ML16307A316
| ML16307A316 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Clinton, Quad Cities |
| Issue date: | 11/28/2016 |
| From: | John Lamb Plant Licensing Branch IV |
| To: | Exelon Generation Co |
| Lamb J, NRR/DORL/LPLIV-2, 415-3100 | |
| References | |
| CAC MF8511, CAC MF8512, CAC MF8513, CAC MF8514 | |
| Download: ML16307A316 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 28, 201 6 LICENSEE: Exelon Generation Company, LLC FACILITY: Clinton Power Station, Unit No. 1; Quad Cities Nuclear Power Station, Units 1 and 2; and Oyster Creek Nuclear Generating Station
SUBJECT:
SUMMARY
OF NOVEMBER 14, 2016, PUBLIC MEETING WITH EXELON GENERAION COMPANY, LLC TO DISCUSS PRE-SUBMITTAL LICENSE AMENDMENT REQUESTS AND/OR EXEMPTIONS TO 10 CFR PART 37 FOR DECOMMISSIONING PLANS FOR CLINTON POWER STATION, UNIT NO. 1; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; AND OYSTER CREEK NUCLEAR GENERATING STATION (CAC NOS. MF8511, MF8512, MF8513, AND MF8514)
On November 14, 2016, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC (Exelon or the licensee), at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to afford Exelon, the licensee for Clinton Power Station, Unit No. 1 (Clinton); Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities); and Oyster Creek Nuclear Generating Station (Oyster Creek), an opportunity to discuss pending license amendment requests and/or exemptions to Title 10 of the Code of Federal Regulations (10 CFR) Part 37, "Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material," associated with the future decommissioning plans. The meeting notice and agenda, dated October 26, 2016, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML16302A047. A list of attendees is enclosed.
On June 20, 2016, the licensee submitted letters to the NRC certifying the permanent cessation of operations for Clinton by June 1, 2017, and for Quad Cities, by June 1, 2018 (ADAMS Accession Nos. ML16172A137 and ML16172A151, respectively). By letter dated January 7, 2011, the licensee certified its contingent determination to permanently cease operations at Oyster Creek no later than December 31, 2019 (ADAMS Accession No. ML110070507).
No regulatory decisions were made at this meeting. No legal interpretations were made at this meeting by the NRC staff regarding the regulations in accordance with 10 CFR 37.9, "Interpretations," and 10 CFR 73.3, "Interpretations." Section 37.9 and Section 73.3 of 10 CFR state: "Except as specifically authorized by the Commission in writing, no interpretations of the meaning of the regulations in this part by any officer or employee of the Commission other than a written interpretation by the General Counsel will be recognized as binding upon the Commission."
After opening remarks, the NRC staff gave a high level overview of 10 CFR Part 37 and 10 CFR Part 73, "Physical Protection of Plants and Materials." Detailed information regarding the regulations can be found on the NRC public webpage.
Part 37 of 10 CFR has been established to provide the requirements for the physical protection program for any licensee that possesses an aggregated Category 1 or Category 2 quantity of radioactive material listed in Appendix A to 10 CFR Part 37. These requirements provide reasonable assurance of the security of Category 1 or Category 2 quantities of radioactive material by protecting these materials from theft or diversion. Specific requirements for access to material, use of material, transfer of material, and transport of material are included in 10 CFR Part 37. No provision of 10 CFR Part 37 authorizes possession of licensed material.
Part 73 of 10 CFR prescribes requirements for the establishment and maintenance of a physical protection system, which will have capabilities for the protection of special nuclear material at fixed sites and in transit and of plants in which special nuclear material is used.
The licensee presented slides titled, "Part 37 Applicability to Reactor Vessels and Associated Structures, Systems, and Components while in SAFSTOR Awaiting Active Decommissioning Activities," which is available in ADAMS at Accession No. ML16314E481.
SAFSTOR is a method of decommissioning in which a nuclear facility is placed and maintained in a condition that allows the facility to be safely stored and subsequently decontaminated (deferred decontamination) to levels that permit release for unrestricted use.
Exelon discussed that its objective was to shut down Clinton in June 2017, Quad Cities in June 2018, and Oyster Creek in December 2019. Subsequently, the reactors would be defueled and the fuel would be stored in the spent fuel pool (SFP). After 5 years of wet storage in the SFP, Exelon plans to move all the fuel to the independent spent fuel storage installation (ISFSI), and to then minimize the 10 CFR Part 73 security footprint to only the ISFSI.
Exelon plans on maintaining control rod blades, fuel support pieces, and possibly other non-special nuclear material (SNM) reactor components within the closed reactor vessel (RV) at sites in SAFSTOR awaiting decommissioning activities. Exelon said closed means the RV head is in place and no open pathways exist to enter the RV.
Exelon said delaying the removal of these components provides greater safety during its eventual removal and transport as waste material, due to the decreased activity level due to natural decay of the radioactive materials.
Exelon stated that the RV walls are nominally 8 inches thick, and the RV vessel heads typically weigh in excess of 100 tons. Exelon said access to the activated materials would require either head removal or through wall breaching.
Exelon plans to store 12 control rod blades, fuel support pieces and other non-SNMs in the RV, to re-install the RV head and close the drywell by re-installing the drywell steel containment vessel. Exelon expressed its intention was then to provide normal industrial security measures around the facilities and to put the facility into SAFSTOR.
By memorandum dated March 13, 2014 (ADAMS Accession No. ML14056A151), the NRC staff issued Enforcement Guidance Memorandum (EGM) 2014-001, "Interim Guidance for Dispositioning 10 CFR Part 37 Violations with Respect to Large Components or Robust Structures Containing Category 1 or Category 2 Quantities of Material at Power Reactor Facitlities Licensed under 10 CFR Parts 50 and 52 (RIN 3150-Al12)."
According to 10 CFR 37.5, "Definitions," the following are the definitions of Category 1 and Category 2 quanitity of radioactive material:
Category 1 quantity of radioactive material means a quantity of radioactive material meeting or exceeding the category 1 threshold in Table 1 of Appendix A to this part. This is determined by calculating the ratio of the total activity of each radionuclide to the category 1 threshold for that radionuclide and adding the ratios together. If the sum is equal to or exceeds 1, the quantity would be considered a category 1 quantity. Category 1 quantities of radioactive material do not include the radioactive material contained in any fuel assembly, subassembly, fuel rod, or fuel pellet.
Category 2 quantity of radioactive material means a quantity of radioactive material meeting or exceeding the category 2 threshold but less than the category 1 threshold in Table 1 of Appendix A to this part. This is determined by calculating the ratio of the total activity of each radionuclide to the category 2 threshold for that radionuclide and adding the ratios together. If the sum is equal to or exceeds 1, the quantity would be considered a category 2 quantity.
Category 2 quantities of radioactive material do not include the radioactive material contained in any fuel assembly, subassembly, fuel rod, or fuel pellet.
Exelon discussed its understanding that in the third round of 10 CFR Part 37 Questions and Answers, from a memorandum dated August 26, 2015 (ADAMS Accession No. ML15237A129),
Answer No. 6 exempted RVs and associated components from Part 37 requirements. The NRC staff clarified that this was in the context of the Question No. 6 (i.e., that this applied while the facility was under a Part 73 security program).
The NRC staff asked the following questions:
- Would Exelon be maintaining a 10 CFR Part 73 security plan to include the reactor building?
- Would Exelon be moving waste materials from the SFP or elsewhere and placing them into the reactor?
- Would Exelon be applying for a complete exemption from 10 CFR Part 37 or an exemption under 10 CFR 37.11(c)?
- Would Exelon be requesting enforcement discretion under the EGM 14-01?
- Would Exelon be evaluating and storing other Category 1 and 2 materials in the reactor building and turbine buildings (e.g., pumps, pipes, valves)?
After 5 years of wet storage in the SFP, Exelon plans to move all the fuel to the ISFSI, and to then minimize the 10 CFR Part 73 security footprint to only the ISFSI. Exelon plans to store 12 control rod blades, fuel support pieces and other non-SNM in the RV, and re-install the RV head. Exelon has not decided yet if it will submit an exemption for all of 10 CFR Part 37 or just portions of Part 37. Exelon said that they most likely will submit an exemption that would mirror EGM 14-01. Exelon has not decided yet where they will store Category 1 and 2 materials, but Exelon will evaluate if those materials should be stored in the reactor building or the ISFSI; regardless of location, Exelon will ensure that the material meet the appropriate security plan or request an exemption.
Exelon stressed that the inherent security, provided by the RV and drywell, would not require additional security measures to protect the Category 1 and 2 materials.
Exelon requested clarification of the "immediate detection" requirement.
Exelon questioned whether an exemption had ever been completed for protection of Category 1 and 2 materials. The NRC staff discussed the exemption granted for the Zion Nuclear Power Station, Units 1 and 2 decommissioning activities (ADAMS Accession No. ML15119A099).
Exelon requested an update on the Nuclear Energy Institute petition for rulemaking and the expected timeframes. The NRC staff stated that the petition for rulemaking had been received and approved for rulemaking by the Commission, and the rulemaking plan with general concepts and timelines will be sent to the Commission for approval.
To facilitate a timely review of a possible exemption, the NRC staff emphasized the need for frequent communication of schedule plans, submitting high quality applications, and timely responses to requests for additional information.
Five members of the public and external stakeholders were in attendance by phone and one member of the public in person.
The State of New Jersey was offered an opportunity to comment, but had no comment. The meeting was opened to members of the public for comment. Ms. Ruth Thomas expressed her concern about shutting down reactors, about low level radioactive waste, and concerns about the nuclear industry having accidents.
No Public Meeting Feedback forms were received.
Please direct any inquiries to me at 301-415-3100, or by email at John.Lamb@nrc.gov.
Jo n . Lamb, Senior Project Manager Pl n Licensing Branch IV-2 Di i ion of Operating Reactor Licensing 0 ce of Nuclear Reactor Regulation Docket Nos.: 50-461, 50-254, 50-265 and 50-219
Enclosure:
List of Attendees cc w/encl: Distribution via Listserv
LIST OF ATTENDEES NOVEMBER 14. 2016. MEETING WITH EXELON GENERATION COMPANY. LLC POTENTIAL DECOMMISSIONING LICENSE AMENDMENT REQUESTS AND/OR EXEMPTIONS RELATED TO 10 CFR PART 37 FOR CLINTON POWER STATION. UNIT NO. 1 QUAD CITIES NUCLEAR POWER STATION. UNITS 1 AND 2 AND OYSTER CREEK NUCLEAR GENERATING STATION Name Afffiliation U.S. Nuclear Regulatory Commission (NRC)/Office of Nuclear Douglas Broaddus Reactor Requlation (NRR)
John Lamb NRC/NRR Steve Garry NRC/NRR Undine Shoop NRC/NRR Vince Williams NRC/Office of Nuclear Security and Incident Response (NSIR)
Garry Purdy NRC/NSIR Duane White NRC/NSIR Zahira Cruz NRC/Office of Nuclear Material Safety and Safequards (NMSS)
Adelaide Giantelli NRC/NMSS John Hickman NRC/NMSS Sabrina Atack NRC/NMSS Ted Smith* NRC/NMSS Neil Sheehan* NRC/Reqion I Mike Gallaqher Exelon Generation Company, LLC (Exelon)
Chris Wilson Exelon Paul Bonnett Exelon Dennis Bakalar Exelon Ray Landis Exelon Tim Keenan* Exelon Joe Dwyer* Exelon Matt Morrison* Exelon Mike Peterson* Exelon Richard Grooo* Exelon Leslie Holden* Exelon Ellen Anderson Nuclear Enerav Institute Veena Gubbi* State of New Jersey Mark Van Sicklen* Duke Enerav Florida Coley Chappel* Entergy Nuclear Operations, Inc. (Enterqy)
Phil Couture* Enterqy Ruth Thomas* Public Marv Lewis* Public
- via telephone Enclosure
Meeting Notice: ML16302A047 Meeting Summary: ML16307A316 Han d ou t s: ML16314E481 *C oncurrence b1v ema1*1 OFFICE NRR/DORL/LPL4-2PM NRR/DORL/LPL3-2/PM NRR/DORL/LPL4-2/LA NRR/DORL/LPL3-2/BC NAME Jlamb EBrown PBlechman GEMiller DATE 11/14/16 11/15/16 11/21/16 11/15/16 OFFICE NRR/DORL/LPL4-2/BC NRR/DORL/LPL4-2PM NAME DBroaddus (JKim for) Jlamb DATE 11/21/16 11/28/16