Storage Module Flood and Wind (HI-STORM FW) Multi-Purpose Canister (MPC) Storage system which contains the Susquehanna-utilized model MPC-89, including the continuous basket shim (CBS) variant, MPC-89CBS. The requested exemption would allow for the loading of new canisters of the CBS style.
Document Control Desk PLA-8109 Susquehanna requested approval of the exemption request by May 31, 2024, in order to avoid delays to the planned Spent Fuel Storage campaign beginning in August 2024.
The NRC held a public meeting with general licensees on March 06, 2024, in which expectations for exemption requests were presented to general licensees to support expedient NRC reviews for urgent licensee needs (Reference 2). The enclosure to this letter provides additional information to assist the NRC staff in a timely review of the Susquehanna exemption request. This supplement does not change any information provided in Reference 1.
Susquehanna has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Reference 1 and determined the information provided herein does not impact the original conclusions in Reference 1. The future use ofMPC-89CBS at Susquehanna is in the public interest in that it avoids unnecessary operational risks for the SSES Units 1 and 2 that would result from the alternative to the proposed action.
There are no new or revised regulatory commitments contained in this submittal.
Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager-Nuclear Regulatory Affairs, at (570) 542-1818.
E. Casulli
Enclosure:
Supplemental Information Copy:
NRC Region I Mr. R. Lorson, Region I Administrator Ms. J. England, NRC Senior Resident Inspector Ms. A. Klett, NRC Project Manager Mr. M. Shields, PADEP/BRP
Enclosure to PLA-8109 Supplemental Information
Enclosure to PLA-8109 Page 1 of 3 Supplemental Information The Holtec International Storage Module Flood and Wind (HI-STORM FW) dry cask storage system is designed to hold and store spent fuel assemblies for independent spent fuel storage installation deployment. The system is listed in 10 CFR 72.214 as Certificate of Compliance (CoC) Number 1032 (hereafter, CoC No. 72-1032). This system is used by Susquehanna Nuclear, LLC (Susquehanna), at the Susquehanna Steam Electric Station (SSES) in accordance with 10 CFR 72.210, General license issued.
In Reference 1, pursuant to 10 CFR 72.7, Specific Exemptions, Susquehanna requested an exemption from certain requirements of 10 CFR 72.212(a)(2), 10 CFR 72.212(b)(3), 10 CFR 72.212(b)(5)(i), 10 CFR 72.212(b)(11), and 10 CFR 72.214 for SSES. These regulations require, in part, that a licensee store its irradiated fuel in compliance with the terms and conditions of the spent fuel storage casks CoC. Specifically, Susquehanna requested an exemption from certain requirements in Amendment No. 5 of the Holtec International, Inc. (Holtec) CoC No. 72-1032 for the HI-STORM FW Multi-Purpose Canister (MPC) Storage system. If approved, the exemption will allow the loading of new canisters of the Continuous Basket Shim (CBS) style.
Susquehanna requested approval of the exemption request by May 31, 2024, to support the loading of the next MPC-89CBS canisters beginning in August 2024.
In the exemption request (Reference 1), Susquehanna stated:
It is in the publics interest to grant an exemption, since dry storage places the fuel in an inherently safe, passive system. This exemption would allow the upcoming loading campaign to proceed on time to move fuel into the dry storage condition and maintain the ability to offload fuel from the reactor, thus allowing continued safe reactor operation.
Specifically, if the 2024 loading campaign is canceled or deferred, then in 2025 when the next new fuel batch is received followed by the refueling outage core discharge, Susquehanna will be challenged to support a full core offload until the deferred dry fuel storage campaign is performed, or the storage in the fuel pools is otherwise optimized.
The following is intended to provide additional detail to support the conclusions above.
Enclosure to PLA-8109 Page 2 of 3 Maintain Full Core Discharge Capabilities:
Susquehanna has continued to maintain a healthy margin in the spent fuel pools in support of a full core discharge capability for one (1) reactor unit with a goal of providing a full core discharge for both reactor units. The inability to utilize the MPC-89 canister containing the CBS basket in the 2024 Spent Fuel Storage campaign significantly impacts the ability to effectively manage margin for full core discharge capability.
The 2024 Spent Fuel Storage campaign will support increasing the available cell locations by a quantity of 534 which followed by the 2025 Refueling Outage fuel discharge, will reduce the available cell locations by a quantity of 300. If the 2024 Spent Fuel Storage campaign is not performed, due to resource limitations discussed in further detail below, the expected increase in margin of 534 locations will not be realized until 2027. This margin reduction will challenge the ability to provide a full core discharge capability for one (1) reactor unit and further prolong the goal of obtaining full core discharge capability for both reactor units. Additionally, increased inventory in the spent fuel pool would likely require additional fuel moves to facilitate a full core offload. Therefore, the margin reduction presents a potential reactivity management risk due to increased fuel handling operations pre-and post-outage.
Logistical Considerations and Cascading Impact:
Spent Fuel Storage campaigns are scheduled, planned, and budgeted multiple years in advance of project execution. Each Spent Fuel Storage campaign utilizes resources with specialized qualifications for spent fuel handling, processing and storage. Each campaign is scheduled months to years in advance to ensure that these resources are appropriately allocated throughout the industry. These resources also support other specific projects and tasks that include but are not limited to Fuel Pool Cleanout and Refueling Outages. Additionally, specialty equipment and components are secured months in advance of a planned campaign by Holtec to ensure the ability to support the industry. Any delay encountered with a Spent Fuel Storage campaign or any other project has an obvious cascading impact on all other scheduled activities that utilize these specialized resources.
Margin to Capacity:
Once spent fuel pool capacity is reached, the ability to refuel the operating reactor is limited, thus taking away a highly reliable clean energy source.
Enclosure to PLA-8109 Page 3 of 3
==
Conclusion:==
Maintaining adequate full core discharge capability margin ensures operational flexibility necessary for sustained safe and efficient operation of the operating nuclear facility.
Additionally, based on the logistical impacts as discussed above when compared to the minimal safety benefit discussed in the Reference 2, delaying the use of the MPC-89CBS canisters does not provide a measurable public benefit. In contrast, approval of the referenced exemption request supports the continued safe, efficient, and cost-effective operation of the SSES.
References:
- 1. Susquehanna letter to NRC, Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 Resulting from Fuel Basket Design Control Compliance (PLA-8107), dated March 19, 2024 (ADAMS Accession No. ML24079A070).
- 2. NRC Memorandum, Safety Determination of a Potential Structural Failure of the Fuel Basket During Accident Conditions for the HI-STORM 100 and HI-STORM Flood/Wind Dry Cask Storage Systems, dated January 31, 2024 (ADAMS Accession No. ML24018A085).