BVY 14-069, Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 2

Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 2

ML14297A159
Person / Time
Site:	Vermont Yankee
Issue date:	10/21/2014
From:	Wamser C Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 14-069, TAC MF3614
Download: ML14297A159 (7)

Text

I Entergy Nuclear Operations, Inc.

Vermont Yankee 320 Governor Hunt Rd.

vEntergy Vernon, VT 802-257-7711 Christopher J. Wamser Site Vice President BVY 14-069 10 CFR 50.12 10 CFR 50.47 10 CFR 50, Appendix E October 21, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E - Supplement 2 (TAC No. MF3614)

Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28

REFERENCES:

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Notification of Permanent Cessation of Power Operations," BVY 13-079, dated September 23, 2013 (ML13273A204)

2. Letter, Entergy Nuclear Operations, Inc. to USNRC, "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," BVY 14-009, dated March 14, 2014 (ML14080A141)

(TAC No. MF3614)

3. Email, NRC to Entergy Nuclear Operations, Inc. "Vermont Yankee

- RAI Regarding Request for Exemption to Specific Emergency Planning Requirements (MF3614)," dated October 8, 2014

Dear Sir or Madam:

On September 23, 2013, Entergy Nuclear Operations, Inc. (ENO) informed the NRC that Vermont Yankee Nuclear Power Station (VY) will permanently cease operations in the fourth quarter of 2014 (Reference 1). Once VY permanently ceases operations and dockets the certifications required by 10 CR 50.82(a)(1)(i) and (ii), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for VY will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel.

By letter dated March 14, 2014, ENO requested exemptions from portions of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50) for the VY Radiological Emergency Response Plan (Reference 2). Specifically, ENO requested exemption from certain emergency plan requirements of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and Section IVto Appendix E of 10 CFR

50. The requested exemptions would allow ENO to reduce emergency plan requirements and subsequently revise the VY Radiological Emergency Response Plan consistent with the permanently defueled condition of the reactor.

BVY 14-069 / Page 2 of 2 In Reference 3, the NRC provided ENO with a request for additional information (RAI). The RAI questions and associated ENO response are provided in Attachment 1 to this letter.

The analyses and conclusions provided in Reference 1 are not affected by, and remain applicable to, this supplement.

This letter contains no new regulatory commitments.

Should you have any questions concerning this letter or require additional information, please contact Mr. Philip Couture at 802-451-3193.

Sincerely, CJW/plc Attachments: 1. Response to Request for Additional Information cc: Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Mr. James S. Kim, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 08D15 Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. Christopher Recchia, Commissioner Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601

BVY 14-069 Docket 50-271 Attachment 1 Vermont Yankee Nuclear Power Station Response to Request for Additional Information

BVY 14-069 / Attachment 1 / Page 1 of 4 REQUEST FOR ADDITIONAL INFORMATION VERMONT YANKEE NUCLEAR POWER STATION REGARDING REQUEST FOR EXEMPTION FROM VARIOUS EMERGENCY PLANNING REQUIREMENTS (TAC NO. MF3614)

Background

By application, dated March 14, 2014 (Agencywide Documents Access and Management System Accession Number ML14080A141), Entergy Nuclear Operations, Inc. (the licensee) requested exemptions that would allow the licensee to reduce emergency planning requirements and subsequently revise the Vermont Yankee Nuclear Power Station Emergency Plan to reflect the permanently defueled condition of the station. The Nuclear Regulatory Commission (NRC) staff have reviewed the information in the exemption request and determined additional information is required to complete its review.

ARCB-RAI-1 ,Section IV.C.b, entitled, "Radioactive Waste Handling Accident," analyzed the consequences of a radioactive waste handling accident. The purpose of this analysis is to calculate the two hour integrated dose in the direction of the closest site boundary (250 meters away) from dropping a high integrity container (HIC). The accident evaluated the largest liner containing the highest concentration of radioactive materials (dewatered resin containing 19,415 curies of 25 various radionuclides representing the highest '

activity waste at the facility). The licensee concluded, "The resulting two hour integrated dose at the Site Boundary is projected to be 16.1 millirem TEDE, which is below the EAB limit of 1 rem TEDE."

Therefore, the U.S. Nuclear Regulatory Commission (NRC) staff needs additional information on the 19,415 curies of each of the 25 various radionuclides representing the highest activity waste at the facility to confirm this result at the Site Boundary. Please provide the activity, in units of Curies, of each radionuclide of the HIC representing the highest activity waste at the facility.

Response

The analysis assumed the liner contains all radionuclides found in plant radwaste, each of which is at the Department of Transportation (DOT) limit for low specific activity (LSA) material (except 1-129, which is at the 10 CFR 61 limit for disposal). Approximately 26 radionuclides are expected to be present in the waste (this represents a correction to the 25 stated in the application). It is assumed that the liner contains 150 ft3 of this waste which results in approximately 1000 curies of each, of about 19 radionuclides and a lesser amount for the remaining 7 radionuclides. These radionuclides and their total activity are listed below.

BVY 14-069/ Attachment 1 / Page 2 of 4 Nuclide 1 Total Activity (Ci)2 Cr-51 1020 Mn-54 1020 Fe-55 1020 Co-58 1020 Co-60 1020 Fe-59 1020 Ni-59 1020 Ni-63 1020 Sb-124 1020 Zn-65 1020 Ag-110m 1020 Sr-89 1020 Sr-90 17 Zr-95 1020 Nb-95 1020 Tc-99 1020 I-1297 0.34 Cs-134 1020 Cs-137 1020 Ce-141 1020 Ce-144 1020 Pu-238 0.34 Pu-239/240 0.34 Am-241 0.34 Cm-242 17 Cm-243/244 0.34 Total 19,415.7 Table Footnotes:

1. Radionuclides that typically are determined by laboratory analysis to be present in reactor cleanup resin waste. Short lived gaseous, and volatile radionuclides are not detected in typical radwaste streams.

2. Because concentration and distribution of radionuclides in waste are expected to vary over time, it is assumed for purposes of radiological accident analysis that all radionuclides are at their upper limit. In reality, a small number of radionuclides may be expected to approach a limiting condition while the majority would be at some lower level. Cask shielding considerations would be expected to limit gamma emitters. The total activity is based on: a) 150 ft3 liner of waste with a density of 50 lb/ft3, or 3.41 E06 gm; b) Each nuclide at LSA limit (mCi/gm).

3. 1-129 is limited by 10 CFR 61 burial requirements rather than DOT. The class C disposal limit for 1-129, as listed in 10 CFR 61.55, Table 1, is 0.08 Ci/m 3 .

BVY 14-069 / Attachment 1 / Page 3 of 4 ARCB-RAI-2 The dose criteria specified in Title 10 of the Code of Federal Regulations, Section 50.67 (10 CFR 50.67) is in terms of total effective dose equivalent (TEDE). As such, confirmatory calculations are performed in terms of TEDE to compare against the dose acceptance criteria specified in NUREG-0800, Section 15.0.1. This analysis differs from the Environmental Protection Agency (EPA) Protective Action Guide [PAG] and Planning Guidance for Radiological Incidents (a.k.a the EPA PAG Manual) recommendation for a projected whole body dose of I to 5 rem total effective dose (TED) over four days. The TEDE is defined as the sum of the effective dose equivalent for external exposures and the committed effective dose equivalent for internal exposures. The projected whole body dose calculation for TED is defined as the sum of the effective dose from external radiation exposure (i.e., groundshine and cloudshine) and the committed effective dose from inhaled radioactive material. Dose conversion factors (DCF) applied in both analyses convert the estimated environmental exposure to dose in the units of concern.

Dose conversion factors acceptable to the NRC staff are derived from data provided in International Commission on Radiological Protection Publication 30, "Limits for Intakes of Radionuclides by Workers" and can be found in Federal Guidance Report 11, "Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion," and Federal Guidance Report No. 12, "External Exposure to Radionuclides in Air, Water, and Soil," for exposure to radionuclides in air, water, and soil."

While both TEDE and TED calculate dose for external and internal exposure, the underlying dosimetry models used to develop the DCFs are not the same. Specifically, the TED DCF (FRG 13) for the thyroid is higher than the TEDE DCF (FRG11 and 12);

resulting in a larger contribution to the total dose. One primary difference between the TED and TEDE thyroid DCF is due to a higher tissue weighting factor specified in ICRP 60 being assigned to the thyroid. Please provide a summary explaining why the use of the EPA PAG dose criteria TED is acceptable in addition to the dose criteria specified in 10 CFR 50.67 which is calculated in terms of TEDE.

Response

Federal Guidance Reports 11 and 12 were used to calculate the TEDE in the supporting fuel handling accident (FHA)-based analysis provided as Attachment 4 to Reference 1. Dose calculations for implementing the PAGs (Reference 2) are made using the DCFs referenced in the Federal Radiological Monitoring and Assessment Center (FRMAC) Assessment Manuals.

The draft EPA PAG manual also states that other calculation methods to implement PAGs may be appropriate.

The table below provides a comparison of the DCFs between the Federal Guidance Reports 11 and 12 (as used in the FHA analyses) vs. the FRMAC values recommended in the draft EPA PAG manual. It is clear that the Federal Guidance Report values are mostly bounding, the exceptions being with the short-lived radionuclides (1-132, 1-134 and 1-135) in comparison to the primary dose contributors (1-131 and 1-133). These short-lived radionuclides will have decayed to negligible levels within a few days after shutdown. Therefore, calculation of the number of days after shutdown for the dose at the exclusion area boundary to fall below the EPA PAG limit using the DCFs specified in Federal Guidance Reports 11 and 12 results in a more conservative result than using the FRMAC DCF values.

BVY 14-069 / Attachment 1 / Page 4 of 4 It is also noted that the FRMAC manuals do not have any DCFs for the noble gases, although these are not significant dose contributors for the FHA.

Submersion Dose FRMAC (Appendix C, Table 1) FGR-12 Ratio mrem-m 3/pCi-hr rem-m 3/Ci-hr Sv-m3/Bq-sec rem-m 3/Ci-hr FGR-12/FRMAC 1-129 3.80E-03 3.80E+00 3.80E-16 5.06E+00 1.33 1-131 2.30E-01 2.30E+02 1.82E-14 2.42E+02 1.05 1-132 1.40E+00 1.40E+03 1.12E-13 1.49E+03 1.07 1-133 3.70E-01 3.70E+02 2.94E-14 3.92E+02 1.06 1-134 1.60E+00 1.60E+03 1.30E-1 3 1.73E+03 1.08 1-135 1.10E+00 1.1OE+03 7.98E-14 1.06E+03 0.97 Inhalation Dose Radionuclide FRMAC (Appendix C, Table 1) FGR-11 Ratio mrem/pCi rem/Cl Sv/Bq rem/Cl FGR-11/FRMAC 1-129 1.30E+02 1.30E+05 4.69E-08 1.74E+05 1.33 1-131 2.70E+01 2.70E+04 8,89E-09 3.29E+04 1.22 1-132 4.20E-01 4.20E+02 1.03E-10 3.81 E+02 0.91 1-133 5.40E+00 5.40E+03 1.58E-09 5.85E+03 1.08 1-134 2.1OE-01 2.1OE+02 3.55E-11 1.31 E+02 0.63 1-135 1.20E+00 1,20E+03 3.32E-10 1.23E+03 1.02 References

1. Letter, Entergy Nuclear Operations, Inc. to USNRC, 'Technical Specifications Proposed Change No. 306 Eliminate Certain ESF Requirements during Movement of Irradiated Fuel," BVY 13-097, dated November 14, 2013 (TAC No.

MF3068) (ML13323A516)

2. Environmental Protection Agency Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment, dated March 2013

3. U.S. Department of Energy "Federal Radiological Monitoring and Assessment Center (FRMAC) Assessment Manual, Volume 1: Overview and Methods,"

SAND2010-1405P, Federal Radiological Monitoring and Assessment Center, U.S. Department of Energy, Washington, D.C., December 2010