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Category:E-Mail
MONTHYEARML22235A7862022-08-23023 August 2022 Acceptance Review: Exemption Request from 10 CFR 20, Appendix G, LLW Shipping Investigation Requirements ML21181A1882021-06-30030 June 2021 E-mail from S. Johnston, Holtec, to A. Snyder and F. Bower, NRC - Oyster Creek Nuclear Generating Station - Readiness Status for ISFSI Only Inspection ML21175A2092021-06-24024 June 2021 E-mail from A. Sterdis to P. Longmire - Oyster Creek Nuclear Generating Station: ISFSI-only Physical Security Plan (Stating Implementation Intent) ML21162A3602021-06-11011 June 2021 E-mail Response from the State of New Jersey Regarding the Pending Revision to the Emergency Plan to Reflect Independent Spent Fuel Storage Installation Only Status ML21162A1172021-06-11011 June 2021 E-mail to HDI: Acceptance Review - FOF Exemption ML21168A0172021-06-10010 June 2021 E-mail from HDI: RAI Response ML21161A2572021-06-0707 June 2021 State Consultation: ISFSI-only Physical Security Plan (Email Response) ML21175A0712021-06-0202 June 2021 Issuance of Request for Additional Information: Oyster Creek Nuclear Generating Station. Request for Amendment to Technical Specifications ML21148A0562021-05-27027 May 2021 E-mail to State of New Jersey Informing of the Pending Revision to the Emergency Plan to Reflect Independent Spent Fuel Storage Installation Only Status ML21132A3182021-05-12012 May 2021 E-Mail from V. Gubbi, DEP to Z. Cruz, NRC - Oyster Creek Nuclear Generating Station - State of New Jersey Response to the Pending Revision to the Defueled Technical Specifications to Reflect Independent Spent Fuel Storage Installation Only ML21132A0312021-05-11011 May 2021 E-mail to State of New Jersey Informing of the Pending Revision to the Physical Security Plan to Reflect Independent Spent Fuel Storage Installation Only Status ML21119A1422021-04-28028 April 2021 E-mail to State of New Jersey Informing of the Pending Revision to the Emergency Plan to Reflect Independent Spent Fuel Storage Installation Only Status ML21113A0742021-04-23023 April 2021 Acceptance Review Email - April 20, 2021 Oyster Creek Request for Exemption from 10 CFR Part 73 Requirements Due to Covid ML21099A0382021-04-0808 April 2021 Email from Z. Cruz to A. Sterdis - Request for Additional Information - HDI Request for Approval of Oyster Creek Nuclear Generating Station Independent Spent Fuel Storage Installation Facility Only Emergency Plan ML21085A4872021-03-26026 March 2021 E-mail from Z. Cruz to A. Sterdis - Acceptance Review: Oyster Creek Nuclear Generating Station - Request for Approval of Independent Spent Fuel Storage Installation Only Permanently Defueled Technical Specifications ML21064A2432021-03-0505 March 2021 Email from Z. Cruz to A. Sterdis Acceptance Review_ Oyster Creek Nuclear Generating Station - Request for Approval of Independent Spent Fuel Storage Installation Facility Only Emergency Plan and Emergency Action Level Scheme ML21064A2392021-03-0202 March 2021 E-mail from Z. Cruz to A. Sterdis Acceptance Review - Oyster Creek Nuclear Generating Station - Request for Approval of Independent Spent Fuel Storage Installation Only Physical Security Plan ML20345A1462020-12-0909 December 2020 E-mail - Response to Request for Additional Information: HDI Request for One-Time Exemption from Part 73, Appendix B FOF Requirements ML20335A3112020-11-30030 November 2020 Request for Additional Information Regarding Request for a one-time Exemption from Part 73, Appendix B Requirements for Oyster Creek Nuclear Generating Station ML20332A1472020-11-24024 November 2020 Acceptance Review: November 20 2020 Exemption Request from 10 CFR Part 73 Appendix B Requirements for Oyster Creek ML20297A2372020-10-22022 October 2020 Request for Additional Information - HDI Fleet Decommissioning Quality Assurance Program ML20279A5082020-10-0505 October 2020 Email to Holtec - Response to Notification of Oyster Creek Onsite Property Insurance Coverage ML20266G4032020-09-22022 September 2020 Acceptance Review Email - Request for Approval of HDI Fleet Decommissioning Quality Assurance Program, Revision 0 ML20134H8742020-05-12012 May 2020 Request for Additional Information Regarding Request for Temporary Exemption from Part 73, Appendix B Requirements ML20133J9182020-05-11011 May 2020 Acceptance Review Email - Oyster Creek Request for Exemption from Part 73 Qualification Requirements ML20120A0252020-04-22022 April 2020 NRR E-mail Capture - (External_Sender) Oyster Creek Sea Turtle Handling and Conservation Recommendation Obligations NRC-2019-0073, Response from NEIMA Local Community Advisory Board Questionnaire 10-30-2019 R Discenza2019-10-30030 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-30-2019 R Discenza ML19344C8022019-10-20020 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-20-2019 a Dressler ML19344C8002019-10-0909 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-09-2019 W Mcmullin ML19344C7982019-10-0909 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-09-2019 M Noto ML19344C7992019-10-0909 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-09-2019 s Feldman ML19344C7932019-10-0909 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-09-2019 C Bischoff ML19344C7962019-10-0909 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-09-2019 G Adams ML19344C7912019-10-0808 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-08-2019 J Branciforte ML19344C7902019-10-0808 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-08-2019 Anonymous ML19344C7892019-10-0505 October 2019 Response from NEIMA Local Community Advisory Board Questionnaire 10-05-2019 P Dressler ML19263D1222019-09-20020 September 2019 for Your Action Request for Additional Information Hdi Oyster Creek PSDAR ML19214A0452019-08-0202 August 2019 NRC to NMFS, Revised Proposed Action for Oyster Creek Endangered Species Act Section 7 Consultation ML19182A3422019-07-0101 July 2019 Transaction ML19178A0702019-06-26026 June 2019 Email to State of New Jersey - Oyster Creek - Request Comments on Proposed Amendment to Remove Reference to the Oyster Creek Cyber Security Plan and Update License Condition 2.C.(4) in the Renewed Facility License ML19196A3422019-06-20020 June 2019 Email: Courtesy Notice on the Issuance of the Oyster Creek License Transfer and Exemption (Sierra Club) ML19196A3342019-06-20020 June 2019 Email: Courtesy Notice on the Issuance of the Oyster Creek License Transfer and Exemption ML19162A2242019-06-11011 June 2019 NRC to NMFS, NRC Responses to NMFS Requests for Additional Information for Oyster Creek ESA Section 7 Consultation NRC-2018-0237, Comment from Paul Dressler of the Concerned Citizens for Lacey Coalition, Regarding the Oyster Creek Nuclear Plant License Transfer Application2019-06-0707 June 2019 Comment from Paul Dressler of the Concerned Citizens for Lacey Coalition, Regarding the Oyster Creek Nuclear Plant License Transfer Application ML19155A1182019-06-0404 June 2019 Incoming E-mail from State of New Jersey on the Oyster Creek Exemption for Reduced Insurances and Use of Decommissioning Trust Fund for Spent Fuel Management and Site Restoration ML19155A1192019-06-0404 June 2019 State of New Jersey Comments - Oyster Creek Conforming Amendment Associated with the Oyster Creek Generating Station License Transfer Application ML19154A0582019-05-31031 May 2019 E-mail Response from State of New Jersey Dated May 31, 2019, Notification-and-Request-Oyster Creek License Transfer Application L-2018-LLM-0002 ML19158A2912019-05-30030 May 2019 NRR E-mail Capture - Oyster Creek ESA Consultation: Information Requests from NMFS ML19158A2772019-05-28028 May 2019 NRR E-mail Capture - Oyster Creek ESA Consultation: Information Requests from NMFS ML19148A4392019-05-24024 May 2019 NMFS to NRC, Requests for Additional Information to Support Oyster Creek Reinitiated Section 7 Consultation 2022-08-23
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML21099A0442021-04-0808 April 2021 Enclosure - Request for Additional Information Related to Request for Approval of Oyster Creek Nuclear Generating Station Independent Spent Fuel Storage Installation Only Emergency Plan Holtec Decommissioning International, LLC ML20335A3102020-11-30030 November 2020 RAI November 2020 Part 73 FOF Exemption Request ML20297A2382020-10-22022 October 2020 Fleet DQAP RAIs - Enclosure ML20297A2372020-10-22022 October 2020 Request for Additional Information - HDI Fleet Decommissioning Quality Assurance Program ML20134H8732020-05-12012 May 2020 E-mail - Request for Additional Information: Oyster Creek Request for Temporary Exemption from Part 73, Appendix B Requirements ML19263D2142019-09-20020 September 2019 Hdi PSDAR Environmental RAI Enclosure (002) ML19158A2772019-05-28028 May 2019 NRR E-mail Capture - Oyster Creek ESA Consultation: Information Requests from NMFS ML19025A1172019-01-24024 January 2019 NRR E-mail Capture - for Your Action - RAI for Oyster Creek EP Exemption (Change to Adiabatic Heat-Up Calculation) ML18256A0022018-09-12012 September 2018 NRR E-mail Capture - for Your Action: RAIs for Oyster Creek Post Shutdown Decommissioning Activities Report (PSDAR) ML18135A0732018-05-15015 May 2018 NRR E-mail Capture - RAIs - Oyster Creek - Request Approval of the Decommissioning Quality Assurance Program ML18068A6582018-03-0909 March 2018 NRR E-mail Capture - RAIs - Oyster Creek Defueled TS LAR ML18067A1482018-03-0808 March 2018 Enclosurequest for Additional Information (Letter to P. R. Simpson Request for Additional Information Regarding Exelon Generating Company, Llc'S Decommissioning Funding Plan Update for Independent Spent Fuel Storage Installation) ML18024B0642018-01-24024 January 2018 NRR E-mail Capture - for Your Action - RAI for Oyster Creek Permanently Defueled EP and EAL Scheme LAR (CAC No. MG0160; EPID: L-2017-LLA-0307) ML18012A0782018-01-12012 January 2018 NRR E-mail Capture - for Your Review - Draft RAI for Oyster Creek Permanently Defueled EP and EAL Scheme LAR (CAC No. MG0160; EPID: L-2017-LLA-0307) ML18003A4122018-01-0303 January 2018 NRR E-mail Capture - for Your Action - RAI - Oyster Creek BWRVIP LAR (CAC No. MG0180; EPID No. L-LLA-2017-0304) ML17320A6372017-11-16016 November 2017 NRR E-mail Capture - Oyster Creek Nuclear Generating Station - Request for Additional Information Regarding License Amendment Request for Emergency Plan Exemption (CAC No. MG0153; EPID L-2017-LLE-0020) ML17319A9422017-11-15015 November 2017 NRR E-mail Capture - Oyster Creek Nuclear Generating Station - Request for Additional Information Regarding License Amendment Request for Emergency Plan Exemption (CAC No. MG0153; EPID L-2017-LLE-0020) ML17208A7472017-09-14014 September 2017 Request for Additional Information, License Amendment Request to Revise the Site Emergency Plan for On-Shift and Emergency Response Organization Staffing for Permanently Defueled Condition ML17136A3852017-05-12012 May 2017 NRR E-mail Capture - (External_Sender) Oyster Creek Response to NRC Flood MSA Audit Review Questions ML17038A5152017-02-0303 February 2017 NRR E-mail Capture - (External_Sender) Oyster Creek Nuclear Generating Station Response to Environmental Questions Regarding the Mitigating Strategies Final Integrated Plan and SPF Instrumentation Compliance Letter ML16244A3112016-10-0707 October 2016 Request for Additional Information Regarding License Amendment Request for Technical Specifications Section 6.0, Administrative Controls for Permanently Defueled Condition ML16125A2452016-05-16016 May 2016 Request for Additional Information Regarding Request for Approval of a Certified Fuel Handler Training and Retraining Program ML16060A1722016-03-0707 March 2016 Request for Additional Information Regarding Preliminary Decommissioning Cost Estimate and Spent Fuel Management Program ML16056A0012016-02-24024 February 2016 NRR E-mail Capture - Request for Additional Information - Oyster Creek Security Plan - Revision 14 ML17144A3702015-05-0606 May 2015 NRC Email J. Hughey( NRC) to Dave Distel (Exelon)- Request for Additional Information Regarding Request for Extension to Comply with NRC Order EA-13-109, Dated May 6, 2015 ML15005A0692015-01-0606 January 2015 Request for Additional Information Regarding the Fourth 10-Year Interval Inservice Inspection Program Plan Requests for Relief ML14246A5182014-09-17017 September 2014 Request for Additional Information Regarding the Fourth 10-Year Interval Inservice Inspection Program Plan Requests for Relief ML14252A7032014-09-17017 September 2014 Request for Additional Information Regarding Preliminary Decommissioning Cost Estimate and Annual Decommissioning Funding Status Reports ML14247A5862014-09-16016 September 2014 Request for Additional Information Regarding License Amendment Request to Revise Snubber Surveillance Requirements (Tac No. MF4124) ML14114A5632014-09-10010 September 2014 Request for Additional Information Regarding License Amendment Request Related to Reactor Building Vital Area Access Control ML14220A0272014-08-27027 August 2014 Request for Additional Information Regarding Request for Extension to Comply with NRC Order EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions ML14083A1602014-03-31031 March 2014 Request for Additional Information Regarding Bulletin 2012-01, Design Vulnerability in Electric Power System ML13351A3142013-12-20020 December 2013 Request for Additional Information Regarding Response to Bulletin 2012-01, Design Vulnerability in Electric Power System. ML13268A0312013-11-0808 November 2013 Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation ML13304B4182013-11-0101 November 2013 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Seismic Walkdowns ML13227A3042013-08-28028 August 2013 Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) ML13196A3382013-07-15015 July 2013 2013 Decommissioning Fund Report RAI ML12229A4332012-09-0606 September 2012 Request for Additional Information Regarding Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 12 (TAC No. D91660) ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12032A1872012-02-21021 February 2012 Request for Additional Information Related to the Response to License Renewal Commitment No. 10 Regarding Thermal Aging Irradiation Embrittlement of Cast Austenitic Stainless Steel ML12025A2542012-01-23023 January 2012 Request for Additional Information - License Renewal Commitment Regarding Thermal Aging and Neutron Irradiation Embrittlement of CASS Materials ML1200603242012-01-19019 January 2012 Fleet, RAI, Proposed Alternative to Use American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Case N-789 (N-789) ML1131200572011-11-22022 November 2011 Fleet - Bulletin 2011 01, Mitigating Strategies Request for Additional Information Regarding 60-Day Response ML1123604472011-08-24024 August 2011 E-mail, Miller to Loomis, Oyster Creek Flaw Evaluation Draft RAI Questions ML1120910012011-07-22022 July 2011 Generation Station - Licensed Operator Request for Additional Information ML1116805642011-07-0707 July 2011 Fleet, Request for Additional Information, 2011 Report on Status of Decommissioning Funding for Reactors 2021-04-08
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Text
NRR-DMPSPEm Resource From: Lamb, John Sent: Friday, March 09, 2018 1:43 PM To: 'david.helker@exeloncorp.com'; Richard.Gropp@exeloncorp.com; Bonnett, Frederick Paul:(GenCo-Nuc)
Subject:
RAIs - Oyster Creek Defueled TS LAR (EPID: L-2017-LLA-0395)
Importance: High
Dear Mr. Helker:
By letter dated January 7, 2011 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML110070507), Exelon Generation Company, LLC (Exelon or the licensee), submitted its Notification of Permanent Cessation of Power Operations for Oyster Creek Nuclear Generating Station (OCNGS). In this letter, Exelon provided notification to the U.S. Nuclear Regulatory Commission (NRC) of its intent to permanently cease power operation no later than December 31, 2019.
By letter dated February 14, 2018 (ADAMS Accession No. ML18045A084), Exelon submitted its updated Notification of Permanent Cessation of Power Operations for OCNGS. In this letter, Exelon provided notification to the NRC of its intent to permanently cease power operation no later than October 31, 2018.
By application dated November 16, 2017 (ADAMS Accession No. ML17320A411), Exelon requested changes to Renewed Facility Operating License (RFOL) No. DPR-16 and technical specifications (TSs) for OCNGS.
Exelon requested an amendment to revise the OCNGS RFOL and the associated TS to Permanently Defueled Technical Specifications (PDTS) consistent with the permanent cessation of reactor operation and permanent defueling of the reactor.
The NRC staff has reviewed Exelon's submittal and determined that additional information is required to enable the NRC staff to make an independent assessment regarding its technical review.
The enclosure to this email provides the request for additional information (RAI). On February 28, 2018, the draft RAI questions were sent to Mr. Richard Gropp, and Mr. Paul Bonnet of your staff to ensure that they were understandable, the regulatory bases for the questions were clear, and to determine if the information was previously docketed. A teleconference was held on March 9, 2018, with Mr. Paul Bonnet and Mr. Richard Gropp of your staff to clarify the RAI questions. Exelon stated they would respond to the RAI within 30 days of the date of this email.
If you have any questions, please contact me at 301-415-3100 or via e-mail at John.Lamb@nrc.gov.
Sincerely, John G. Lamb, Senior Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-219
Enclosure:
Request for Additional Information 1
DRAFT RAI REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGES TO THE OYSTER CREEK NUCLEAR GENERATING STATION PERMANENTLY DEFUELED TECHNICAL SPECIFICATIONS EXELON GENERATION COMPANY, LLC OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219 By application dated November 16, 2017 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML17320A411), Exelon Generation Company, LLC (Exelon or the licensee), requested changes to Renewed Facility Operating License (RFOL) No. DPR-16 and technical specifications (TSs) for the Oyster Creek Nuclear Generating Station (OCNGS). Exelon requested an amendment to revise the OCNGS RFOL and the associated TS to Permanently Defueled Technical Specifications (PDTS) consistent with the permanent cessation of reactor operation and permanent defueling of the reactor.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Exelon's submittal and determined that additional information is required to enable the NRC staff to make an independent assessment regarding its technical review.
RFOL-01 You propose to delete RFOL 1.C. In Reference 9 (ML15117A551) of your submittal, you refer to the Vermont Yankee Defueled TS amendment that the NRC approved. In the Vermont Yankee approval, the NRC staff approved the following License Condition, which is similar to your RFOL 1.C that you request to delete.
Actions have been identified and have been or will be taken with respect to: (1) managing the effects of aging on the functionality of structures and components that have been identified to require review under 10 CFR 54.21 (a)(1) during the period of extended operation, and (2) time-limited aging analyses that have been identified to require review under 10 CFR 54.21 (c), such that there is reasonable assurance that the activities authorized by this license will continue to be conducted in accordance with the current licensing basis, as defined in 10 CFR 54.3 for the facility, and that any changes made to the facility's current licensing basis in order to comply with 10 CFR 54.29(a) are in accordance with the Act and the Commission's regulations.
Please provide a technical justification for deleting RFOL 1.C.
RFOL-02 In RFOL 2.C.(2), explain why you wish to delete incorporated in the license and replace it with replaced with the Permanently Defueled Technical Specifications (PDTS). Once you decommission, you will still have a Part 50 license for OCNGS that you must adhere to.
RFOL-03 2
On December 22, 2017, the NRC staff issued Amendment No. 292 (ML17289A222) regarding Cyber Security.
Your current request would supersede Amendment No. 292. Do you wish to supplement your November 16, 2017, submittal to delete your requested change for RFOL 2.C.(4)?
RFOL-04 In RFOL 2.C.(10), you state that Exelon analyzed the FHA for dose results for the CR. Where is this analysis?
Is it part of the submittal dated November 16, 2017? Can you provide more technical details of this analysis?
TS 3.0-05 Why does the proposed LCO 3.0.1 refer to TS 3.0.2 and not LCO 3.0.2?
TS 3.0-06 Why is there a colon between LCO and 3.1 on page 44 of 91?
SR 4.2-07 Why is the frequency once per 7 days when liquid is being added? Why not once per 7 days while radioactive liquid is in the tank?
TS 6.0-08 You are proposing to change TS 6.8.1.a, TS 6.8.4.a.9, TS 6.9.1.d, TS 6.9.1.e; however, Amendment No. 290 has been approved with a 60-day implementation period not to exceed March 29, 2020. These are the same TSs being revised in the Defueled TS LAR. How is Exelon going to ensure that Amendment No. 290 is implemented before the Defueled TS amendment? What controls does Exelon have in place?
TS 3.1-09 On April 26, 2007, the NRC issued Amendment No. 262 (ADAMS No. ML071080019) to Facility Operating License No. DPR-16 for the OCNGS, approving the implementation of the alternative source term in accordance with 10 CFR 50.67 following the guidance provided in applicable sections of Regulatory Guide (RG) 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors.
Chapter 15 of the OCNGS Updated Final Safety Analysis Report (UFSAR) describes the design basis accidents (DBA) and transient scenarios applicable to OCNGS during power operations. With the termination of reactor operations at OCNGS and the permanent removal of fuel from the reactor pressure vessel (RPV) the majority of the DBA scenarios postulated in the UFSAR are no longer possible. During decommissioning, the irradiated fuel will be stored in the Spent Fuel Pool (SFP) and the Independent Spent Fuel Storage Installation until it is shipped off site. The analyzed accidents that remain applicable to OCNGS in the permanently shut down and defueled condition is a Fuel Handling Accident (FHA) in the SFP (a dropped fuel assembly onto the top of the core will no longer be applicable), the Postulated Radioactive Tank Failure, and Release of Radioactive Liquid Waste while radioactive liquids are still present.
The licensee proposed to change TS Section 3.1, Protective Instrumentation to be TS Section 3/4.1, Spent Fuel Storage with a new proposed TS LCO: TS 3.1, Spent Fuel Pool Water Level. The purpose of the change is to ensure safe storage and management of the spent fuel. LCO 3.1, Spent Fuel Pool Water Level, specifies requirements to ensure that the minimum water level in the spent fuel pool meets the assumptions of iodine decontamination factors following a FHA in the SFP. LCO 3.1 states:
Whenever irradiated fuel is stored in the spent fuel storage pool, water level shall be maintained at a level 117 feet 8 inches (elevation above sea level) with the exception of planned cask movements.
3
To support this new proposed change, the licensee evaluated the required minimum water level in the SFP (calculation C-1302-226-E310-460) for the dropping an irradiated fuel assembly onto irradiated fuel bundles stored in the SFP.
The licensee stated:
There is slightly over 23 feet of water above the top of active fuel for bundles within the storage racks; however, this does not ensure the dropped bundle will have 23 feet of water coverage above it.
Regulatory Issue Summary (RIS) 2006-04, Summary of Issue 8, Elemental Iodine Decontamination Factor (DF),
explains:
Appendix B to RG 1.183, provides assumptions for evaluating the radiological consequences of a fuel handling accident. If the water depth above [emphasis added] the damaged fuel is 23 feet or greater, Regulatory Position 2 states that the decontamination factors for the elemental and organic [iodine] species are 500 and 1, respectively, giving an overall effective decontamination factor of 200. However, an overall DF of 200 is achieved when the DF for elemental iodine is 285, not 500.
The licensee credits an overall effective decontamination factor of 200 even though 23 feet of water above the dropped bundle is not ensured. The licensee justifies the decontamination factor:
because less fuel damage would occur due to the shorter drop compensating for having slightly less than 23 feet of water coverage above the dropped bundle.
It is unclear how a decontamination factor of 200 is justified due to the reduced drop height in the SFP. The licensees fuel assembly drop analysis uses a simplified conservation of energy approach to estimate the maximum kinetic energy generated from a dropped fuel assembly. The analysis does not estimate a decontamination factor due to the assembly drop height.
As discussed in RG 1.183, Regulatory Position 2, Water Depth, if the depth of water is not 23 feet, the decontamination factor will have to be determined on a case-by-case method.
Please provide the technical basis for applying a decontamination factor associated with the water above the spent fuel being 23 feet or greater, when the water depth in the SFP is not 23 feet or greater. In addition, explain the methodology used to calculate the decontamination factor. Please state the estimated water level [in linear feet] above the damaged fuel assembly as applied in the radiological consequence analysis.
4
Hearing Identifier: NRR_DMPS Email Number: 235 Mail Envelope Properties (John.Lamb@nrc.gov20180309134300)
Subject:
RAIs - Oyster Creek Defueled TS LAR (EPID: L-2017-LLA-0395)
Sent Date: 3/9/2018 1:43:06 PM Received Date: 3/9/2018 1:43:00 PM From: Lamb, John Created By: John.Lamb@nrc.gov Recipients:
"'david.helker@exeloncorp.com'" <david.helker@exeloncorp.com>
Tracking Status: None "Richard.Gropp@exeloncorp.com" <Richard.Gropp@exeloncorp.com>
Tracking Status: None "Bonnett, Frederick Paul:(GenCo-Nuc)" <Frederick.Bonnett@exeloncorp.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 10652 3/9/2018 1:43:00 PM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received: