ML15351A490

Request for Exemption from 10 CFR 50.54(w)(1) Regarding Onsite Insurance Coverage

ML15351A490
Person / Time
Site:	Crystal River
Issue date:	12/17/2015
From:	Reising R Duke Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F1215-01, TAC MF2981
Download: ML15351A490 (20)

Text

ENERGY. Crystal R i ver Nudear Plant 15760 W. Power Li ne St ree t Crysta l R i ver. FL 34428 Docket 50-302 Ope r ating License No. DPR-72 10CFR50.1 2 10 CFR 50.54(w)(1) December 1 7. 20 1 5 3F1215-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 -Request for Exemption From 10 CFR 50.54(w)(1) Regarding Onsite Insurance Coverage

References:

1. CR-3 to NRC letter, "Crystal River Unit 3 -Certification of Permanent Cessation of Power Operations and that Fuel Has Been Perma n ent l y Removed from the Reactor," dated February 20, 2013. (ADAMS Accession No. ML13056A005)

Dear Sir:

2. NRC to CR-3 letter, "Crystal River Unit 3 Nuclear Generati n g P lant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel from the Reactor," dated March 13, 2013. (ADAMS Accession N o. ML13058A380)

3. NRC to CR-3 letter dated March 31, 2015, "Crystal River Unit 3 -Issuance of Amendment Regarding Changes to the Emergency Plan and Emergency Action Levels (TAC No. MF3415)" (ADAMS Accession No. ML15027A209) 4. NRC to CR-3 letter dated March 30, 2015, "Crystal River Unit 3 -Exemptions From Certain Emergency Planning Requirements and Related Safety Evaluation (TAC No. MF2981 )" (ADAMS Accession No. ML15058A906)

In accordance with 10 CFR 50.12 , "Spec i fic E xe m ptions," Duke Energy Florida, LLC, formerly known as Duke Energy Florida Inc. (DEF) hereby requests a permanent exemption from 10 CFR 50.54(w)(1) for Crystal River Unit 3 (CR-3). 10 C F R 50.54(w)(1) requires individual power reactor licensees to obtain insurance coverage from private sources to provide protection covering the licensee's obligation, in the u nlikely event of an accident, to stabilize and decontaminate the reactor and the reactor site. Spec i fically, licensees must obtain insurance having a m i nimum coverage limit for each reactor sta ti on site of either $1.06 billion or whatever amount of insurance is generally ava il ab l e fr o m private sources, whichever is less. This insurance coverage i s referred to as "onsite cove r age" o r "onsite insurance coverage." DEF is requesting an exemption to 10 CFR 50.54(w)(1) to reduce the CR-3 minimum onsite insurance coverage to $50 million. The underlying purpose of 10 CFR 50.54(w)(1) is to require sufficient property damage insurance to ensure adequate funding of onsite post-acc i dent recovery , stabilization and decontamination costs following an accident at an operating n uclear power plant. However, the regulation does not take into consideration the reduced pote nt ial for , and consequences of, such nuc l ear incidents at permanently shutdown facilities.

Th e CR-3 facility is a single reactor s i te and the reactor is permanently shut down and de f ue l ed (References 1 and 2). The U.S. Nuclear Regulatory Comm i ssion 3F1215-0 1 Page 2 of 3 proposed exemption would allow a reduction in the level of onsite insurance coverage to a l evel that is commensurate with the permanently defueled status of the CR-3 facility and the underly i ng purpose of the rule. The exempt i on request is provided in the attachment to this letter. DEF requests approval of this proposed exemption by March 31, 2017. The CR-3 reactor was last critical on September 26, 2009. All significant radioactive sources are in the spent fuel pools, and decay heat and source term continue to significantly diminish.

CR-3 determined that the only remaining postulated accident in the permanently defueled condition is the fuel handling accident (FHA). The Radioactive Waste Decay Tank Rupture Accident previously described in the Final Safety Analysis Report is no longer credible as all waste gas has been released and the tank relief valves have been removed. Accident source terms no longer contain particulates (alkali metals), halogens (iodines), or noble gases that contribute to dose consequences.

DEF evaluated the consequences of an FHA. The ca l culation assumed that when the fuel assemblies are damaged underwater, alkali metals (e.g., cesium) remain trapped in the pools, and halogens (iodine's) are decayed. As a result of decay time and diminishing decay heat during the past 6 years, a release from an FHA would only consist of the noble gas Kr-85. The FHA analysis shows that the dose consequences at the site boundary are well below the 10 CFR 50.67 dose limits without relying upon any systems, structures, or components (SSCs) to remain functional during and following the event. Additionally, DEF evaluated the effects of a beyond design basis accident where the spent fuel assemblies in the spent fuel pool (SFP) are uncovered following a drain down event. The beyond design basis accident SFP drain down event is calculated for the hypothetical situation where the pool is completely dry, with and without ventilation running. The calculation demonstrates that for spent fuel in the pool with decay times much l onger than one year, which is the case for the current condition of CR-3, a zirconium fire cannot occur. A fire would be necessary to create a significant airborne release. Due to the significant decay time, an airborne release from the spent fuel assemblies in the SFP's is not expected in the event of a loss of water inventory.

The NRC concurred with these conclusions in References 3 and 4 where CR-3 received exemptions for emergency planning in accordance with the planning standards of 1 O CFR 50.47, and emergency planning requirements of 1 O CFR 50, Appendix E. There are no new regulatory commitments made within this submittal.

If you have any questions regarding th i s submittal, please contact Mr. Phil Rose, Lead Eng i neer, Nuclea r Regulatory Affairs, at (352) 563-4883. I dec l are under penalty of perj u ry that the foregoing is true and correct. Executed on December 17, 2015. Rona l d R. Re i s in g , Se ni or Vice Pr es i dent Ope r ations Support RRR/par U. S. Nuclear Regulatory Commission 3F1215-01 Attachments:

A. Request for Exemption from 10 CFR 50.54(w)(1) Page 3 of 3 B. No Significant Hazards Consideration, Environmental Assessment and Conclusions cc: NRR Project Manager Regional Administrator, Region I