L-PI-24-012, Independent Spent Fuel Storage Installation - License Amendment Request: Revise Independent Spent Fuel Storage Installation (ISFSI) License Conditions 23(a), 24(A)(2), and 24(B)(2)

Independent Spent Fuel Storage Installation - License Amendment Request: Revise Independent Spent Fuel Storage Installation (ISFSI) License Conditions 23(a), 24(A)(2), and 24(B)(2)

ML24095A075
Person / Time
Site:	Prairie Island
Issue date:	04/02/2024
From:	Conboy T Northern States Power Company, Minnesota, Xcel Energy
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
L-PI-24-012
Download: ML24095A075 (1)

Text

1717 Wakonade Drive Welch, MN 55089 (l Xcel Energy

April 2, 2024 L-PI-24-012 10 CFR 72.56

ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Prairie Island Independent Spent Fuel Storage Installation Docket 72-10 Materials License No. SNM-2506

License Amendment Request: Revise Independent Spent Fuel Storage Installation (ISFSI)

License Conditions 23(a), 24(A)(2), and 24(B)(2)

Pursuant to 10 CFR 72.56, Northern States Power Company, a Minnesota Corporation, doing business as Xcel Energy (hereafter NSPM), hereby requests a license amendment to Renewed Special Nuclear Materials (SNM) License No. SNM-2506 to change License Conditions 23(a), 24(A)(2), and 24(B)(2). The subject license conditions are aging management activities with specified inspecti on intervals of three months or one quarter.

NSPM proposes to revise the license conditions to describe the inspection intervals similar to Technical Specifications Surveillance Requirement Frequency, allowing up to 1.25 times the specified intervals to account for scheduling challenges, including but not limited to periods of extreme cold weather or other high-priority plant activities.

The Enclosure provides NSPMs evaluation of the proposed change including a proposed markup of the PI ISFSI Renewed License SNM-2506 pages.

NSPM requests approval of the proposed amendment within 12 mont hs of acceptance, with an implementation period of 90 days.

NSPM is notifying the State of Minnesota of this request by transmitting a copy of this letter and enclosures to the designated State Official.

Please contact Mr. Jeff Kivi at (612) 330-5788 or Jeffrey.L.Kivi@xcelenergy.com if there are any questions or if additional information is needed.

Document Control Desk L-Pl-24-012 Page 2

Summary of Commitments

This letter makes no new commitments and no revisions to existing commitments.

I declare under penalty of perjury, that the foregoing is true and correct.

Executed on

Thomas A. Conboy Site Vice President, Prairie I d Nuclear Generating Plant Northern States Power Company - Minnesota

Enclosure

cc: Administrator, Region 111, USNRC Project Manager, Nuclear Material Safety and Safeguards, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota President of the Prairie Island Indian Community Tribal Council ENCLOSURE

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2

Evaluation of Proposed Change

License Amendment Request

Revise Independent Spent Fuel Storage Installation (ISFSI)

License Conditions 23(a), 24(A)(2), and 24(B)(2)

1.0

SUMMARY

DESCRIPTION

2.0 DETAILED DESCRIPTION

2.1 Facility Description 2.2 Current License Condition Requirements 2.3 Reason for Proposed Changes 2.4 Description of Proposed Changes

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria 4.2 Conclusions

6.0 REFERENCES

Page 1 of 7 L-PI-24-012 NSPM Enclosure

1.0

SUMMARY

DESCRIPTION

Pursuant to 10 CFR 72.56, Northern States Power Company, a Minnesota Corporation, doing business as Xcel Energy (hereafter NSPM), hereby requests a license amendment to Renewed Special Nuclear Materials (SNM) License No. SNM-2506 to change License Conditions 23(a), 24(A)(2), and 24(B)(2). The subject license conditions are aging management activities with specified inspection intervals of three months or one quarter.

NSPM proposes to revise the license conditions to describe the inspection intervals similar to Technical Specifications Surveillance Requirement Frequency, allowing up to 1.25 times the specified intervals to account for scheduling challenges, including but not limited to periods of extreme cold weather or other high-priority plant activities.

2.0 DETAILED DESCRIPTION

2.1 Facility Description

NSPM owns and operates the Prairie Island Nuclear Generating Plant (PINGP), which is a two unit plant located on the right (West) bank of the Mississippi River within the city limits of Red Wing, Minnesota. Unit 1 began commercial operation on December 16, 1973, and Unit 2 began commercial operation on December 21, 1974. The PINGP Units 1 and 2 Renewed Facility Operating Licenses expire August 9, 2033, and October 29, 2034, respectively.

Discharged spent fuel assemblies from PINGP, Units 1 and 2, were originally intended to be stored on-site in a spent fuel pool. However, based on the fuel cycle management strategy and the limited spent fuel pool capacity, storage capacity was projected to be exhausted by 1994.

Consequently, NSPM requested permission on August 31, 1990, to build and operate an on-site ISFSI in compliance with 10 CFR 72. (Reference 1) The NRC issued the original 20-year PI ISFSI site-specific license SNM-2506 on October 19, 1993 with an expiration of October 31, 2013. (Reference 2)

On October 20, 2011, NSPM submitted an application pursuant to 10 CFR 72.42 for renewal of the site-specific PI ISFSI license. (Reference 3) The NRC issued the renewed license on December 9, 2015. The renewed license authorizes operation of the PINGP ISFSI in accordance with the provisions of the renewed license and its technical specifications. The renewed license expires on October 31, 2053. (Reference 4)

Additionally, the Minnesota Public Utility Commission (MPUC) issued a Certificate of Need (CoN) on December 18, 2009, for the storage of up to 64 TN-40/TN-40HT casks to support continued operation of PINGP Units 1 and 2 through the end of the renewed operating licenses. (Reference 5)

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2.2 Current License Condition Requirements

Current ISFSI Renewed Operating License includes the following License Conditions:

23(a) The licensee shall perform visual inspections of accessible exterior surfaces of the dry storage (in-service) casks at intervals not to exceed every quarter.

24(A)(2) [With respect to aging management activities...of the dry storage (in-service) casks as described in the ISFSI Inspection and Monitoring Program...the following activities shall apply...as of the date of the issuance of the renewed license.]

Thereafter, NSPM shall continue to perform dose rate surveys for each loaded cask at an interval not to exceed three months, as is consistent with the aging management program ISFSI Inspection and Monitoring Program.

24(B)(2) [For each dry storage (in-service) cask added to the PI ISFSI site after the issuance of the renewed license, the following aging management activities...shall commence 20 years after the individual dry storage cask was initially placed into operation.]

Thereafter, NSPM shall continue to perform dose rate surveys for each loaded cask at an interval not to exceed three months, as is consistent with the aging management program ISFSI Inspection and Monitoring Program.

2.3 Reason for Proposed Changes

The inspection intervals are given not to exceed every quarter for license condition 23 and not to exceed three months for license condition 24. This is inconsistent with similar ISFSI Technical Specifications (TS) Surveillance Requirements (SRs) (for example, SR 3.1.4.1 and SR 3.1.4.2) give the frequency as 92 days and ISFSI TS SR 3.0.2 applies, which allows up to 1.25 times the interval specified in the frequency. An interval extension period will provide flexibility to schedule the inspections around typical challenges, including but not limited to inclement weather, security drills, and refueling outages). The proposed changes to the inspection intervals in the subject license conditions also make them more consistent with the ISFSI TS.

2.4 Description of Proposed Changes

NSPM proposes a revision to the inspection interval for each of the subject license conditions to allow an extension of up to 25 percent to the interval.

The specific wording changes to the subject license conditions are as follows (proposed addition underlined):

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License Condition 23(a)

(a) The licensee shall perform visual inspections of accessible exterior surfaces of the dry storage (in-service) casks at intervals not to exceed every quarter of 92 days.

This inspection interval is met if the inspection is completed within 115 days.

License Condition 24(A)(2)

(2) Thereafter, NSPM shall continue to perform dose rate surveys for each loaded cask at an interval not to exceed three months of 92 days, as is consistent with the aging management program ISFSI Inspection and Monitoring Program. This inspection interval is met if the inspection is completed within 115 days.

License Condition 24(B)(2)

(2) Thereafter, NSPM shall continue to perform dose rate surveys for each loaded cask at an interval not to exceed three months of 92 days, as is consistent with the aging management program ISFSI Inspection and Monitoring Program. This inspection interval is met if the inspection is completed within 115 days.

3.0 TECHNICAL EVALUATION

The proposed change to the subject license conditions are described as being part of the aging management activities for the in-service dry storage casks. As such, they are meant to monitor the casks over the period of extended operation (until end of license life in 2053). The aging effects of the monitored parameters progress slowly such that an additional 25 percent (or 23 days) will not impact the licensee's ability to address issues before they become a threat to the casks' specified safety functions. Similar monitoring items (for example, SR 3.1.4.1 and SR 3.1.4.2) are contained in ISFSI TS which include the 25% allowance in accordance with SR 3.0.2.

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria

The applicable regulatory requirements associated with the pr oposed change include the following:

10 CFR 72.44, License Conditions

10 CFR 72.44 defines the requirements for license conditions included with license issued under Part 72. Specifically, 10 CFR 72.44(a) states:

Page 4 of 7 L-PI-24-012 NSPM Enclosure

Each license issued under this part shall include license conditions. The license conditions may be derived from the analyses and evaluations included in the Safety Analysis Report and amendments thereto submitted pursuant to § 72.24. License conditions pertain to design, construction and operation. The Commission may also include additional license conditions as it finds appropriate.

This license amendment request proposes a change to license conditions under SNM-2506 pertaining to aging management inspections of the PI ISFSI. The technical evaluation in this enclosure concluded that the proposed change to the license condition is technically justified, acceptable and will not exceed regulatory limits. Therefore, with the changes proposed in this license amendment request, the requirements of 10 CFR 72.44 continue to be met.

10 CFR 72, Subpart F - General Design Criteria

10 CFR 72 Subpart F provides general design criteria for storage of high level nuclear wastes of which some apply to independent spent fuel storage facilities. The PI ISFSI provides for storage of dry spent fuel casks within a licensed storage facility. The proposed change does not alter the cask design or the manner in which spent fuel is stored within the casks. Table 4.1-1 below lists the sections of Part 72 and whether they are affected by the proposed change.

Affected by the Regulation Title proposed change 72.120 General Consideration No 72.122 Overall Requirements Yes 72.124 Criteria for nuclear criticality safety No 72.126 Criteria for radiological protection Yes 72.128 Criteria for spent fuel, high-level radioactive No waste, and other radioactive waste storage and handling 72.130 Criteria for decommissioning No

10 CFR 72.122, Overall Requirements

10 CFR 72.122 defines criteria applicable to dry spent fuel storage casks including quality standards, protection against environmental conditions and natural phenomena, fires and explosions, confinement barriers and systems, instrumentation and controls, and retrievability. Specifically, 10 CFR 72.122(b) states:

(b) Protection against environmental conditions and natural phenomena. (1)

Structures, systems, and components important to safety must be designed to accommodate the effects of, and to be compatible with, site characteristics and environmental conditions associated with normal operation, maintenance, and testing of the ISFSI or MRS and to withstand postulated accidents.

Page 5 of 7 L-PI-24-012 NSPM Enclosure

The PI ISFSI will continue to meet the requirements of 10 CFR 72.122 allowing up to 1.25 times the specified interval for license condition 23(a), for visual examination of in-service casks. The inspections will continue to ensure that aging management requirements will continue to ensure compliance with 10 CFR 72.122(b).

10 CFR 72.126, Criteria for Radiological Protection

10 CFR 72.126 defines criteria applicable to dry spent fuel storage casks including exposure control and shielding personnel from radiation. Specifically, 10 CFR 72.122(a)(6) states:

Exposure control. Radiation protection systems must be provided for all areas and operations where onsite personnel may be exposed to radiation or airborne radioactive materials. Structures, systems, and components for which operation, maintenance, and required inspections may involve occupational exposure must be designed, fabricated, located, shielded, controlled, and tested so as to control external and internal radiation exposures to personnel. The design must include means to:

(6) Shield personnel from radiation exposure.

The PI ISFSI will continue to meet the requirements of 10 CFR 72.122 allowing up to 1.25 times the specified interval for license conditions 24(A)(2), and 24(B)(2), for surveying and trending cask dose rates. The dose rate surveying and trending, along with other plant radiation protection programs, will continue to ensure compliance with 10 CFR 72.126(a)(6).

Therefore, with the changes proposed in this license amendment request, the requirements of 10 CFR Part 72, Subsection F continue to be met.

4.2 Conclusions

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

NSPM has determined that the proposed change would involve an amendment to a materials license identified in 10 CFR 51.60(b)(1) which is administrative, organizational, or procedural in

Page 6 of 7 L-PI-24-012 NSPM Enclosure

nature, or which results in a change in process operations or equipment. However, the proposed amendment does not involve (i) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, (ii) significant increase in individual or cumulative occupational radiation exposure, (iii) significant construction impact, or (iv) significant increase in the potential for or consequences from radiological accidents.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(11). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

In addition, NSPM has determined that the proposed amendment would not involve (i) a significant expansion of a site, (ii) a significant change in the types of effluents, (iii) a significant increase in the amounts of effluents, (iv) a significant increase in individual or cumulative occupational radiation exposure, (v) a significant increase in the potential for or consequences from radiological accidents, or (vi) a significant increase in spent fuel storage capacity.

Therefore, pursuant to 10 CFR 51.60(b)(2), no environmental report need be prepared in conjunction with the proposed amendment. The proposed change does not require any changes to the PI ISFSI Environmental Report.

6.0 REFERENCES

1. NSPM Letter to NRC re: Application for a License to Construct and Operate a Dry Cask Independent Spent Fuel Storage Installation, dated August 31, 1990.

2. License for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste No. SNM-2506, issued to NSPM October 19, 1993.

3. NSPM Letter L-PI-11-074, re: Prairie Island Independent Spent Fuel Storage Installation (ISFSI) License Renewal Application, dated October 20, 2011. (NRC ADAMS Accession No. ML11304A068)

4. NRC letter to NSPM re: Issuance of Renewed Materials License No. SNM-2506 for the Prairie Island Site Specific Independent Spent Fuel Storage Installation (TAC No. L24592), dated December 9, 2015.

5. Minnesota Public Utilities Commission (MPUC) Order Accepting Environmental Impact Statement and Granting Certificate of Need and Site Permit Condition, issued December 18, 2009. (MPUC eDockets Document ID 200912-45206-02)

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