[Federal Register Volume 63, Number 34 (Friday, February 20, 1998)]
[Notices]
[Pages 8703-8710]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 98-4324]
[[Page 8703]]
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NUCLEAR REGULATORY COMMISSION
[Docket Nos. 50-282, 50-306 and 72-10]
Northern States Power Company, Prairie Island Nuclear Plant and
Prairie Island Independent Spent Fuel Storage Installation; Issuance of
Director's Decision Under 10 CFR 2.206
Notice is hereby given that the Director, Office of Nuclear Reactor
Regulation, has issued a Director's Decision concerning a Petition
dated August 26, 1997, filed by the Prairie Island Coalition
(Petitioner) under Section 2.206 of Title 10 of the Code of Federal
Regulations (10 CFR 2.206). The Petitioner requests that the NRC (1)
suspend Northern States Power Company's (the licensee's) Materials
License No. SNM-2506 for cause under Section 50.100 of Title 10 of the
Code of Federal Regulations (10 CFR 50.100) until all material issues
regarding the maintenance, unloading, and decommissioning processes and
procedures, as described in the Petition and in the Petition filed on
May 28, 1997, by the Prairie Island Indian Community, have been
adequately addressed and resolved, and until the maintenance and
unloading processes and procedures in question are safely demonstrated
under the scrutiny of independent third-party review of the TN-40 cask
seal maintenance and unloading procedure; (2) determine that the
licensee violated 10 CFR 72.122(f) by using a cask design that requires
periodic seal maintenance and emergency seal replacement that must be
performed in the plant storage pool. The Petitioner asserts that these
casks cannot be placed back into the pool to perform these functions
due to unresolved problems with fuel degradation during storage, flash
steam, thermal shock, and the resulting potential for radiation
dispersion; (3) determine that the licensee violated 10 CFR 72.122(h)
by using a cask that must be placed into the pool for necessary
maintenance and/or unloading procedures. The Petitioner asserts that
such placement of the cask into the pool will prematurely degrade the
fuel and pose operational safety problems with respect to its ultimate
and necessary removal from dry cask storage; (4) determine that the
licensee violated 10 CFR 72.122(l) by loading casks and storing them
before the licensee had developed and implemented procedures adequate
to safely unload and decommission the TN-40 casks; (5) determine that
the licensee violated 10 CFR 72.130 by using the TN-40 cask and failing
to make provisions capable of accomplishing the removal of radioactive
waste and contaminated materials at the time the independent spent fuel
storage installation (ISFSI) is permanently decommissioned; (6)
determine that the licensee violated 10 CFR 72.11 by failing to provide
and include complete and accurate material information regarding
maintenance and unloading of TN-40 casks in the application for the
Prairie Island ISFSI and in subsequent submittals regarding cask
maintenance and unloading issues; (7) determine that the licensee
violated 10 CFR 72.12 by deliberately and knowingly submitting
incomplete and inaccurate material information regarding maintenance
and unloading of TN-40 casks in the application for the Prairie Island
ISFSI and in subsequent submittals regarding cask maintenance and
unloading issues; (8) require that the licensee pay a substantial
penalty for each cask loaded in violation of NRC regulations; (9)
administer such other sanctions for the alleged violations of NRC
regulations as the NRC deems necessary and appropriate; (10) provide
Petitioner the opportunity to participate in a public review of
maintenance, unloading, and decommissioning processes and procedures in
question and an opportunity to comment on draft findings after
investigation by the NRC; (11) order modification of the licensee's
Technical Specifications for the Prairie Island ISFSI to ensure a
demonstrated ability to, in fact, safely maintain, unload, and
decommission TN-40 casks; and (12) review the licensee's processes and
procedures for maintenance, unloading, and decommissioning, and if the
licensee does not possess capability to unload casks, order the
licensee to build a ``hot shop'' for air unloading of casks and
transfer of the fuel.
The Director of the Office of Nuclear Reactor Regulation has
determined that the Petition should be denied for the reasons stated in
the ``Director's Decision Under 10 CFR 2.206'' (DD-98-02), the complete
text of which follows this notice. The decision and documents cited in
the decision are available for public inspection and copying in the
Commission's Public Document Room, the Gelman Building, 2120 L Street,
NW., Washington, D.C., and at the local public document room in the
Minneapolis Public Library, Technology and Science Department, 300
Nicollet Mall, Minneapolis, Minnesota.
A copy of this decision has been filed with the Secretary of the
Commission for the Commission's review in accordance with 10 CFR
2.206(c). As provided therein, this decision will become the final
action of the Commission 25 days after issuance unless the Commission,
on its own motion, institutes a review of the decision within that
time.
Dated at Rockville, Maryland, this 11th day of February 1998.
For the Nuclear Regulatory Commission.
Frank J. Miraglia,
Acting Director, Office of Nuclear Reactor Regulation.
[DD-98-02]
Director's Decision Under 10 CFR 2.206
I. Introduction
On August 26, 1997, the Prairie Island Coalition filed a Petition
pursuant to Section 2.206 of Title 10 of the Code of Federal
Regulations (10 CFR 2.206) requesting that the U.S. Nuclear Regulatory
Commission (NRC) take action to accomplish the following:
1. Suspend Northern States Power Company's (the licensee's)
Materials License No. SNM-2506 for cause under Section 50.100 of Title
10 of the Code of Federal Regulations (10 CFR 50.100) until all
material issues regarding the maintenance, unloading, and
decommissioning processes and procedures, as described in the Petition
and in an earlier Petition filed on May 28, 1997, by the Prairie Island
Indian Community, have been adequately addressed and resolved, and
until the maintenance and unloading processes and procedures in
question are safely demonstrated under the scrutiny of independent
third-party review of the TN-40 cask seal maintenance and unloading
procedure;
2. Determine that the licensee violated 10 CFR 72.122(f) by using a
cask design that requires periodic seal maintenance and emergency seal
replacement that must be performed in the plant storage pool. The
Petitioner asserts that these casks cannot be placed back into the pool
to perform these functions due to unresolved problems with fuel
degradation during storage, flash steam, thermal shock, and the
resulting potential for radiation dispersion;
3. Determine that the licensee violated 10 CFR 72.122(h) by using a
cask that must be placed into the pool for necessary maintenance and/or
unloading procedures. The Petitioner asserts that such placement of the
cask into the pool will prematurely degrade the fuel and pose
operational safety problems with respect to its ultimate and necessary
removal from dry-cask storage;
4. Determine that the licensee violated 10 CFR 72.122(l) by loading
casks and storing them before developing and preparing procedures
adequate to safely
[[Page 8704]]
unload and decommission the TN-40 casks;
5. Determine that the licensee violated 10 CFR 72.130 by using the
TN-40 cask and failing to make provisions capable of accomplishing the
removal of radioactive waste and contaminated materials at the time the
independent spent fuel storage installation (ISFSI) is permanently
decommissioned;
6. Determine that the licensee violated 10 CFR 72.11 by failing to
provide and include complete and accurate material information
regarding maintenance and unloading of TN-40 casks in the application
for the Prairie Island ISFSI and in subsequent submittals regarding
cask maintenance and unloading issues;
7. Determine that the licensee violated 10 CFR 72.12 by
deliberately and knowingly submitting incomplete and inaccurate
material information regarding maintenance and unloading of TN-40 casks
in the application for the Prairie Island ISFSI and in subsequent
submittals regarding cask maintenance and unloading issues;
8. Require that the licensee pay a substantial penalty for each
cask loaded in violation of NRC regulations;
9. Administer such other sanctions for the alleged violations of
NRC regulations as the NRC deems necessary and appropriate;
10. Provide Petitioner the opportunity to participate in a public
review of maintenance, unloading, and decommissioning processes and
procedures in question and an opportunity to comment on draft findings
after investigation by the NRC;
11. Order modification of the licensee's Technical Specifications
for the Prairie Island ISFSI to ensure a demonstrated ability to in
fact safely maintain, unload, and decommission TN-40 casks; and
12. Review the licensee's processes and procedures for maintenance,
unloading, and decommissioning, and if the licensee does not possess
capability to unload casks, order the licensee to build a ``hot shop''
for air unloading of casks and transfer of the fuel.
The Petition has been referred to me pursuant to 10 CFR 2.206. The
NRC letter dated October 2, 1997, to George Crocker, on behalf of the
Petitioner, acknowledged receipt of the Petition and reported the NRC
staff's determination that the Petition did not require immediate
action to be taken by the NRC. The letter of October 2, 1997, also
explained that the NRC staff would address the requests for formal
rulemaking proceedings as detailed in Items 13, 14, and 15 of the
Petition, in accordance with 10 CFR 2.802, ``Petition for Rulemaking.''
A notice of receipt was published in the Federal Register on October
10, 1997 (62 FR 53031).
On the basis of the NRC staff's evaluation of the issues and for
the reasons given below, the Petitioner's requests as detailed in Items
1 through 12 of the Petition are denied.
II. Background
On October 19, 1993, the NRC issued Materials License No. SNM-2506
to allow the licensee to store spent nuclear fuel in TN-40 dry-storage
casks, designed by Transnuclear Incorporated, at the ISFSI located at
the Prairie Island Nuclear Plant. The NRC issued Technical
Specifications (TS) defining operating limits, surveillance
requirements, design features, and administrative controls as Appendix
A to Materials License No. SNM-2506. No spent nuclear fuel was allowed
to be loaded into a storage cask at Prairie Island until several
preoperational license conditions were satisfied. Among the
preoperational license conditions were a required training exercise
(dry-run) of the loading, handling, and unloading activities for the
TN-40 casks and the implementation of written procedures describing the
actions to be taken during operational, off-normal, and emergency
conditions associated with the Prairie Island ISFSI.
A report dated April 20, 1995, submitted by the licensee to the NRC
pursuant to 10 CFR 72.82(e), gave the results of the preoperational
tests that the licensee was required to perform before loading spent
fuel into a TN-40 cask.1 On May 12, 1995, following the
completion of the staff's reviews and inspections that found that the
licensee had satisfied the conditions of the license, the licensee
began loading spent fuel assemblies into a TN-40 cask. The licensee
subsequently placed the cask, and casks loaded since that time, onto
the storage pad within the Prairie Island ISFSI.
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\1\ On May 11, 1995, the NRC granted a schedular exemption to
the provision of 10 CFR 72.82(e) that requires licensees to submit
the preoperational test results at least 30 days before receipt of
spent fuel into the ISFSI. The basis for the exemption was the fact
that the NRC staff had reviewed cask fabrication records, observed
portions of the preoperational test activities, and completed its
review of the report submitted on April 20, 1995.
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The NRC staff's determination that the licensee was in compliance
with applicable regulations and license conditions was the basis for
the NRC staff's decision to approve the ISFSI at Prairie Island and to
allow the actual loading of TN-40 casks at that facility. The
Petitioner has requested that, in light of the information in the
Petition, the NRC staff reconsider its findings and suspend Materials
License No. SNM-2506. The regulations cited by the Petitioner as those
that establish technical requirements not being satisfied by the
licensee for the ISFSI at Prairie Island are:
72.122(f) Testing and maintenance of systems and
components. Systems and components that are important to safety must be
designed to permit inspection, maintenance, and testing.
72.122(h) Confinement barriers and systems. (1) The spent
fuel cladding must be protected during storage against degradation that
leads to gross ruptures or the fuel must be otherwise confined such
that degradation of the fuel during storage will not pose operational
safety problems with respect to its removal from storage. This may be
accomplished by canning of consolidated fuel rods or unconsolidated
assemblies or other means as appropriate.
72.122(l) Retrievability. Storage systems must be designed
to allow ready retrieval of spent fuel or high-level radioactive waste
for further processing or disposal.
72.130 Criteria for decommissioning. The ISFSI or MRS
(monitored retrievable storage [installation]) must be designed for
decommissioning. Provisions must be made to facilitate decontamination
of structures and equipment, minimize the quantity of radioactive
wastes and contaminated equipment, and facilitate the removal of
radioactive wastes and contaminated materials at the time the ISFSI or
MRS is permanently decommissioned.
The regulations in 10 CFR Part 72 require that the design of the
storage system and the procedures implemented by specific licensees
support the unloading activity, whether it is being performed to allow
further processing or disposal of the spent fuel, such as may be
necessary to support decommissioning of the ISFSI; as part of planned
maintenance activities; or as part of the response to an unplanned
event or condition. The unloading of a cask, for any reason, should be
performed in a manner that prevents gross rupture of the fuel cladding,
which could result in operational safety problems. Although unloading
procedures need not contain detailed guidance on removing damaged fuel,
they should contain precautions in case fuel cladding has unexpectedly
degraded during storage so that additional measures can be taken to
address increased radiological hazards during the unloading process.
NRC regulations, facility licenses, and NRC-approved quality
assurance
[[Page 8705]]
programs require licensees to establish and maintain a formal process
for preparing and issuing procedures and changes thereto. NRC
assessments of licensee procedures are generally conducted within the
NRC's inspection program. The major procedures pertaining to dry-cask-
storage activities at Prairie Island, including the procedure for
unloading a cask, were reviewed by the NRC staff during a special
inspection conducted from January 24 through May 11, 1995, to oversee
the preoperational activities discussed above. In addition to reviewing
the licensee's facility and procedures, as previously noted, the NRC
inspectors observed preoperational testing that the licensee was
required to perform before loading casks with spent fuel assemblies.
The inspection findings are documented in NRC Inspection Report 50-282/
95002; 50-306/95002; 72-10/95002(DRP), dated June 30, 1995.
The NRC inspectors noted several instances in which the procedures
for dry-cask-storage activities that the licensee had in place at the
beginning of the inspection, including the procedures for loading and
unloading of TN-40 casks, did not ensure compliance with the
requirements of the license. Although the licensee corrected these
procedural deficiencies during the course of the inspection, the staff
issued a Notice of Violation to the licensee for failing to satisfy
Criterion V of Appendix B to 10 CFR Part 50, which, for activities
affecting quality, requires the preparation of and adherence to
procedures appropriate to the circumstances. In addition, the
inspectors found weaknesses in the licensee's initial performance in
overseeing the activities of the cask vendor and in overall planning
for dry-cask-storage activities. On the basis of the licensing reviews
and inspection findings, documented in Inspection Report 50-282/95002;
50-306/95002; 72-10/95002(DRP), the NRC staff concluded that as of May
1995, the licensee had corrected these deficiencies and was ready to
safely load, and if necessary unload, spent nuclear fuel in TN-40
casks.
In July 1995, the NRC staff issued an action plan for dry-cask
storage to manage the resolution of a variety of technical and process
issues that were noted during the licensing reviews and inspections
completed for the first several ISFSI facilities, including the ISFSI
at Prairie Island. An item related to the loading and unloading of dry-
storage casks was added to the action plan, in part to ensure that the
importance of the unloading procedures was emphasized to licensees and
that technical issues related to unloading problems were resolved.
Addition of an item pertaining to unloading was deemed prudent because
the staff observed that some of the licensees' unloading procedures
failed to consider contingencies and assumptions related to possible
fuel degradation, gas-sampling techniques, cask design issues,
radiation protection requirements, and the thermal-hydraulic behavior
of a cask during the process of cooling and filling it with water from
the spent fuel pool.
To fulfill the goals of its dry-cask-storage action plan, the NRC
staff has emphasized the importance of unloading procedures and shared
observations with licensees using or considering dry-cask storage. The
staff revised inspection procedures and licensing review guidance to
specifically instruct NRC inspectors to review unloading procedures
developed by licensees and to identify those issues that warrant
particular attention. Application of the revised guidance ensures that
recent and future reviews will address the adequacy of unloading
procedures developed by licensees. To address those ISFSIs that began
operation before NRC improved its guidance on review and inspection,
the staff audited or inspected those licensee programs for which the
inspection record did not document whether the unloading procedures
adequately addressed the major issues in the action plan. Regarding
Prairie Island, the staff reviewed the available information and
determined that the assessment of the unloading procedure performed as
part of the inspection documented in NRC Inspection Report 50-282/
95002; 50-306/95002; 72-10/95002(DRP) adequately addressed the concerns
in the NRC action plan, and that additional reviews or inspections
therefore were not necessary.
In a Petition dated June 5, 1995, Prairie Island Coalition
requested that, among other things, the NRC review--and take whatever
administrative actions were necessary concerning--the licensee's plans
to unload a TN-40 cask if the spent fuel pool lacked sufficient space
to accommodate the spent fuel assemblies from a cask. The NRC staff
issued Northern States Power Company (Prairie Island Nuclear Generating
Plant, Units 1 and 2), DD-96-21, 44 NRC 297, on November 27, 1996,
denying the Petitioner's request. The denial was based, in part, on the
staff's finding that if a cask must be unloaded, it is unlikely that
the need to unload it would represent a time-urgent activity and the
licensee would be able to develop and execute a plan to maintain the
safe storage of the spent fuel assemblies. The NRC staff determined
that even if such an unlikely event occurred and the licensee needed to
implement corrective actions to maintain safe storage conditions,
options would be available to the licensee. These options include
returning a cask to the auxiliary building, returning a cask to the
spent fuel pool without actually removing the spent fuel, and removing
non-fuel-bearing components from the spent fuel pool to allow the
removal of fuel assemblies from a cask. Id., 44 NRC at 309.
The Petitioner has incorporated by reference a Petition dated May
28, 1997, filed by the Prairie Island Indian Community, which, among
other things, asked the NRC to suspend Materials License No. SNM-2506
on the premise that the licensee has failed to establish adequate
procedures for safely unloading the TN-40 dry-storage containers. The
Prairie Island Indian Community also requested that an independent
third-party review of the TN-40 unloading procedure be conducted, that
they be given an opportunity to participate fully in the reviewing of
the unloading procedure for the TN-40 cask, that the NRC hold hearings
and allow them to participate fully in these and in any other
procedures initiated in response to their Petition, and that the TS for
the Prairie Island ISFSI be revised to incorporate mandatory unloading
procedure requirements. The NRC issued Northern States Power Company
(Prairie Island Nuclear Plant and Prairie Island Independent Spent Fuel
Storage Installation), DD-97-18, on August 29, 1997, denying the
requests made by the Prairie Island Indian Community. Although the
staff acknowledged the potential difficulties in retrieving fuel from
dry-storage casks if significant fuel degradation has occurred, the NRC
staff concluded that licensees need not be required to incorporate
specific guidance into the normal unloading procedure to address this
unlikely situation. This conclusion was based on the staff's findings
that (1) the licensee's procedure could support the normal unloading of
spent fuel assemblies from TN-40 casks at Prairie Island, (2) the
licensee's unloading procedure contained the necessary measurements and
precautions to detect if fuel had degraded during storage, and (3) the
licensee could reasonably be expected to develop procedures to safely
unload damaged fuel assemblies in the unlikely event that fuel did
degrade during storage.
[[Page 8706]]
III. Discussion
The Petitioner requests actions by the NRC based on the contention
that the unloading procedure developed by the licensee is inadequate
and, therefore, the licensee has violated various NRC regulations
related to having the ability to test and maintain systems and
components, protecting the spent fuel cladding from degradation,
designing storage systems to allow ready retrieval of spent fuel for
further processing or disposal, and designing ISFSIs to facilitate
decommissioning activities. In addition, the Petitioner alleges that
the licensee violated NRC regulations pertaining to the submittal of
complete and accurate information regarding maintenance and unloading
issues associated with the TN-40 cask.
Item 1. Suspend SNM-2506
On the basis of the contention that the licensee's unloading
procedure is inadequate, and, therefore, that the licensee is in
violation of NRC regulations such as 10 CFR 72.122 and 10 CFR 72.130,
the Petitioner requests that Materials License No. SNM-2506 be
suspended for cause, in accordance with 10 CFR 50.100, until such time
as the significant issues in the unloading process have been resolved
and the unloading process has been demonstrated under the scrutiny of
an independent third-party review.2
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\2\ The Petitioners request that Materials License No. SNM-2506
be suspended for cause in accordance with 10 CFR 50.100. Provisions
for the modification, revocation, or suspension of the licenses for
ISFSI facilities are contained in 10 CFR 72.60. The possible reasons
for suspending licenses for ISFSIs in accordance with 10 CFR 72.60
are similar to the corresponding reasons for suspending licenses for
production and utilization facilities in accordance with 10 CFR
50.100.
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As previously stated, the NRC staff has reviewed the licensee's
procedure for unloading a TN-40 cask at Prairie Island. The review,
including verification that the licensee's unloading procedure was
revised to address deficiencies found by the NRC inspectors, is
documented in NRC Inspection Report 50-282/95002; 50-306/95002; 72-10/
95002(DRP). Reasonable confidence that the licensee could, if
necessary, safely unload a TN-40 cask is supported by the findings from
the NRC inspection. The findings of subsequent evaluations performed by
the NRC staff as part of the activities associated with the dry-cask-
storage action plan and the review of the Petition filed by the Prairie
Island Indian Community confirmed the adequacy of the licensee's
procedure for unloading a cask. The licensee is required to maintain
the adequacy of the unloading procedure through programs required by
NRC regulations, facility licenses, and NRC-approved quality assurance
programs. Additional bases for the staff's findings regarding the cited
regulatory requirements are discussed in the sections that follow. The
NRC staff has determined that the findings discussed in the subsequent
sections of this decision adequately address the Petitioner's claims
regarding the licensee's compliance with the regulatory requirements
pertaining to retrievability of spent fuel, maintenance of ISFSI
systems, and decommissioning. The Petitioner's request to suspend
Materials License No. SNM-2506 is, therefore, denied.
Regarding a third-party review, the NRC staff's concern about the
quality of licensees' unloading procedures led NRC to include the issue
in the dry-cask-storage action plan. The action plan served as a
framework for identifying and resolving various technical and
administrative issues related to the use of dry-storage casks. The
previously-mentioned actions taken by the NRC staff and licensees
adequately resolved the issues pertaining to cask unloading procedures.
In the specific case of the unloading procedure at Prairie Island, the
licensee revised the procedure to address the problems raised by the
staff during its inspection. On the basis of the actions it has already
taken, the NRC staff does not believe that requiring additional
demonstration of the procedures or review of the licensee's procedures
by an independent third party is warranted.
Item 2. Determine That the Licensee Violated 10 CFR 72.122(f)
The Petitioner requests that the NRC determine that the licensee
violated 10 CFR 72.122(f) by using a cask design that may require
periodic seal maintenance or seal replacement that would necessitate
returning the cask to the spent fuel pool. The Petitioner asserts that
these casks cannot be placed back into the pool for the licensee to
perform these functions, due to unresolved problems with fuel
degradation during storage, flash steam, thermal shock, and the
resulting potential for radiation dispersion. The Petitioner states
that such a condition is in violation of the requirements that systems
and components that are important to safety must be designed to permit
inspection, maintenance, and testing.
The fact that the TN-40 cask design uses metallic seals to maintain
the helium atmosphere within the cask was thoroughly reviewed during
the licensing of the Prairie Island ISFSI as well as during staff
reviews of similar casks designed by Transnuclear Inc., such as the TN-
24 cask, which has been certified as an acceptable cask for use under
the general licensing provisions of Subpart K of 10 CFR Part 72, and
the TN-32 cask, which has had an associated topical report approved by
the NRC staff for referencing in site-specific licensing applications.
The seal design and related pressure-monitoring system were found to
provide the necessary confidence that the inert atmosphere would be
maintained and thereby prevent degradation of the fuel cladding during
storage.
If it were necessary to repair or replace the metallic seals, the
licensee would use the unloading procedure or a similar procedure to
control the return of a TN-40 cask to the spent fuel pool. As will be
discussed in more detail in the following section, the staff has
determined that the licensee's unloading procedure is adequate. As
documented in NRC Inspection Report 50-282/95002; 50-306/95002; 72-10/
95002(DRP), the NRC staff did not require demonstration of seal
replacement activities but did find that those activities performed
during the dry-run exercises were adequate to demonstrate that such an
activity could, if necessary, be accomplished. Given the staff's
finding that the licensee's procedure for returning a cask to the spent
fuel pool and subsequently unloading the fuel would not cause
operational safety problems and the fact that the same procedure or a
similar procedure would be used to support the repair or replacement of
a TN-40 cask's metallic seals, the NRC concludes that the licensee has
not violated 10 CFR 72.122(f) as alleged by the Petitioner.
Item 3. Determine That the Licensee Violated 10 CFR 72.122(h)
The Petitioner requests that the NRC determine that the licensee
violated 10 CFR 72.122(h) by using a cask that must be placed into the
spent fuel pool to perform necessary maintenance and unloading
procedures. The Petitioner asserts that such placement of the cask into
the pool will prematurely degrade the fuel and pose operational safety
problems with respect to its ultimate and necessary removal from dry-
cask storage. The Petitioner states that such a condition is in
violation of the requirements that spent fuel cladding either be
protected against degradation that leads to gross ruptures or otherwise
confined so that fuel degradation during storage will not pose
operational safety problems with respect to its removal from storage.
[[Page 8707]]
The staff has found that the TN-40 cask can adequately maintain the
inert atmosphere within the cask to prevent fuel degradation and
provides for sufficient indication of the loss of the inert atmosphere
using the pressure-monitoring system. Maintaining the inert atmosphere
and other design requirements established for the TN-40 casks is
sufficient to protect the fuel cladding during storage. In the event
that the pressure-monitoring system indicates that the helium
atmosphere is not being maintained within a TN-40 cask, the TS for the
Prairie Island ISFSI require that the cask be returned to the spent
fuel pool for replacing or repairing the seals.
The Petitioner asserts that the return of the cask to the spent
fuel pool will prematurely degrade fuel and poses operational safety
problems. In support of this assertion, the Petitioner enclosed, as
Exhibit A to the Petition, a letter from Dr. Gail Marcus of the NRC
staff, dated February 25, 1997, which responded to an inquiry made to
the NRC staff by Mr. George Crocker of the Prairie Island Coalition. In
the letter, Dr. Marcus makes the following statements:
(1) As part of its assessments of licensees' procedures for
unloading dry storage casks, the NRC staff considers the dry-run
exercises performed to verify key aspects of unloading procedures,
as well as licensees' actual experience in the loading and unloading
of transportation casks, loading of storage casks, handling of spent
fuel assemblies under various conditions, and performing various
activities associated with reactor facilities. In the absence of
actual experience in unloading spent fuel from a cask following a
long period of storage, a general understanding of technical
capabilities and related experiences enables the NRC staff to assess
the adequacy of a licensee's procedures for unloading dry storage
casks.
(2) Although the limited unloading experiences with storage
casks have not involved the temperature differences between fuel and
coolant that may occur if a cask was unloaded after a period of
storage, engineering evaluations and experiences with transportation
casks have shown that ``thermal shocking'' is unlikely to cause
operational safety problems.
(3) Although licensees would be able to develop means to
retrieve degraded fuel assemblies from a dry storage cask, the
accumulated occupational dose to perform this activity may be
increased from the previously mentioned estimates. Fuel reactivity
for criticality considerations could increase only under very
idealistic and highly unlikely disintegration patterns in the fuel.
Upon detection that fuel disintegration had occurred, special
measures would be developed and implemented to assure an adequate
safety margin is maintained during unloading.
The statement regarding ``thermal shock'' is based on the fact that
the licensee's unloading procedure contains precautions to slowly
introduce water to the TN-40 cask and thereby minimize the thermal
shock to the fuel assemblies. As explained in DD-97-18, at pp. 13-14,
the NRC staff does not believe that the process of refilling a cask
with water and returning it to the spent fuel pool will cause fuel
degradation or operational safety problems. In DD-97-18, the staff
stated:
The Petitioners expressed concerns regarding the reaction of the
cask and stored fuel assemblies to the introduction of spent fuel
pool water during the execution of the unloading procedure. The
unloading procedure includes the partial immersion of the TN-40 cask
into the spent fuel pool, connection of hoses to the vent and drain
connections, and the slow introduction of spent fuel pool water to
the cask cavity and stored fuel assemblies. The procedure instructs
personnel to continuously monitor the temperature and pressure
instrumentation installed on the vent connection and to stop pumping
water if the pressure exceeds 10 psig or the temperature exceeds 240
deg.F. In the staff's judgment, the cooling process imposed by
these limitations on temperatures and pressures at the vent port of
the cask will adequately ensure that the cooling of the cask and
spent fuel is gradual and, thereby, prevent safety problems that
could hypothetically result from damage to the cask or the fuel
assemblies because of stresses induced by a poorly controlled
addition of cooling water from the spent fuel pool.
The Petitioner also cites a letter dated April 15, 1997, from Susan
Frant Shankman of the NRC staff to Sierra Nuclear Corporation, which
emphasizes that NRC regulations require that inert atmospheres be
maintained within dry-storage casks in order to prevent fuel
degradation during storage. The Petitioner states that the pressure-
monitoring system is included in the design because the loss of helium
from TN-40 casks is an anticipated event and that neither fuel
degradation that may result from a loss of the helium nor the method by
which the licensee would replace a damaged seal has been addressed. As
previously mentioned, the NRC staff has found that the design of the
TN-40 casks, including its combination of metallic seals and a
pressure-monitoring system, is adequate to maintain a helium atmosphere
within the cask. The helium atmosphere, in turn, has been found, when
combined with other restrictions in the license for the Prairie Island
ISFSI, to adequately protect against degradation of the spent fuel
cladding.
Given its finding that (1) fuel integrity will be maintained during
normal storage by the inert atmosphere and (2) the return of a cask to
the spent fuel pool for unloading or seal maintenance would not result
in fuel degradation that would result in operational safety problems,
the NRC staff has not identified a violation of 10 CFR 72.122(h) at the
Prairie Island ISFSI, as is claimed by the Petitioner.
Item 4. Determine That the Licensee Violated 10 CFR 72.122(l)
The Petitioner requests that the NRC determine that the licensee
violated 10 CFR 72.122(l) by loading casks and storing them before the
licensee had developed and implemented procedures adequate to safely
unload and decommission the TN-40 casks.
The staff's basis for determining that the licensee has not
violated the requirements of 72.122(l) for the reasons cited by the
Prairie Island Indian Community was discussed in DD-97-18. As discussed
in DD-97-18, normal unloading procedures do not need to incorporate
contingency actions for failed fuel, provided that precautions exist to
check for fuel degradation before breaching the confinement boundaries
of a cask. In the unlikely event that fuel degradation has occurred
during storage, the licensee would need to address the retrieval of
failed fuel and implement necessary precautions related to the
radioactive and fissile materials within the cask.
In support of its claim regarding potential problems in unloading a
TN-40 cask, the Petitioner enclosed, as Exhibit B to the Petition, a
letter from the NRC staff which asked the licensee questions about a
proposed amendment to the operating license for the Prairie Island
Nuclear Generating Plant. 3 The proposed and subsequently
issued amendment pertained to the TS associated with the operability of
the
[[Page 8708]]
reactor facility's spent fuel pool special ventilation system during
movement of fuel assemblies within the spent fuel pool enclosure.
During its review of the proposed amendment, the NRC staff requested
that the licensee submit additional information about the use of the
ventilation system during the possible unloading of dry-storage casks.
This request for additional information, dated July 10, 1997, is the
letter cited by the Petitioner. In its response of July 29, 1997, to
the staff's request for additional information, the licensee explained
the relationship of the ventilation system to dry-cask activities and
clarified details of the procedure for unloading a TN-40 cask. The NRC
was satisfied with the licensee's response to the questions which
explained that the spent fuel pool special ventilation system is not
operable during the filling and venting of a cask during the unloading
procedure and that cracking of spent fuel rods is not expected as a
result of introducing water to the cask during the unloading procedure.
Those aspects of the proposed revision to the Prairie Island TS that
potentially related to dry-cask activities were subsequently approved
by the NRC staff in Amendment No. 130 to Facility Operating License No.
DPR-42 and Amendment No. 122 to Facility Operating License No. DPR-60.
---------------------------------------------------------------------------
\3\ The Petitioner also claims that an NRC memorandum dated
April 16, 1997, that addressed a request from an NRC regional office
for clarification of terms associated with dry-cask storage, is
deficient in that it does not address possible problems that may be
encountered during unloading of a dry-storage cask or all of the
possible reasons for returning a dry-storage cask to the spent fuel
pool. In that memorandum, the staff stated:
The two basic reasons to return a cask to the spent fuel pool
and unload the spent fuel assemblies are either to (1) retrieve the
fuel assemblies for further processing or disposal or (2) respond to
an event or condition that has potentially degraded the design
requirements established for the cask.
The Petitioner claims that the memorandum failed to address two
reasons to return a cask to the spent fuel pool; maintenance of the
metallic seals and decommissioning of the ISFSI. These are, however,
only specific examples of the general reasons given above to unload
a cask. Seal maintenance is performed to respond to or prevent a
condition that potentially degrades the design requirements
associated with maintaining the inert atmosphere; decommissioning of
the ISFSI would obviously require retrieving or transporting the
fuel assemblies for further processing or disposal.
---------------------------------------------------------------------------
In support of its claim regarding potential problems with removing
fuel assemblies from TN-40 casks, the Petitioner enclosed, as Exhibits
C and D to the Petition, letters from personnel at the Idaho National
Engineering Laboratory (INEL) regarding problems with removing fuel
canisters from a TN-24P cask during testing at INEL. The TN-24P cask is
similar in design to the TN-40 cask used at Prairie Island. The
problems were addressed in the rulemaking that added Transnuclear
Inc.'s TN-24 cask to the list of NRC-certified casks. The subject
comment on the proposed rulemaking pertaining to the TN-24 cask and the
NRC staff's response as published in the Federal Register (58 FR 51762)
are provided below:
2. Comment. One commenter stated that the TN-24 cask is
seriously flawed. Test and operation at Idaho showed the TN-24
storage sleeves to be subject to warpage after only a few years of
storage. A fuel assembly became stuck in the TN-24 cask while trying
to remove it. It could not be removed and it was forced back into
the cask.
Response. The NRC discussed this issue with personnel at INEL
who worked on the tests of the TN-24 cask and other casks. These
individuals said that a canister of consolidated fuel, not a fuel
assembly, got stuck in the TN-24 cask. The canister was larger than
a fuel assembly and, unlike a fuel assembly, it had many screws and
nuts protruding from it. The storage sleeves in the TN-24 Basket did
not warp. The individuals suspect that one of the screws or nuts got
caught on an interlocking plate in the basket of the TN-24 cask. The
Certificate of Compliance does not allow the storage of consolidated
fuel in canisters. Additionally, the basket of the TN-24 tested at
INEL is slightly different from the one which Transnuclear plans to
use in its certified cask.
The license issued for the Prairie Island ISFSI also prohibits the
storage of consolidated fuel assemblies and, therefore, the problems
with unloading experienced during the testing at INEL are not expected
to occur when the licensee unloads its TN-40 casks.
The Petitioner asserts that additional evidence that dry-storage
casks cannot be unloaded is provided by the experiences of the licensee
for the ISFSI at the Palisades Nuclear Plant. As discussed in detail in
NRC Inspection Report 50-255/96201(NRR) dated September 4, 1997, the
NRC staff has found that the Palisades dry-cask unloading procedure,
along with supporting operating, maintenance, radiation protection, and
administrative procedures, contains adequate directions for the safe
unloading of VSC-24 storage casks. 4
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\4\ The NRC staff has also found that the subject cask can
safely be used for storing spent fuel despite the licensee's
announced plans for unloading the cask after it discovered (from
radiographs for a weld in a VSC-24 multi-assembly sealed basket)
indications of possible defects. The licensee subsequently announced
that it was deferring the unloading of the cask pending the
availability of a cask that supports both storage and transport
functions.
---------------------------------------------------------------------------
Much of the argument pertaining to the inadequacy of the licensee's
unloading procedure that is presented by the Petitioner centers on the
lack of an actual example of the unloading of a dry-storage cask at a
commercial reactor facility. As discussed in DD-97-18, the NRC staff's
judgment that there is reasonable assurance that the TN-40 casks can be
safely unloaded comes from a variety of experiences related to the use
and storage of radioactive materials. Among these experiences are the
dry-run exercises that were performed to verify key aspects of
unloading procedures for the TN-40 cask; related research sponsored by
the commercial nuclear industry, the U.S. Department of Energy, and the
NRC; actual loading and unloading of transportation casks; loading of
storage casks; handling of spent fuel assemblies under various
conditions; and performing relevant maintenance and engineering
activities associated with reactor facilities.
The NRC staff has reviewed the information submitted by the
Petitioner and has determined that the licensee could, if necessary,
unload a TN-40 cask and has not, therefore, identified a violation of
10 CFR 72.122(l).
Item 5. Determine That the Licensee Violated 10 CFR 72.130
The Petitioner requests that the NRC determine that the licensee
violated 10 CFR 72.130 by using the TN-40 cask and failing to make
provisions to successfully accomplish the removal of radioactive waste
and contaminated materials at the time the independent spent fuel
storage installation (ISFSI) is permanently decommissioned. The basis
for this assertion is that TN-40 casks cannot be safely unloaded. As
discussed in previous sections and as discussed in DD-96-21, the NRC
staff has found that spent nuclear fuel can be safely unloaded from the
TN-40 casks, whether such unloading is necessary in response to an
event or in support of decommissioning the ISFSI.
In order to support the decommissioning of the Prairie Island
ISFSI, the licensee may need to transfer the spent fuel stored in TN-40
casks to another cask for transfer of the fuel assemblies to another
location for storage or disposal. In order to transfer the spent fuel
assemblies, the licensee will need to either return the casks to the
spent fuel pool or use a yet-to-be-approved system that transfers fuel
assemblies under dry conditions. In the event that the spent fuel pool
is used to transfer fuel assemblies, the unloading procedure or a
similar procedure would control the return of the fuel from the ISFSI
to the spent fuel pool. Given that the staff has determined that the
unloading procedure is adequate to control the unloading of fuel
assemblies from a TN-40 cask to the spent fuel pool, the staff has no
reason to (1) find that its use as part of the decommissioning of the
ISFSI facility raises unique questions regarding compliance with 10 CFR
72.130 or (2) otherwise change the conclusion it reached during the
licensing of the ISFSI at Prairie Island regarding the viability of
decommissioning the facility.
Item 6. Determine That the Licensee Violated 10 CFR 72.11
The Petitioner requests that the NRC determine that the licensee
violated 10 CFR 72.11 by failing to provide and include complete and
accurate material information regarding maintenance and unloading of
TN-40 casks in the application for the Prairie Island ISFSI and in
subsequent submittals on the
[[Page 8709]]
subject of cask maintenance and unloading. In support of this
contention, the Petitioner references the letter from G. Marcus dated
February 25, 1997, (Exhibit A to the Petition), which explained the NRC
action plan for dry-cask storage and its item related to oversimplified
descriptions of the process for unloading fuel from casks as the
reverse of loading casks. In that letter to Mr. Crocker of the Prairie
Island Coalition, Dr. Marcus states:
Some SARs do state that unloading is basically the reverse of
loading and this statement, in a general sense, is true, However,
such statements may tend to over-simplify matters because they do
not reflect that the unloading process introduces different
conditions and complications compared to the loading process. In the
NRC action plan for dry cask storage and related statements made by
the NRC staff, including those by Mr. Kugler, the staff was
emphasizing that licensees need to identify the conditions and
complications that are associated with the unloading process and
ensure that unloading procedures address those concerns. The
unloading procedure for the dry storage casks at Prairie Island was
inspected by the NRC staff and, following minor revisions, was found
to provide adequate guidance to control the unloading process. A
copy of NRC Inspection Report 50-282/95002; 50-306/95002; 72-10/
95002 is provided as Enclosure 2.
The petitioner asserts that upon receipt of information related to
unloading issues, the licensee has not taken steps to correct its
unloading problem and has refused to address these continuing problems.
As stated in DD-97-18, in response to a similar request made by the
Prairie Island Indian Community, the safety analysis report (SAR) for
the Prairie Island ISFSI and other docketed correspondence do state
that a TN-40 cask would be unloaded using a procedure that is basically
the reverse of the procedure used to load the cask. Although this
statement, in a general sense, is true, the NRC staff has expressed its
concerns that such statements may oversimplify the description of the
unloading activity. For this reason, the NRC staff added an item
related to unloading procedures to its dry-cask-storage action plan to
ensure that actual unloading procedures did not reflect such an
oversimplified representation. Additional inspections, revised staff
guidance, and communications with the nuclear industry were conducted
under the staff's action plan related to this issue. The staff
inspected the unloading procedures at Prairie Island and found that
they provided adequate guidance to control the unloading process.
The staff's review of the information originally submitted by the
licensee shows that the information pertaining to cask unloading was
complete and accurate given the staff's expectations and the
information provided by other licensees in applications submitted in
the same time period. It should be noted that material submitted by the
licensee for the ISFSI at Prairie Island includes copies of the loading
and unloading procedures and those procedures have been available for
public review. Regarding the information given to the NRC pertaining to
maintenance of the TN-40 casks, which the Petitioner also claims was
incomplete and inaccurate, the NRC staff acknowledged in its safety
evaluation report that maintenance activities were discussed only
briefly in the submittals supporting the ISFSI at Prairie Island. The
level of information submitted, however, was generally consistent with
the level of information in other applications of that same time period
and was sufficient to meet the staff's expectations for the review
process. The NRC staff has not identified a violation of 10 CFR 72.11
pertaining to the information provided by the licensee as is claimed by
the Petitioner.
Item 7. Determine That the Licensee Violated 10 CFR 72.12
The Petitioner requests that the NRC determine that the licensee
violated 10 CFR 72.12 by deliberately and knowingly submitting
incomplete and inaccurate material information regarding maintenance
and unloading of TN-40 casks in the application for the Prairie Island
ISFSI and in subsequent submittals on cask maintenance and unloading
issues. The Petitioner states that the licensee has continually
insisted that it can unload TN-40 casks and that the licensee has
referenced inapplicable studies to support its position.
As mentioned in the response to the preceding item, the staff
believes that the information submitted by the licensee is consistent
with the information in other applications of that same time period and
was sufficient to meet the staff's expectations for the review process.
Given that the NRC staff has found that the licensee could, if
necessary, unload a cask, the staff does not agree this statement when
made by the licensee was deliberately incomplete or inaccurate
information in any material respect. The NRC staff has not identified a
violation of 10 CFR 72.12 pertaining to the information provided by the
licensee as is claimed by the Petitioner.
Item 8. Require That the Licensee Pay a Substantial Penalty
The Petitioner requests that the NRC require the licensee to pay a
substantial penalty for each cask loaded in violation of NRC
regulations. Given that the staff has not identified violations of NRC
regulations as alleged by the Petitioner, the staff has no basis to
issue a notice of violation and proposed civil penalty.
Item 9. Administer Other Sanctions Deemed Necessary and Appropriate
The Petitioner requests that the NRC administer such other
sanctions for the alleged violations of NRC regulations as the NRC
deems necessary and appropriate. Given that the staff has not
identified violations of NRC regulations as alleged by the Petitioner,
there is no basis for sanctions against the licensee.
Item 10. Provide Petitioner the Opportunity to Review Procedures
The Petitioner requests that it be given the opportunity to
participate in a public review of maintenance, unloading, and
decommissioning processes and procedures in question and an opportunity
to comment on draft findings after investigation by the NRC.
Regarding the unloading procedure, the licensee has provided the
NRC with the unloading procedure, including Revision 2, dated November
8, 1996, for placement into the public record, and the Petitioner has
been supplied with a copy of the procedure. Accordingly, the Petitioner
has had the opportunity to review a recent revision of the unloading
procedure and may continue to review other documents in the public
domain. As previously discussed in this decision, the NRC staff has
performed various technical reviews and inspections related to the
issues raised by the Petitioner. These reviews and inspections have
provided the bases of the NRC staff's findings that the licensee has
complied with the applicable regulatory requirements. Given that no
violations or previously unidentified regulatory issues have been
raised by the Petitioner, the NRC staff sees no reason to undertake
additional reviews of the maintenance, unloading, and decommissioning
processes and procedures or to initiate public hearings.
Regarding the Petitioner's request for an opportunity to comment on
draft findings after the requested NRC ``investigation,'' the request
is rendered moot by the NRC staff's determination that additional
reviews or ``investigations'' are unnecessary. In addition, the NRC
staff does not, as a matter of general policy, release draft or
[[Page 8710]]
predecisional information to its licensees or to the public for review
and comment.
Item 11. Order Modification of the Licensee's ISFSI Technical
Specifications
The Petitioner requests that the NRC issue an order to modify the
TS for the Prairie Island ISFSI to ensure a demonstrated ability to, in
fact, safely maintain, unload, and decommission TN-40 casks.
Although the TS for the Prairie Island ISFSI require that TN-40
casks be unloaded if certain events or conditions defined in the TS are
satisfied, the TS do not include specific requirements for the
unloading process. Likewise the TS do not detail maintenance or
decommissioning procedures or processes. The content of the TS for the
Prairie Island ISFSI is typical in this respect since neither 10 CFR
72.44 nor the associated regulatory guidance documents specify that
technical specifications should include special requirements for these
procedures.5 Instead, the functional and operating limits,
limiting conditions, administrative controls, and other requirements
included in the TS for the Prairie Island ISFSI are intended to
maintain the cask and stored spent fuel assemblies within the limits
established for safe operation during storage within the ISFSI and
activities such as loading and unloading of the casks. For example, TS
2.3 limits the allowable lifting heights during movement of the cask
from the ISFSI and TS 3/4.2 requires a measurement of the boron
concentration of the water in the spent fuel pool before water is
introduced to the cask during the unloading process.
---------------------------------------------------------------------------
\5\ Recent NRC staff guidance pertaining to the appropriate
content of technical specifications is provided in NUREG-1536,
``Standard Review Plan for Dry Cask Storage Systems,'' published in
January 1997. Similar guidance is provided by NRC Regulatory Guide
3.61, ``Standard Format and Content for a Topical Safety Analysis
Report for a Spent Fuel Dry Storage Cask,'' issued in February 1989,
and NRC Regulatory Guide 3.48, ``Standard Format and Content for the
Safety Analysis Report for an Independent Spent Fuel Storage
Installation (Dry Storage),'' issued in October 1981.
---------------------------------------------------------------------------
As the staff explained in DD-97-18, the absence of specific
requirements in the TS to control the unloading process does not
diminish the importance that the NRC staff places on this activity.
Likewise, specific requirements for performing routine maintenance
activities and possible activities during decommissioning, although
important, are not prescribed in the TS. The TS do, however, contain
requirements for monitoring the integrity of the metallic seals and
actions to be taken in the event that the pressure-monitoring system
indicates a potential loss of the inert atmosphere within the cask. The
NRC staff believes that other regulatory requirements offer an
equivalent level of protection to the Petitioner's request to include
specific requirements in the TS to control the maintenance and
unloading of TN-40 casks and the eventual decommissioning of the ISFSI.
The administrative controls in the TS for the Prairie Island ISFSI
require that the associated procedures be prepared, reviewed, and
maintained in accordance with the requirements of the Prairie Island
Nuclear Generating Plant facility operating licenses and associated TS.
In addition, under existing NRC requirements, the licensee must
adequately implement procedures to control loading, maintaining, and
unloading of dry-storage casks (see 10 CFR 72.122, 10 CFR 72.150, and
10 CFR 72.152). For example, as indicated in the NRC inspection
documented in Inspection Report 50-282/95002; 50-306/95002; 72-10/
95002(DRP), and the resulting notice of violation to the licensee,
NRC's requirements in Criterion V of Appendix B to 10 CFR Part 50
already require the incorporation of appropriate steps and precautions
into the original procedure developed to control unloading of a TN-40
cask. Thus, as demonstrated by the example, no changes to the TS or the
SAR are needed to ensure that enforceable requirements for operating
controls and limits are in place to address the unloading of a cask.
Given that the unloading procedure or a similar procedure can be
used during maintenance activities for the repair or replacement of
seals or during the decommissioning of the Prairie Island ISFSI, no
changes to the TS or the SAR are needed to ensure that enforceable
requirements for operating controls and limits are in place to address
the unloading of the cask for these specific purposes.
Item 12. If Necessary, Order the Licensee to Build a Facility for Dry
Transfer of Spent Fuel Assemblies
The Petitioner requests that the NRC review the licensee's
processes and procedures for maintenance, unloading, and
decommissioning, and if the licensee does not possess a capability to
unload casks, order the licensee to build a ``hot shop'' for air
unloading of casks and transfer of the fuel. Given that the staff has
performed the level of reviews and inspections it feels are warranted
and has found that the licensee could safely unload a TN-40 cask using
the spent fuel pool, it is not necessary to order the licensee to build
a facility to support the transfer of fuel assemblies under dry
conditions.6
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\6\ However, as noted in response to Item 5, the licensee may
elect to transfer fuel assemblies under dry conditions if a dry-
transfer system is developed and receives appropriate NRC approval.
---------------------------------------------------------------------------
IV. Conclusion
For the reasons described above, the NRC has determined that no
adequate basis exists for granting the Petitioner's request for
suspension of Northern States Power Company's license for dry-cask
storage of spent nuclear fuel at Prairie Island or for taking the other
actions requested by the Petitioner.
A copy of this decision will be filed with the Secretary of the
Commission for the Commission to review in accordance with 10 CFR
2.206(c).
As provided by this regulation, this decision will constitute the
final action of the Commission 25 days after issuance, unless the
Commission, on its own motion, institutes a review of the decision
within that time.
Dated at Rockville, Maryland, this 11th day of February 1998.
For the Nuclear Regulatory Commission.
Samuel J. Collins,
Director.
[FR Doc. 98-4324 Filed 2-19-98; 8:45 am]
BILLING CODE 7690-01-P
