ML20115H402

Requests Exemption from 10CFR70.24(a) Requirement, Criticality Accident Requirements for Areas Containing Incore Detectors & Unirradiated Fuel Stored in NRC Approved Packaging

ML20115H402
Person / Time
Site:	Grand Gulf
Issue date:	07/15/1996
From:	Meisner M ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
GNRO-96-00082, GNRO-96-82, NUDOCS 9607230103
Download: ML20115H402 (7)

Text

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e Entsrgy Opercti:ns,Inc.

. ~;-" ENTERGY "o c- 7se Pvt Gte MS 39150 Td 601437 6470 M. J. Meisner ,

umcu Ny kw % fy & Rgutivy Ar? arc July 15, 1996 i

U.S. Nuclear Regulatory Commission Director, Office of Nuclear Material Safety and Safeguards Washington, D.C. 20555

Subject:

Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 10CFR70.24 Exemption

Reference:

1) AECM-81/158 dated April 27,1981 Application for SNM License from Mississippi Power & Light to the NRC.

2) NRC letter dated July 15,1981, NRC Materials License No. SNM-1882 GNRO-96/00082 Gentlemen:

By this letter, Entergy Operations, Inc. requests an exemption from the requirements of l 10CFR 70.24(a), " Criticality Accident Requirements" for Grand Gulf Nuclear Station (GGNS). The basis for this request is similar to the previously provided basis for the exemption to 10CFR 70.24 (granted in the July 15,1981 Special Nuclear Material (SNM)

License No.1882 for this facility). This letter requests a regranting of part of the '!

previously approved exemption to the requirements of 10CFR 70.24. It is our i understanding that the NRC Staff has taken the position that unless an exemption granted l under a 10CFR 70 license is explicitly incorporated into the subsequently granted 10CFR 50 Operating License, that the exemption expires with the issuance of the 10CFR 50 licenses. As a result, although there is precedent to the contrary', the previous 10CFR 70.24 exemption is considered to have expired with the SNM License (No.1882) when the d Operating Ucense (OL) was issued since the exemption was not specifically reissued at y the time of OL issuance. Therefore, an exemption is requested to the criticality accident I monitoring requirements of 10CFR 70.24(a) specifically for the areas containing

' On May 11,1988 the NRC Staff and OGC issued a letter to the Tennessee Valley Authority (TVA) (see letter from R.A. Hermann (NRC) to S.A. White (TVA) " Criticality Monitoring")

wherein the Staff considered the previously issued 10CFR Part 70 exemptions for Browns /

Feny to remain in effect although the exemption wording was not transferred from the SNM License to the Operating License.

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9607230103 960715 PDR ADOCK 05000416 p PDR

July 15, 1996 GNRO-96/00082 Page 2 of 4 incore detectors (which are not in use) and unirradiated fuel stored in NRC approved packaging, with the restriction noted in the exemption request and justification section.

We have satisfied the good cause requirements outlined in 10CFR 70.24(d) and the basis is provided in the attached exemption request and justification. We feel the requested exemption is authorized by law, will not endanger life or property or the common defense and security, and are otherwise in the public interest.

Yo s truly, f

J JL -

ment: 10CFR 70.24 Exemption Request and Justification

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i July 15, 1996 '

GNRO-96/00082 Page 3 of 4 i i-cc: Mr. J. E. Tedrow (w/a)

Mr. R. B. McGehee (w/a) t Mr. N. S. Reynolds (w/a) - l i

Mr. H. L Thomas (w/o)

Mr. J. W. Yelverton (w/a) j Mr. L J. Callan (w/a)  ;

Regional Administrator U.S. Nuclear Regulatory Commission .

Region IV i 611 Ryan Plaza Drive, Suite 400 t Arlington,TX 76011 i i

Mr. J. N. Donohew, Project Manager (w/2)

Office of Nuclear Reactor Re0ulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 Dr. E. F. Thompson (w/a) l State Health Officer '

State Board of Health l P. O. Box 1700 Jackson, Mississippi 39205 w -- g. ,

ATTACHMENT 1 10CFR70.24 EXEMPTION REQUEST and JUSTIFICATION

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r Attachm:nt 1 to GNRO-96/00082 j.'- Page 1 of 3 -

l 10CFR70.24 EXEMPTION REQUEST and JUSTlFICATION

! EXEMPTIONS REQUESTED:

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Exemption is requested from the criticality accident monitoring requirements of 10CFR 70.24(a) for i Special Nuclear Material (SNM) areas for SNM in the form of not in use in-core nuclear

instrumentation [for example

source range monitors (SRMs), intermediate range monitors (IRMs),

local power range monitors (LPRMs), and traversing incore probe (TIPS)].

i l Exemption is also requested for storage areas of unirradiated fuel that is packaged in accordance l with 10CFR 71. The fuel bundles, packaged in NRC approved packaging, may be stored in l unmonitored areas as long as the following restriction is met; the fuel assemblies will only be i rzmoved from the NRC approved packaging in areas where criticality monitors are in use.

This exemption is necessary to clarify the requirements of the Operating License for GGNS, which in g neral invokes 10CFR 70 as a whole. The two exemptions specified above will in no way affect the j hralth and safety of the public.

! GOOD CAUSE JUSTIFICATION:

l l j  ; Szction 70.24(d) anticipates that licensees may request relief from these requirements and allows l 1 licensees to apply for an exemption from Section 70.24, in whole or in part, if good cause is shown. l

Grand Gulf believes that good cause exists for following reasons: i l

1 incore Detectors i

The major form of SNM used at Grand Gulf is present principally in the form of nuclear fuel.

l However, other quantities of SNM are used, or may be used (and stored), at the facility in the form of

fissile material incorporated into incore nuclear instrumentation [for example

source range monitors j (SRMs), intermediate range monitors (IRMs), local power range monitors (LPRMs), and traversing

incore probe (TIPS)). The amount of SNM contained in the nuclear instrumentation is small and ,

4 significantly less than the quantities specified in Section 70.24(a). The small quantity of SNM i

- prasent in the nuclear instrumentation and the form in which the SNM is maintained (a very thin i coating applied on the inside of the sealed fission chamber contained at the end of each monitor) 4 precludes inadvertent criticality.

i The total amount of SNM contained in the incore detectors is such that it also meets the " forms not i sufficient to form a critical mass" guidance in Section 1.1 of Regulatory Guide 10.3, " Guide for the I Preparation of Applications for Special Nuclear Material Licenses of Less than Critical Mass l Quantities." The quantities of SNM specified to be enough for a critical mass in Reg. Guide 10.3 are l 350 grams of U-235,200 grams U-233, and 200 grams of Pu-239.

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Attachm:nt 1 to GNRO-96/00082 Page 2 of 3 ,

The quantities of SNM in the form of incore detectors at Grand Gulf as of July 8,1996 are as follows.

Note: this listing is 16r Inkwmation Only and not intended as a limiting listing.

Not used and Stored

• no. U235/ detector (grams) total U235 (grams) detectors SRMs 9 0.0027 0.02430 IRMs 5 0.00075 0.00375 TIPS 1 0.0015 0.00150 i LPRMs 104 0.00022 0.02288 Total 0.05243

'Other irradiated detectors stored in the spent fuel pool are not included in this table since dose rates on irradiated detectors preclude personnel access.

These quantities are well below the amounts for which criticality monitoring would be required as cutlined in 10CFR 70.24(a). If this was the only type of SNM stored on onsite, criticality monitoring would not be required. Since the form of SNM on the incore detectors is such that an inadvertent  !

criticality cannot occur, we feel we have demonstrated the good cause requirements for an  !

cxemption to 10CFR 70.24(d).

Unirradiated Nuclear Fuel Unirradiated nuclear fuel packaged in a NRC approved packaging is precluded from criticality events due to the construction of the package and the storage configuration of the fuelin the package.

Package design ensures that a geometrical criticality safe configuration is maintained during 1

transport, handling, storage, and accident conditions. Package design also precludes introduction of I Kny moderating agents due to leak tight construction. NRC approval (given by issuance of NRC Certificate of Compliance for Radioactive Materials Packages) of the package design is certification

by the NRC that any incident which could occur during transport could not cause a criticality i accident. We only receive fuel that is packaged in NRC approved packaging. Since we will only i remover the fuel from these criticality accident safe NRC approved packages in areas for which -

j- criticality accident monitoring is provided, we feel we have shown good cause for an exemption to the criticality monitoring requirements of 10CFR 70.24(a).

a COST:

1 l Compliance with 10CFR 70.24 would result in a considerable expenditure of resources to install, j maintain, and operate a criticality accident monitoring system for storage of the items listed in the exemption. We believe these resources could be put to better use in other areas to improve the operation of Grand Gulf Nuclear Station.

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Attrchm:nt 1 to GNRO-96/00082 )

Page 3 of 3 l

l RISK TO PUBLIC HEALTH AND SAFETY: 1 Due to the form of SNM contained in the incore detectors and as long as unirradiated fuel is stored in its NRC approved shipping package, criticality will not occur. Since criticality accidents cannot '

occur with the SNM in question, public health and safety considerations are preserved.

l l

CONCLUSION:

B: sed on the above request and justification evaluation, Entergy Operations, Inc. has concluded that operation in accordance with the proposed exemption to 10CFR 70.24(a) is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security i

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