ML20199B247
| ML20199B247 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/20/1998 |
| From: | Meisner M Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| MJM-98-01, MJM-98-1, MN-98-01, MN-98-1, NUDOCS 9801280213 | |
| Download: ML20199B247 (7) | |
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MaineYankee I-P.O. BOX 408 e WISCASSET, MAINE 04578 + (207) 882-6321 January 20,1998 MN-98-01 MJM 98-01 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, D.C. 20555
References:
(a) ~
License No. DPR-36 (Docket No. 50-309)
(b)
Letter: M.B. Sellman to USNRC; Certifications of Permanent Cessation of Power Operation and Permanent Removal of Fuel From The Reactor; MN 89, dated August 7,1997.
(c)
USNRC Staff Requirements Memo, S. J. Chilk to W.C.Parler/J. M. Taylor; SECY-93-127-Financial Protection Required of Licensees of Large Nuclear Power Plants During Decommissioning; dated July 13,1993.
(d)
Memorandum: J.M. Taylor to the Commissioners, USNRC; Changes to ae Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors,10CFR50.54(w) and 10CFR140.11; SECY 96-256, dated December 17,1996 (e)
Proposed Rule: 10 CFR Parts 50 and 140; Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors [FR 58690]; October 30, 1997
Subject:
Request for Exemption From the Financial Protection Requirement Limits of 10CFR50.54(w) and 10CFR140.11.
Gentlemen:
On December 6,1996, Maine Yankee shut down the reactor and has not restarted the reactor or.
returned to power operations.-
In Reference (b) MaineIYankee informed the USNRC that the Board of Directors of Maine Yankee had decided to pennanently cease operations at the Maine Yankee Plant and that fuel had been I
permanently removed from the reactor. In accordance with 10CFR50.82(a)(2) the certifications in l
' the letter modified the Maine Yankee license to permanently withdraw Maine Yankee's authority to operate the reactor. As a result the potential risk to the public health and safety is substantially
[h reduced.
Maine Yankee has prepared requests for exemptions from certain insurance coverage and financial protection requirement limits of 10CFR50.54(w) and 10CFR140.11. These exemptions are requested in accordance with 10CFR50.12, and 10CFR140.8, " Specific Exemptions" and are enclosed as
. Attachment I to this letter.
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UNITED STATES NUCLEAR REGULATORY COMMISSION MN-98 LAttention: Document Control Desk Page Two We conducted an analysis of the potential for a beyond design basis zircalloy fire following the-complete loss of the fuel pool inventory. As discussed in the attachments, Maine Yankee fuel is already beyond the decay time necessary to preclude such an event. Therefore, we request your
. speedy approval of our proposed exemption. Considering the routine nature of these exemption requests, and the significant expense of maintaining an unnecessary level ofinsurance coverage, we -
- would appreciate your approval by February 23,1998.-
Please do not hesitate to call should you require additional information.
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ael J. Meisner, Vice-President Nu r Safety and Regulatory Affairs
- Attachment c:
Mr. H.J. Miller Mr. R.A. Rasmussen
- Mr. Michael Webb Mr. Patrick J. Dostie i
Mr, Uldis Vanags Mr. Michael T. Masnik
ATTACHMENTI REOUEST FOR EXEMPTION FROM CERTAIN REOUIREMENTS OF TITI E 10 OF CODE OF FEDERAL REGULATIONS PART 50.54(w) AND PART 140.11
- 1. REQUEST FOR EXEMPTION Maine Yankee Atomic Power Company (MYAPC) hereby requests an exemption from 10CFR50.54(w) which requires licensees to maintain 51.06 billion in onsite coverage. MYAPC requests that the coverage requirement be reduced to $50 million in onsite coverage.
MYAPC also requests an exemption from the requirements of 10CFR140.11 which requires licensees to maintain $200 million in offsite fmancial protection as primary liability coverage and to be allowed to withdraw from the secondary liability coverage under Price-Anderson. MYAPC requests that the primary liability coverage be reduced to $100 million.
II. BACKGROUND On December 6,1996, Maine Yankee shut down the reactor and placed the plant in a Hot Shutdown l
Condition (Condition 5 ) defined in the Technical Specifications as suberitical by at least 5% delta k/k and Tave greater than 500 degrees F. Subsequently Maine Yankee brought the plant to a cold shutdown condition and, without ever returning to criticality, by June 20,1997, had removed the fuel from the reactor and placed the fuel in the spent fuel pool. On August 7,1997, Maine Yankee i
submitted " Certifications of Permanent Cessation of Power Operation and Permanent Removal of Fuel from the Reactor" pursuant to 10CFR50.82(a)(1)(i) and (ii).
The infomiation in NUREG-1353," Regulatory Analysis for the Resolution of Generic Issue 82, Beyond Design Basis Accidents in Spent Fuel Pools, " indicated that a potential hazard, the potential zircaloy cladding fire sequence, would remain for some time after a reactor has been shutdown.
An analysis by Brookhaven Na'ional Laboratory (BNL), as discussed in Reference (d), estimates that,in order to prevent fuel cladding failure leading to a zircaloy cladding fire given the loss of all spent fuel pool water, the rod cladding temperature must not exceed 565 degrees C. This cladding temperature would be reached by a shutdown reactor after a variable decay period depending upon plant-specific design and operational history.
Maine Yankee contracted Scientech Inc. to perform a Maine Yankee specific spent fuel decay heat analysis which models the fuel, power history and spent fuel rack configuration. This analysis demonstrates that the fuel cladding will not be able to reach 565 degrees C. thirteen months after shutdown assuming a complete loss of cooling water inventory. This result is consistent with the BNL analysis given the Maine Yankee storage configuration, power history, and platit specific test results. ( The summary of the analysis is considered proprietary by the vendor and will be held by Maine Yankee onsite for inspection by the Nuclear Regulatory Commission staff should they wish to examine the report. Attachment 11 is a summary of the analytical approach).
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After January 16,1998 the requisite cooling period aller shutdown for the spent fuel would have clapsed a'nd the potential zircaloy fire sequence would no longer be a concern since air would cool the spent fuel sufficiently to avoid combustion. At this time Maine Yankee would be in " Reactor l
Configuration 2" as defined in References (d) and (c) of the cover letter and would meet the
" requisite minimum spent fuel cooling period" of Reference (c).
Maine Yankee has also updated the FSAR analysis of a spent fuel bundle drop and a release from an accident associated with stored radioactive waste. These FSAR analyses, which become the bounding design basis accidents reflect the shutdown configuration of the plant. As discussed in Reference (d), these scenarios result in a negligible site boundary dose and the risk to the public health and safety is minimal. Consequently there is ample justification for the reduction of the financial protection requirements applicable to Maine Yankee.
111. JUSTIFICATION FOR GRANTING THE EXEMPTION REQUESTS 10CFR50.54(w)
The specific requirements for granting exemptions from Part 50 regulations are set forth in 10CFR50.12. The commission is authorized to grant an exemption upon a demonstration that the exemption:(A) is authorized by law; (B) will not present an undue risk to the public health and safety; and (C)is consistent with the common defense and security. Special circumstances must exist for the NRC to consider an exemption request. Special circumstances include: (1) particular circumstances where the application of the regulation would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule and (2) undue hardship of costs that are significantly in excess of those incurred by others similarly situated.
1 A. The requested exemption is authorized by law and has been routinely granted by the Commission. Those plants granted insurance exemptions include Humboldt Bay, Yankee Rowe, Lacrosse, Trojan, among others. In addition the requested exemptions are consistent with Reference (c), the NRC proposed rule.
B. The requested exemption produces no undue risk to the public health and safety. Generic analyses produced for the NRC staff by BNL and site specific analyses produced by Maine Yankee confirm that the risks associated with Maine Yankee in the shutdown and defueled condition and the resulting damage to property are greatly reduced from those of power operations. The reduction in the amount of onsite property insurance coverage is administrative in nature and does not impact either thm risk of an accident or release or affect the safety of the public. The reduction in coverage is shown to be commensurate with the reduction in the risk and consequences of an accident.
C. The requested exemption is consistent with the common defense and security. The exemption would reduce the required onsite property damage coverage. There would be no physical change to the plant or the fuel as a result of this exemption and no impact on the common defense or security of the public or the Maine Yankee facility.
- 1. The continued application of the requirements of 10CFR50.54(w) is not necessary to achieve the underlying purpose of the rule which is to provide assurance that the licensee will have the financial capability to restore the facility to a safe configuration after a design basis accident. The $1.06 billion coverage specified in the rule was clearly applicable to the potential for damage at an operating plant, in the present shutdown and defueled condition, $50 million in property coverage is more than sufficient to provide that assurance. The NRC analysis discussed in Reference (d) estimates the onsite costs associated with a fuel bundle drop to be 59 to $24 million dollars and the cleanup costs associated with the rupture of a large tank of slightly contaminated water to be about
$50 million. The requested exemption is consistant with these estimates and is suflicient to meet the
- underlying purpose cf the rule.
- 2. The requirement to maintain $1.06 billion in property coverage represents a financial burden to the licensee which has no benefit to the licensee, the public, or the Federal Govemment. As such the financial burden of the specified insurance level represents a hardship not appropriate for a shutdown and defueled facility.
10CFR140.11 10CFR140.8 states that the Commission may grant exemptions from the requirements of the regulations of this part as it determines are authorized by law and are otherwise in the public interest.
l The requested exemptions to the primary and secondary financial protection layer have been granted
- to other licensees i.e. Yankee Rowe, Rancho Seco, Trojan. This action is authorized by law. The Commission has determined that the withdrawal of Licensees from the secondary financial protection layer and the reduction in the primary level coverage requiren ents to $100 million of Part 140.ll(a)(4) is in the public interest. This exemption request, consistent with " option 2" of Reference (e), protects the public by providing a level ofinsurance commensurate with the risk and potential judgements or settlements from litigation and shields the Federal Government from indemnity claims.
IV. CONCLUSION Maine Yankee has concluded that the requested exemption from 10CFR50.54(w) to reduce the onsite financial coverage from $1.06 billion to S50 million and the requested exemption from 10CFR140.11 to reduce the primary layer financial coverage from $200 million to $100 million and to allow withdrawal from the secondary layer financial coverage and its retrospective premium liability of 575.5 million 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. The exemptions will reduce a financial burden not appropriate to a defueled shutdown facility and will eliminate requirements that do not serve the underlying purpose of the rules. The remaining coverage requested by Maine Yankee will provide an appropriate level of offsite financial protection still required to account for judgements or settlements from litigation and also to protect the Federal government from indemnity claims.
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In addition the requested exemptions are consistent with the proposed rules promulgated in Referenc'e (d) add (c) of the cover letter and the decision of the Commissioners in Reference (c) of the cover letter.
V. ENVIRONMENTAL IMPACT Pursuant to the provisions of 10CFR50.12 and 140.8, Maine Yankee is requesting exemptions to the requirements of 10CFR50.54(w) and 140.11(a)(4) regarding the required financial protection requirements for _onsite property damages and offsite liability. The proposed exemptions are administrative and financial in nature and have no effect on the conduct of activities at Maine Yankee. The exemptions will result in no change in the type or quantity of radioactive or non-radioactive effluents, no increase in licensed power level, and no change to the plant configuration.
Therefore, the proposed exemptions will not have a significant impact on the environment.
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ATTACHMENT 11 DESCRIPTION OF ANALYTICAL METHODS An analysis of spent fuel cooling was performed by Scientech, Inc. using the Transient Reactor Analysis Code W (TRAC -PFl.) The key applicable models in TRAC include two-phase flow and heat transfer, noncquilibrium thermodynamics, two-dimensional structural heat transfer, noncondensible gas fields, and cladding oxidation. The TRAC model for natural air circulation through the spent fuel storage cells relies entirely on air to remove the decay heat load.
A single fuel assembly located in Region 2 of the spent fuel pool was chosen. That assembly is contained in one cell of a high density rack, and it had the highest bu; nup,41,372 MWD /MTU, and initial uranium loading,0.373862 MTU, and the fewest number of decay days,355 days as of i
December 1,1997. The cell in which this fuel resides was modeled with an adiabatic boundary on the periphery of the storage cell. It bounds the other assemblies in the pool.
A postulated event was modeled that caused the instantaneous loss of all water in the pool. Decay heat was calculated for the limiting assembly using the NRC Branch Technical Position on long term decay heat level in spent fuel pools m as modified by a recent refueling decay heat analysis donc using actual plant datam Based on a correction factor developed in this analysis and test, a realistic decay heat for the limiting assembly was used in the oxidation analysis. It was shown that aller
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January 16,1998 natural circulation of air was sufficient to keep the cladding temperature below the zirconium oxidation temperature criterion (565*C) proposed in SECY-97-186,W (1) Schnurr, N.M., et Al. TRAC-PF1IMOD2: An Advanced Best-Estinwte Computer Programfor.
Pressurized Water Reactor ThermalHydraulic Analysis, Los Alamos National Laboratory Report LA-12031-M, Vols. I-IV, NUREG/CR-5673,1990.
(2) NRC Branch TechnicalPosition on Residual Decay Energyfor Light-Water Reactorsfor Long Term Cooling, NRC ASB 9-2, Rev. 2,1981 p 9.2.5-8 through 9.2.5-14 (located in USNRC Standard Review Plan, Section 9.1.3 " Spent Fuel Pool Cooling and Cleanup System" NUREG-0800)
(3) Letter: A Randolph Blough, USNRC Division of Nuclear Material Safety, to M. B. Sellman MYAPCt NRCIntegrated Inspection Report 50-309/97-08, Section E2.1, December 29,1997.
(4) Memorandum: L. Joseph Callan to the Commissioners, Changes to the Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactcrs, 10CFR50.54(u) and 10CFR140.ll, SECY-97-186, August 13,1997.
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