RA-02-163, Request for Exemption from Certain Requirements of NRC Regulations 10 CFR 72.212(a), 72.212(b)(2)(i), 72.212(b)(7), and 72.214

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Request for Exemption from Certain Requirements of NRC Regulations 10 CFR 72.212(a), 72.212(b)(2)(i), 72.212(b)(7), and 72.214
ML023610343
Person / Time
Site: Maine Yankee, 07201015
Issue date: 12/19/2002
From: Williamson T
Maine Yankee Atomic Power Co
To:
Document Control Desk, NRC/FSME
References
+sispjld120050505, -RFPFR, MN-02-064, RA-02-163
Download: ML023610343 (3)


Text

MaineYankee 321 OLD FERRY RD

  • WISCASSET. ME 04578-4922 December 19, 2002 MN-02-064 RA-02-163 U. S. NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, D.C. 20555

References:

(a) License No. DPR-36 (Docket No. 72-30).

(b) NAC Certificate of Compliance for Spent Fuel Storage Casks Issued to NAC International Inc. Certificate No. 1015, Amendment 2, dated 12/31/2001.

(c) Certificate of Compliance, Appendix A, Technical Specifications for the NAC-UMS System (d) NAC International Inc., Final Safety Analysis Report (FSAR) for the UMS Universal Storage System Docket No. 72-1015 (e) Letter: T. Williamson, MYAPC to USNRC; "Request for Exemption from Certain Requirements of NRC Regulations 10 CFR72.212(a),

72.212(b)(2)(i), 72.212(b)(7), and 72.214"; MN-02-055; November 7, 2002.

Subject:

Request for Exemption from Certain Requirements of NRC Regulations 10 CFR72.212(a), 72.212(b)(2)(i), 72.212(b)(7), and 72.214 Ladies and Gentlemen:

This letter supplements information submitted in reference (e) which requests USNRC approval of an exemption to certain requirements in 10 CFR72.212(a), 72.212(b)(2)(i), 72.2 f2(b)(7) and 72.214.

Maine Yankee was requested by the staff in a conference call on December 10, 2002 to provide additional information regarding occupational exposure estimates for the vacuum drying evolutions and the relationship to the overall station decommissioning exposure estimates. Maine Yankee also indicated that the information regarding Occupational Exposure presented in reference (e) only included gamma exposure and did not include the contribution from neutron exposure. The following table contains the amended exposure totals including neutron contribution.

U. S. NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Page 2 Canister Sequence Approximate Processing Hours Occupational Heat Load (kW) Exposure-neutron and gamma

1. 4.36 250 272mrem
2. 4.41 175 223mrem
3. 4.41 150 241mrem

_____4. 4.31 160 - 254mrem

5. 9.15 220 422mrem
6. 9.13 210 358mrem
7. 9.37 330 365mrem
8. 9.37 312 512mrem
9. 9.31 396 529mrem Our experience to date indicates the repeated entry into the limiting condition of the technical specification requirement for air cooling adds a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> to the overall evolution for each canister. Maine Yankee believes the granting of the exemption requested and the resulting increased drying times will result in the reduction of the occupational exposure for the processing of the remaining dry storage canisters of approximately 5 person-rem. This reduction is a significant percentage of the overall station dose for the entire decommissioning project. For the entire year 2002, the total station dose for all activities will be approximately 65 person-rem. The expected savings of 5 person-rem represents nearly 8% of the 2002 station dose and will likely represent an even greater percentage of the 2003 station dose. We expect the fuel loading campaign to be completed in 2003 with the loading of 50 remaining canisters. Maine Yankee views an 8-10% reduction in overall dose to be a substantial benefit to health and safety the personnel involved with these evolutions.

Maine Yankee has also confirmed that the additional exposure incurred by security force personnel is not tabulated on our canister exposure data base but would add to the totals presented above (except for overall annual station dose data). Security personnel are required to be present whenever spent fuel is being loaded into dry casks storage and until the fuel is transferred to the ISFSI.

U. S. NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Page 3 Please contact me at (207-882-4530) should you have any questions or desire additional information.

Very truly yours, omas L. Williamson, Director Nuclear Safety and Regulatory Affairs c: Mr. H. J. Miller, USNRC, Region 1 Mr. M. K. Webb, USNRC Mr. S. C. O'Connor, USNRC Ms. P. Craighead, Esq., State of Maine Mr. P. J. Dostie, State of Maine Mr. T. Thompson, NAC International, Inc.