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Category:Letter
MONTHYEARML23342A0972024-01-0909 January 2024 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan CY-23-014, Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI2023-12-0404 December 2023 Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI ML23124A2012023-04-20020 April 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2022 CY-23-006, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2023-03-0606 March 2023 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-23-007, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2023-03-0606 March 2023 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste ML22340A4922023-02-24024 February 2023 Closeout Letter to Connecticut Yankee Regarding 2018 and 2021 Updated DFPs for Haddam Neck Plant ISFSI CY-23-003, Independent Spent Fuel Storage Installation, Nuclear Liability Insurance Coverage2023-01-17017 January 2023 Independent Spent Fuel Storage Installation, Nuclear Liability Insurance Coverage CY-23-004, Independent Spent Fuel Storage Installation, Property Insurance Coverage2023-01-17017 January 2023 Independent Spent Fuel Storage Installation, Property Insurance Coverage CY-23-001, Independent Spent Fuel Storage Installation, Report of 10 CFR 50.59 Changes, Tests, and Experiments2023-01-0505 January 2023 Independent Spent Fuel Storage Installation, Report of 10 CFR 50.59 Changes, Tests, and Experiments CY-23-002, Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments2023-01-0505 January 2023 Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments IR 07200039/20224012022-10-0505 October 2022 Connecticut Yankee Atomic Power Company - NRC Independent Spent Fuel Storage Security Inspection Report No. 07200039/2022401 CY-22-012, Independent Spent Fuel Storage Installation, Supplemental Information for the Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2022-08-0303 August 2022 Independent Spent Fuel Storage Installation, Supplemental Information for the Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan CY-22-010, Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation, Formal Announcement of New ISFSI Manager2022-05-25025 May 2022 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation, Formal Announcement of New ISFSI Manager CY-22-006, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 20212022-04-25025 April 2022 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2021 CY-22-003, and Independent Spent Fuel Storage Installation, Decommissioning Funding Assurance Status Report2022-03-14014 March 2022 and Independent Spent Fuel Storage Installation, Decommissioning Funding Assurance Status Report CY-22-004, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2022-03-14014 March 2022 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste ML22011A1352022-01-31031 January 2022 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan CY-22-002, Independent Spent Fuel Storage Installation - Property Insurance Coverage2022-01-20020 January 2022 Independent Spent Fuel Storage Installation - Property Insurance Coverage CY-22-001, Independent Spent Fuel Storage Installation - Nuclear Liability Insurance Coverage2022-01-20020 January 2022 Independent Spent Fuel Storage Installation - Nuclear Liability Insurance Coverage CY-21-015, Independent Spent Fuel Storage Installation, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2021-12-10010 December 2021 Independent Spent Fuel Storage Installation, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan CY-21-011, Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI2021-12-0101 December 2021 Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI CY-21-013, Biennial Update to the Haddam Neck Plant License Termination Plan2021-12-0101 December 2021 Biennial Update to the Haddam Neck Plant License Termination Plan ML22075A2382021-12-0101 December 2021 Biennial Update to the Haddam Neck Plant Updated Final Safety Analysis Report CY-21-014, Independent Spent Fuel Storage Installation - Adoption of Amendment 8 of NAC-MPC Certificate of Compliance No. 72-1025 and Canister Registration2021-11-18018 November 2021 Independent Spent Fuel Storage Installation - Adoption of Amendment 8 of NAC-MPC Certificate of Compliance No. 72-1025 and Canister Registration IR 05000213/20210012021-10-26026 October 2021 Connecticut Yankee Atomic Power Company - NRC Independent Spent Fuel Storage Installation Inspection Report Nos. 07200039/2021001 and 05000213/2021001 ML21144A2512021-04-13013 April 2021 Independent Spent Fuel Storage Installation - Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2020 CY-21-006, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2021-03-0202 March 2021 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-21-005, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2021-03-0202 March 2021 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-21-003, Independent Spent Fuel Storage Installation Nuclear Liability Insurance Coverage2021-01-27027 January 2021 Independent Spent Fuel Storage Installation Nuclear Liability Insurance Coverage CY-21-004, Independent Spent Fuel Storage Installation - Property Insurance Coverage2021-01-27027 January 2021 Independent Spent Fuel Storage Installation - Property Insurance Coverage ML21012A3192021-01-13013 January 2021 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan IR 07200039/20204012020-11-20020 November 2020 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Report 07200039/2020401, Without Enclosure (Public - Cover Letter Only) ML20150A3352020-06-19019 June 2020 COVID-19 Exemption for Haddam Neck CY-20-011, Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement2020-05-14014 May 2020 Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement ML20143A0972020-04-16016 April 2020 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2019 CY-20-007, Independent Spent Fuel Storage Installation - Formal Announcement of New Tsfst Manager2020-03-31031 March 2020 Independent Spent Fuel Storage Installation - Formal Announcement of New Tsfst Manager CY-20-004, Independent Spent Fuel Storage Installation - Funding Report for Managing Irradiated Fuel and GTCC Waste2020-03-17017 March 2020 Independent Spent Fuel Storage Installation - Funding Report for Managing Irradiated Fuel and GTCC Waste CY-20-003, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2020-03-12012 March 2020 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-20-002, Independent Spent Fuel Storage Installation, Letter Notifying NRC the Amount of Property Insurance Coverage in Force for 20202020-01-22022 January 2020 Independent Spent Fuel Storage Installation, Letter Notifying NRC the Amount of Property Insurance Coverage in Force for 2020 ML20015A5262020-01-15015 January 2020 Connecticut Yankee Atomic Power Company - Independent Spent Fuel Storage Installation Security Inspection Plan ML19269C4642019-10-11011 October 2019 Letter to B. Mitchell Exemption from 10 CFR 72.212 and 72.214 for Dry Spent Fuel Storage Activities - Haddam Neck Plant Independent Spent Fuel Storage Installation CY-19-014, Independent Spent Fuel Storage Installation - Formal Announcement of ISFSI Manager'S Return2019-06-0505 June 2019 Independent Spent Fuel Storage Installation - Formal Announcement of ISFSI Manager'S Return CY-19-012, Independent Spent Fuel Storage Installation - 2018 Individual Monitoring NRC Form 5 Report2019-04-23023 April 2019 Independent Spent Fuel Storage Installation - 2018 Individual Monitoring NRC Form 5 Report ML19070A0332019-02-20020 February 2019 Letter to C. Pizzella Nuclear Regulatory Commission'S Analysis of Connecticut Yankee Atomic Power Company'S Initial and Updated Decommissioning Funding Plans for the Haddam Neck Plant Independent Spent Fuel Storage Installation CY-18-021, Connecticut Yankee Atomic Power Company Haddam Neck Plant Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2018-12-10010 December 2018 Connecticut Yankee Atomic Power Company Haddam Neck Plant Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan IR 05000213/20180012018-05-31031 May 2018 NRC Independent Spent Fuel Storage Installation Inspection Report Nos. 07200039/2018001 and 05000213/2018001, Connecticut Yankee Atomic Power Company, East Hampton, Connecticut Site IR 07200039/20184012018-05-17017 May 2018 Connecticut Yankee Atomic Power Company Independent Spent Fuel Storage Security Inspection Report No. 07200039/2018401 - (Cover Letter Only) CY-18-004, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2018-03-0505 March 2018 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-18-005, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2018-03-0505 March 2018 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-17-021, Independent Spent Fuel Storage Installation Formal Announcement of Change in HNP ISFSI Manager2017-09-0505 September 2017 Independent Spent Fuel Storage Installation Formal Announcement of Change in HNP ISFSI Manager 2024-01-09
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4CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT i362 INJUN HOLLOW ROAD
- EAST HAMPTON, CT 06424-3099 October 24, 2011 CY-1 1-038 License No. DPR-61 Docket No. 50-213, 72-39 Re: DG 5033 Comments Mr. Phil Brochman Office of Nuclear Security and Incident Response U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001
Dear Mr. Brochman:
Connecticut Yankee Atomic Power Company appreciates the opportunity to comment on the Draft Regulatory Guide DG 5033, "Security Performance (Adversary)
Characteristics for Physical Security Programs for 10 CFR Part 72 Licensees".
Connecticut Yankee supports a revision to the regulations in 10 CFR Parts 72 and 73 so that the physical security requirements for ISFSIs are based upon the type of facility (and its attendant risk) and not on the type of license held by the facility.Connecticut Yankee is the licensee for the Haddam Neck Plant facility.Connecticut Yankee is an Independent Spent Fuel Storage Installation (ISFSI) at a fully decommissioned power reactor site. The ISFSI is licensed under a 10 CFR Part 50 possession-only license and a general license under 10 CFR 72.210. Connecticut Yankee has serious concerns regarding the scope of the regulatory bases contained in the Draft Regulatory Guide and regarding the dramatic departure from existing guidance as it pertains to a stand-alone ISFSI at a former reactor site.The general comments below on DG 5033 are intended to be non safeguards but to nonetheless clearly reflect Connecticut Yankee's objection to the approach in the DG. DG 5033 states that it is intended to be risk informed.
However, it does not appear that the significant reduction in risk to the public of fuel in dry storage compared to the risks of fuel in wet storage (and from other radiological sources)at operating nuclear plants is adequately reflected in the content of the draft guidance.
General Comments: 1. Similar to other stand-alone ISFSI licensees, Connecticut Yankee utilizes a detect, deter and communicate protective strategy.
The DG would adopt a new protective strategy based on an evaluation of dose consequences of security scenarios.
The basis for this departure has not been adequately explained.
If such a change were warranted by existing "classified threat information", presumably new orders would have been issued for licensees to address the threats. This has not been the case.2. With the introduction of a radiological design basis for ISFSIs, a number of areas of concern result: a. The Final Safety Analysis Reports (FSARs) for dry cask storage systems demonstrate the robust nature of the construction of the storage system. The FSARs conclude that the systems preclude the release of radiological materials.
This is inconsistent with the approach of the draft guidance.b. The highest level of emergency event classification for an ISFSI is an Unusual Event based on the FSAR analysis that a radiological release is not credible.
A radiological event which includes a plume and exposure pathway would dictate escalation to a higher event.This creates an inconsistency in the regulatory basis. Similarly, a number of ISFSIs utilize a design basis for the Emergency Plan that is based on the conclusion that the limits set forth in 10 CFR 100.11 and 10 CFR 72.106(b) cannot be reached at the site area boundary.c. A number of ISFSI licensees have reduced their 10 CFR Part 50 licensed area to a small area encompassing the ISFSI pad and the area immediately surrounding it. With the introduction of a hypothetical radiological release, ISFSI licensees may be required to acquire and re-license property adjacent to the ISFSI, creating practical difficulties and unjustified expense.2. We recognize that Regulatory Guides cannot incorporate requirements from Orders. However, DG-5033 does not address the entire range of requirements that are contained within the ICM's or ACM's previously issued to these facilities.
For example, the number of Local Law Enforcement Agencies (LLEA) responders required and the time intervals for those responses are specifically stated in the ICM's and yet are not addressed in DG-5033. Since DG-5033 only addresses some of the requirements of the ICM's or ACM's, it may lead to confusion.
The requirements in the DG should replace the existing orders and those orders should be rescinded.
- 3. The change from the currently approved design basis threat to a radiological event based approach as proposed in DG-5033 is contrary to a number of NRC Safety Evaluation Reports (SERs) written for stand-alone ISFSIs. For example, as quoted from the SER for Amendment 199 to Connecticut Yankee License (DPR-61) the NRC conclusion states: "Connecticut Yankee has stated that it plans to maintain the boundary of its controlled area to 300 meters from the dry cask storage installation.
Based on the 300 meters, the NRC staffs conclusion is that the DBT of radiological sabotage would result in a dose that would be well below the 10 CFR 72.106(b) limits." 4. The NRC in its design basis threat rule for power plants did not include airborne attacks. Accordingly, the DG raises the issue of whether an airborne attack to the ISFSI is a valid accident/threat scenario.
Cask vendors who license the casks are not currently required to evaluate the scenario in their FSAR. Is an airborne attack part of the adversarial characteristics listed in Reg. Guide 5.69? Didn't the RAMCAP evaluations look at the beyond design basis scenarios for applicability at each site and were these evaluations considered when drafting DG-5033?5. As a general matter, it appears that the NRC's approach of developing draft guidance for preliminary stakeholder comment before the regulation (10 CFR 73.51) has been drafted and/or released for comment is backwards.
Since the requirements are performance-oriented, and necessarily broad, the associated guidance is commonly understood to be an explication of the requirements.
Shouldn't the regulation be in place before guidance documents implementing the regulation are issued?Section 1.1.a 1. Even though DG-5033 discusses in Section 1, "Applicability" the protective strategies of "Detect, assess and communicate" and"denial", it seems that the entire regulatory guide is written to implement a "denial" strategy with no additional consideration given to a "detect, assess and communicate" strategy.Section 2.11: 1. If a site utilizes a protective strategy of "detect, assess and communicate," and those tasks can be accomplished without requiring the alarm station within a Protected Area, even if the vehicle bomb assault was successful, then the requirement for an alarm station to be within a Protected Area would be unnecessary.
Many of the decommissioned stand-alone ISFSI sites such as Connecticut Yankee currently have an exemption that allows the alarm station to be located outside the PA. The basis (in part) for this exemption is the ability to complete the notification requirement to LLEA.2. If a site has contracted remote monitoring services to satisfy the requirement for a secondary monitoring location, are they required to meet the requirements of Section 8, "Insider Assistance," and Section 12, "Cyber Assault"?
Would these same requirements apply to LLEA and their communication systems that would be utilized to dispatch responders to the site?3. The list of personnel, components and functions does not state "and" or "or" and, therefore, the reader cannot tell whether all must be protected, or only subsets must be protected.
As presently worded, it appears that both the CAS and SAS must be protected, which is a protective standard that exceeds the requirements for power reactors.This comment also applies to Sections 3.1, 4.1, 5.1 and 7.1.Implementation:
- 1. DG-5033 states: "A licensee who believes that the NRC staff is inappropriately imposing this Regulatory Guide as part of a request for a license amendment or a request for a change to a previously issued NRC regulatory approval may file a back-fitting appeal with the NRC in accordance with applicable procedures." Isn't the NRC bound by regulation (10 CFR 50.109 -which only applies to Part 50 licensees) to establish a need for back-fit?Conclusion:
- 1. The conclusion states: "This Regulatory Guide is not being imposed on current licensees and may be voluntarily used by existing licensees." This statement is very ambiguous since the whole basis of the Regulatory Guide is to establish a new Design Basis Threat (DBT) for an ISFSI and to define the adversarial characteristics included in the design basis threat. In fact, the enhanced characteristics and capabilities of adversaries described in DG-5033 far exceed those outlined in Regulatory Guide 5.69, establishing a DBT that power reactors are required to defend against.One final comment pertains to any and all proposed changes to the protective strategies for ISFSIs and/or the adversarial characteristics defining a DBT. It is very difficult to comment as a stakeholder without appropriate information.
Many licensee personnel that are being asked for comment on DG-5033 are not cleared for "Classified Information" and are at a disadvantage evaluating the information.
Meetings and seminars are being scheduled to discuss changes to D\.the threat environment and these people cannot attend. Priority should be elevated to establish the process to clear the appropriate licensee personnel.
Connecticut Yankee appreciates this opportunity to provide comments on DG 5033. We believe significant improvements remain necessary to accurately risk inform the guidance, particularly as it may relate to a stand-alone ISFSI (dry storage) at a decommissioned reactor site such as Connecticut Yankee. The fact that the license remains a Part 50 license (authorizing possession only of special nuclear material) should be irrelevant to the scope of physical security requirements that should be applied.Respectfully submitted, ('mes M. Lenois onnecticut Yankee ISFSI Manager Cc: S. Wastler, NRC Document Control Desk J. Hanson, NEI J. Goshen, NRC Project Manager J.Joustra, NRC Region 1
'SPOS.)0~2 IP $001 000186086.OCT 20 4AL2 FRO'F ~Connecticut Yankee Atomic Power Co.362 Injun Hollow Road East Hampton, CT 06424 aftmm A 41%FlRzii MAIL 111 ffm U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 A