ML20022A162
| ML20022A162 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center |
| Issue date: | 01/24/2020 |
| From: | Duane Hardesty NRC/NRR/DANU/UNPL |
| To: | Feyrer M GE Hitachi Nuclear Energy |
| Hardesty D, NRR/DANU/UNPL,301-415-3724 | |
| References | |
| EPID L-2019-LLA-0159 | |
| Download: ML20022A162 (7) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 24, 2020 Mr. Matthew Feyrer, Site Manager GE-Hitachi Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Road Sunol, CA 94586
SUBJECT:
GE-HITACHI NUCLEAR ENERGY AMERICAS LLC - REQUEST FOR ADDITIONAL INFORMATION RE: LICENSE AMENDMENT REQUEST FOR THE VALLECITOS NUCLEAR CENTER RADIOLOGICAL EMERGENCY PLAN (EPID L-2019-LLA-0159)
Dear Mr. Feyrer:
By letter dated July 17, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19198A298), GE-Hitachi Nuclear Energy Americas LLC requested the U.S. Nuclear Regulatory Commission (NRC) approval for changes to the Vallecitos Nuclear Center Radiological Emergency Plan pursuant to Section 50.54(q) Emergency plans, in Title 10 of the Code of Federal Regulations (10 CFR).
The NRC staff identified additional information needed to continue its review of the license amendment request (LAR), as described in the enclosed requests for additional information (RAIs). As discussed by telephone on January 21, 2020, provide a response to the RAIs or a written request for additional time to respond, including the proposed response date and a brief explanation of the reason, by February 28, 2020. Following receipt of the complete response to the RAIs, the NRC staff will continue its review of the LAR.
The response to the RAIs must be submitted in accordance with 10 CFR 50.4, Written communications, and pursuant to 10 CFR 50.30(b), Oath or affirmation, be executed in a signed original document under oath or affirmation. Information included in the response that you consider sensitive or proprietary, and seek to have withheld from public disclosure, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Any information related to safeguards should be submitted in accordance with 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements.
Based on the response date provided above, the NRC staff continues to expect to complete its review and make a final determination on the LAR by July 31, 2020. This date could change due to several factors, including a need for further RAIs, unanticipated changes to the scope of the review, unsolicited supplements to the LAR, and others. If the forecasted date changes, the NRC staff will notify you in writing of the new date and an explanation of the reason for the change. In the case that the NRC staff requires additional information beyond that provided in the response to this RAI, the NRC staff will request that information by separate correspondence.
M. Feyrer If you have any questions, please contact me at (301) 415-3724 or by electronic mail at Duane.Hardesty@nrc.gov.
Sincerely,
/RA/
Duane A. Hardesty, Senior Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket No.50-073 License No. R-33
Enclosure:
As stated cc: See next page
GE-Hitachi Nuclear Energy Americas LLC Docket No.50-073 cc:
Jeffrey Smyly, Manager Regulatory Compliance GE Hitachi Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Road Sunol, CA 94586 Thomas McConnell, Manager Nuclear Test Reactor GE Hitachi Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Road Sunol, CA 94586 Scott Murray, Manager Facility Licensing GE Hitachi Nuclear Energy 3901 Castle Hayne Road Wilmington, NC 28401 David Heckman, Vallecitos Reg Affairs & Licensing Lead GE Hitachi Nuclear Energy Vallecitos Nuclear Center 6705 Vallecitos Road Sunol, CA 94586 Commissioner California Energy Commission 1516 Ninth Street, MS-34 Sacramento, CA 95814 California Department of Health ATTN: Chief Radiologic Health Branch P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept. of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115
ML20022A162 *concurred via e-mail NRR-088 OFFICE NRR/DANU/UNPL/PM
- NRR/DANU/UNPL/LA* NRR/DANU/UNPL/BC NAME DHardesty NParker wcomments GCasto DATE 1/23/2020 1/23/2020 1/24/2020 OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR FACILITY OPERATING LICENSE NO. R-33 GE-HITACHI NUCLEAR ENERGY AMERICAS LLC NUCLEAR TEST REACTOR DOCKET NO.50-073 The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the license amendment request (LAR) for compliance with the appropriate regulations in Title 10 of the Code of Federal Regulations (10 CFR) using the following guidance and standard(s):
o NUREG-1537 Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, February 1996, Agencywide Documents Access and Management System (ADAMS) Accession No. ML042430055 o NUREG-1537 Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Standard Review Plan and Acceptance Criteria, February 1996, ADAMS Accession No. ML042430048 o Regulatory Guide (RG) 2.6, Revision 2, Emergency Planning for Research and Test Reactors and Other Non-Power Production and Utilization Facilities, September 2017, ADAMS Accession No. ML17263A472 o NUREG-0849, Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors, o American National Standard Institute/American National Standard--15.16-2008, Emergency Planning for Research Reactors o U.S. Environmental Protection Agency (EPA), EPA 400/R-17/001, PAG Manual:
Protective Action Guides [PAG] and Planning Guidance for Radiological Incidents, January-2017 (ADAMS Accession No. ML17044A073)
Based on its review, the NRC staff requires the following additional information to continue its review of the LAR for the GE-Hitachi Nuclear Energy Americas LLC (GEH) Radiological Emergency Plan (REP).
Enclosure
GEH RAI-1 Section 3.3, Off-Site Support Organization Descriptions, of Attachment 2, Reduction in Effectiveness Evaluation, of the application states, in part, The proposed REP describes the off-site support organizations VNC maintains written agreements with, but does not specify the name or the location of those off-site support organizations. It further states, The removal of specific names of organizations will require fewer changes when the agreements are changed.
RG 2.6, Revisions 1 and 2, states, The plan should not incorporate details that may routinely change (e.g., names and telephone numbers, specific items of equipment and supplies, inventory lists, and step-by-step procedures or checklists that may be altered as a result of experience or test exercises). These details are useful, but are better maintained in the facilitys implementing emergency procedures.
However, RG 2.6, Revision 1, states, Supporting organizations that would augment the licensees emergency organization, e.g., fire department, hospitals, and security organizations, should be specified.
Update the GEH REP to specify the supporting organizations that would augment the licensees emergency organization or provide a justification why the specific facilities do not need to be specified.
GEH RAI-2 By application dated July 17, 2019, GEH requested an exemption from the requirement of Appendix E.IV.D.3 to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, regarding the 15-minute notification of state agencies.
The NRC staff finds that an exemption is not required because in this specific section of the regulations, the intent is not applicable to non-power reactors. As provided in the statements of consideration for the revision to the emergency planning regulations, the purpose of the 15-minute notification is to ensure prompt notification of the public within the plume exposure pathway emergency planning zone for power reactors (see 44 Federal Register (FR) 75173; December 19, 1979 and 45 FR 55407; August 19, 1980).
There are no other specific time requirements in Appendix E to 10 CFR Part 50 for notification of the NRC, State and local agencies. The one-hour notification is acceptable to the NRC staff for the GEH Nuclear Test Reactor and is consistent with other regulations for other NRC non-power reactor licensees that are required to have emergency plans.
Update the LAR to rescind (or omit) the requested exemption or further explain why GEH still requests an exemption to Appendix E.IV.D.3 to 10 CFR Part 50.
GEH RAI-3 Section 7.4.4, Emergency Exposure Control and Guidelines, of the proposed Vallecitos Nuclear Center (VNC) REP references an earlier version of the EPA PAG Manual. The latest version of the EPA PAG Manual is U.S. Environmental Protection Agency, EPA 400/R-17/001, PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents, January-2017 (ADAMS Accession No. ML17044A073).
Update the VNC REP to reflect the latest version of the EPA PAG Manual or explain why referencing the current version of the EPA PAG manual is not necessary.