ML062010042
| ML062010042 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 07/19/2006 |
| From: | Joseph Sebrosky NRC/NMSS/SFPO |
| To: | Ruland W H NRC/NMSS/SFPO |
| Sebrosky J M, NRC/NMSS 301-415-1132 | |
| References | |
| Download: ML062010042 (5) | |
Text
July 19, 2006NOTE TO:William H. Ruland, Deputy DirectorSpent Fuel Project Office Office of Nuclear Material Safety and SafeguardsTHROUGH:Christopher M. Regan, Acting Chief /RA/Licensing SectionSpent Fuel Project Office Office of Nuclear Material Safety and SafeguardsFROM:Joseph M. Sebrosky, Senior Project Manager /RA/ by Stewart Brown for
/Spent Fuel Project OfficeOffice of Nuclear Material Safety and Safeguards
SUBJECT:
CONCERNS REGARDING EXEMPTION FROM 10 CFR 72.48, 10 CFR 72.212AND 72.214 FOR DRY SPENT FUEL STORAGE ACTIVITIES - FORT CALHOUN STATIONThe purpose of this note is to respond to the concerns identified in an anonymous letter datedJune 20, 2006, regarding Omaha Public Power District's (OPPD's) exemption request dated June 9, 2006. The anonymous letter is publicly available in the records component of NRC'sAgencywide Documents Access and Management System (ADAMS). The ADAMS accession number for the anonymous letter is ML061800438. OPPD requested in its June 9, 2006, letter an exemption from NRC regulations to enable the use of a light-weight transfer cask (TC) andallow an earlier start time for vacuum drying. The June 20, 2006, anonymous letter requests that the NRC deny OPPD's exemption request, because in general: 1) there is no valid basis forOPPD to file the exemption request or for the NRC to grant the exemption, 2) it would l ead tohigher doses for the workers, and 3) the possibility that use of the TC with temporary shieldingintroduces a new type of accident.The need for the exemption was identified during an NRC inspection of the licensee'spreparation for the dry cask storage campaign. Interactions with the NRC led OPPDmanagement to the determination that submittal of an exemption request was the optimum pathforward for use of the light weight TC at the Fort Calhoun Station. Regarding the basis for NRCgranting the exemption, NRC's regulations permit licensees to seek exemptions in specialcircumstances which NRC may grant if it determines that the exemption is authorized by law
and will not endanger life or property or the common defense and security and is otherwise inthe public interest. NRC's basis for granting OPPD an exemption is documented in its safety evaluation report (SER) dated July 19, 2006 (ADAMS accession no. ML062000153).
Regarding doses to the workers, in the SER the staff evaluates the use of the light-weight TCand measures taken to compensate for the removal of the lead shielding in the TC (e.g., use of supplemental shielding, remote operation of the spent fuel pool building crane, and use of fuelwith a minimum cooling time of 16.2 years to reduce the dose rate). In the SER the staff evaluated the exemption against the shielding and dose requirements in 10 CFR Part 72 and 10 CFR Part 20 and concludes that these requirements are met. Regarding the possibility of introducing a new type of accident because of the introduction of the temporary shielding, thestaff also evaluated this issue in the SER. The staff's determination is that the temporaryshielding does not introduce the possibility of an accident that is not bounded by previouslyanalyzed accidents. The staff placed four conditions on the exemption which are:
1)OPPD will be limited to loading a total of four 32PT DSCs.2)OPPD shall limit the decay heat level per DSC to 11 kW to ensure cask loadings arebounded by the analyses supporting the TN CoC No. 1004, Amendment No. 8. 3)OPPD shall limit the cooling time of the fuel that it intends to load to a minimum of 16.2years to ensure that the radiological source term for fuel that is loaded in the light weightTC is kept as low as reasonably achievable.4)The TS 1.2.11 dose rate limit/specification are substituted with the limit of 170 mrem/hrin the axial direction and 110 mrem/hr in the radial direction. The axial dose rate limit of 170 mrem/hr is to be taken under the conditions in Table 1 below. The radial dose rate limit of 110 mrem/hr is to be taken under the conditions in Table 2 below.Table 1Axial Dose Rate Measurement Configuration32PT DSC inside the OS197L inside the decon sleeve/bell water drained from the DSC TC/DSC annulus full (within approximately 1 foot of the top)
TC neutron shield full top shield plug in place and included in axial shielding inner top cover plate in place and included in axial shielding automated welding system (AWS) with integral shield in place and included in axialshieldingmeasurement taken at vertical centerline of DSC, 3 feet from AWS shield Table 2Radial Dose Rate Measurement Configuration32PT DSC inside OS197L inside decon sleeve/bell water drained from the DSC TC/DSC annulus full (within approximately 1 foot of the top)
TC neutron shield full 6 inch nominal thickness carbon steel decon sleeve/bell in place and included in radialshieldingmeasurement taken at outside surface (contact) of decon sleeve/bell Given the staff's safety determination and the limited nature of the exemption, the staff believesthat the issuance of the exemption is warranted. The NRC considers public involvement in ouractivities to be a cornerstone of strong, effective, and fair regulation of the nuclear industry.
The staff appreciates the concern regarding OPPD's exemption request being identified to us.
If there are questions regarding this issue pleas e contact Joe Sebrosky at (301) 415-8500.Docket Nos. 72-54, 50-285cc:Service List Table 2Radial Dose Rate Measurement Configuration32PT DSC inside OS197L inside decon sleeve/bell water drained from the DSC TC/DSC annulus full (within approximately 1 foot of the top)
TC neutron shield full 6 inch nominal thickness carbon steel decon sleeve/bell in place and included in radialshieldingmeasurement taken at outside surface (contact) of decon sleeve/bell Given the staff's safety determination and the limited nature of the exemption, the staff believesthat the issuance of the exemption is warranted. The NRC considers public involvement in ouractivities to be a cornerstone of strong, effective, and fair regulation of the nuclear industry.
The staff appreciates the concern regarding OPPD's exemption request being identified to us.
If there are questions regarding this issue pleas e contact Joe Sebrosky at (301) 415-8500.Docket Nos. 72-54, 50-285cc:Service ListDistribution
- AWang, NRRBSpitzberg, RIVE:\Filenet\ML062010042.wpd OFC SFP OESFPOEOGCESFPOESFPOE NAMEJSebrosky EZieglerSTreby(NLO)CReganWRuland DATE7/12/067/3/067/13/067/19/067/19/06C = COVERE = COVER & ENCLOSUREN = NO COPY OFFICIAL RECORD COPY Ft. Calhoun Station, Unit 1 Service List cc:
Winston & StrawnATTN: James R. Curtiss, Esq.
1700 K Street, N.W.
Washington, DC 20006-3817ChairmanWashington County Board of Supervisors
P.O. Box 466 Blair, NE 68008Mr. John Hanna, Resident InspectorU.S. Nuclear Regulatory Commission
P.O. Box 310 Fort Calhoun, NE 68023Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007Mr. David J. Bannister, ManagerFort Calhoun Station Omaha Public Power District Fort Calhoun Station FC-1-1 Plant
P.O. Box 550 Fort Calhoun, NE 68023-0550Mr. Joe L. McManisManager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550 Fort Calhoun, NE 68023-0550Mr. Daniel K. McGheeBureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319Mr. R. T. RidenoureVice President - Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
Post Office Box 550 Fort Calhoun, Nebraska 68023-0550