ML18310A021

NRR E-mail Capture - RAI - Pilgrim EP Exemption

ML18310A021
Person / Time
Site:	Pilgrim
Issue date:	11/06/2018
From:	John Lamb Special Projects and Process Branch
To:	Miner P Entergy Nuclear Operations
References
L-2018-LLE-0011
Download: ML18310A021 (4)

Text

NRR-DMPSPEm Resource From: Lamb, John Sent: Tuesday, November 6, 2018 6:57 AM To: Miner, Peter Cc: Byrne, Robert M; Couture III, Philip; Halter, Mandy; Powers, Michael J

Subject:

RAI - Pilgrim EP Exemption (EPID: L-2018-LLE-0011)

Importance: High Mr. Miner:

By letter dated July 3, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18186A635), Entergy Nuclear Operations, Inc. requested an exemption from specific emergency planning requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 for the Pilgrim Nuclear Power Station (PNPS), based on the proposed permanent cessation of power operations and removal of fuel from the reactor vessel, which is expected no later than June 1, 2019. The exemption request has been reviewed against the requirements in 10 CFR 50.47, Emergency plans, and Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities, using the guidance provided in Interim Staff Guidance (ISG) NSIR/DPR-ISG-02, Emergency Planning Exemption requests for Decommissioning Nuclear Power Plants (ADAMS Accession No. ML14106A057). The review considered the storage of the spent nuclear fuel in the spent fuel pool (SFP) and the onsite independent spent fuel storage installation, and the low likelihood of any credible accident resulting in radiological releases requiring offsite protective measures.

Based on the U.S. Nuclear Regulatory Commission (NRC) staff's initial review of PNPSs EP exemption request, the following request for additional information (RAI) is required to facilitate completion of the staff's technical review.

The enclosure to this email provides the RAI. On October 31, 2018, the draft RAI questions were sent to you to ensure that they were understandable, the regulatory bases for the questions were clear, and to determine if the information was previously docketed. On November 5, 2018, you stated that a clarifying teleconference was not needed and that Entergy would respond to the RAI within 45 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. 50-293

Enclosure:

Request for Additional Information RAI 1

REQUEST FOR ADDITIONAL INFORMATION EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 50.47 AND APPENDIX E TO 10 CFR PART 50 ENTERGY NUCLEAR OPERATIONS, INC.

PILGRIM NUCLEAR POWER STATION By letter dated July 3, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18186A635), Entergy Nuclear Operations, Inc. requested an exemption from specific emergency planning requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50 for the Pilgrim Nuclear Power Station (PNPS), based on the proposed permanent cessation of power operations and removal of fuel from the reactor vessel, which is expected no later than June 1, 2019. The exemption request has been reviewed against the requirements in 10 CFR 50.47, Emergency plans, and Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities, using the guidance provided in Interim Staff Guidance (ISG) NSIR/DPR-ISG-02, Emergency Planning Exemption requests for Decommissioning Nuclear Power Plants (ADAMS Accession No. ML14106A057). The review considered the storage of the spent nuclear fuel in the spent fuel pool (SFP) and the onsite independent spent fuel storage installation, and the low likelihood of any credible accident resulting in radiological releases requiring offsite protective measures.

Based on the NRC staff's initial review of PNPSs EP exemption request, the following request for additional information (RAI) is required to facilitate completion of the staff's technical review.

NRR-SCPB-01 Applicable Regulation and Guidance The current 10 CFR 50 regulatory requirements for emergency planning, developed for operating reactors, ensure protection of the health and safety of the public. However, once a power plant is permanently shutdown and defueled, some of these requirements exceed what is necessary to protect the health and safety of the public. Therefore, pursuant to 10 CFR 50.12 Specific Exemptions, Entergy Nuclear Operations (ENO) requested exemptions from certain emergency planning regulations in 10 CFR 50.47 and 10 CFR Part 50, Appendix E, for the Pilgrim Nuclear Power Station (PNPS).

Guidance for the staff review of Emergency Plan Exemption Requests can be found in Interim Staff Guidance (ISG) NSIR/DPR-ISG-02, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants. This guidance notes that the provisions of 10 CFR 50.12 permit the NRC to grant exemptions from the requirements of 10 CFR Part 50 regulations in circumstances where the application of the regulation is not necessary to achieve the underlying purpose of the rule. The staff concluded that a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> would provide adequate time to initiate mitigative actions to cool the fuel or, if needed, for offsite authorities to implement protective actions using a comprehensive emergency management plan (CEMP) approach. Thus, a formal offsite radiological emergency plan would not be necessary for permanently shutdown and defueled nuclear power reactor licensees when at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> would be necessary for the fuel to heat-up to the cladding ignition temperature following a complete loss of coolant.

Issue of Entergys submittal contains the Adiabatic Heatup Analysis for Drained Spent Fuel Pool. In the attachment, Table 2 Fuel Bundle Inputs for GNF2 Fuel lists the geometry inputs for the GNF2 fuel bundles evaluated in the analysis. The mass of the upper and lower plenums, 13.217 and 14.612 lbms respectively, are listed. These values are then added to the calculated mass of zircaloy-2, which are used to calculate the total heat capacity of the fuel assembly. This heat capacity was used to demonstrate that a 10 hour1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> heat up time to 2

the ignition temperature (900°C) would be available with a 10 month decay time, assuming the fuel assembly heats uniformly.

Request for Additional Information Based on the construction of a GNF2 fuel assembly, describe how the heat up rates of the plenums would be the same as the rest of the fuel assembly. Specifically, describe how the heat originating in the fuel gets to the upper and lower plenums under the assumed adiabatic conditions (when temperatures within the fuel bundle are assumed to maintain uniformity).

3

Hearing Identifier: NRR_DMPS Email Number: 651 Mail Envelope Properties (John.Lamb@nrc.gov20181106065600)

Subject:

RAI - Pilgrim EP Exemption (EPID: L-2018-LLE-0011)

Sent Date: 11/6/2018 6:56:52 AM Received Date: 11/6/2018 6:56:00 AM From: Lamb, John Created By: John.Lamb@nrc.gov Recipients:

"Byrne, Robert M" <rbyrne@entergy.com>

Tracking Status: None "Couture III, Philip" <pcoutur@entergy.com>

Tracking Status: None "Halter, Mandy" <mhalter@entergy.com>

Tracking Status: None "Powers, Michael J" <mpower1@entergy.com>

Tracking Status: None "Miner, Peter" <pminer@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 6531 11/6/2018 6:56:00 AM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: