ML22104A035
| ML22104A035 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/13/2022 |
| From: | Cruz-Perez Z Reactor Decommissioning Branch |
| To: | Fleming J Holtec Decommissioning International |
| Zahira Cruz, 301-415-3808 | |
| Shared Package | |
| ML22104A027 | List: |
| References | |
| Download: ML22104A035 (3) | |
Text
REQUEST FOR ADDITIONAL INFORMATION RELATED TO EXEMPTION REQUEST FROM EMERGENCY PLANNING HOLTEC DECOMMISSIONING INTERNATIONAL, LLC INDIAN POINT ENERGY CENTER DOCKET NOS.50-003, 50-247 AND 50-286 By letter dated December 22, 2021, as supplemented by letter dated February 1, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21356B693 and ML22032A117, respectively), Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Indian Point 2, LLC (IP1 and IP2) and Holtec Indian Point 3, LLC (IP3), collectively referred to as Indian Point Energy Center (IPEC), requested exemptions from certain emergency preparedness and planning (EP) requirements of Part 50, Domestic Licensing of Production and Utilization Facilities, to Title 10, Energy, of the Code of Federal Regulations (10 CFR) for the IPEC.
Issue: The regulation wording for item #21 in Table 2, Exemptions Requested from 10 CFR 50, Appendix E, of the Enclosure, Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR Part 50, Appendix E, states in part, The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.
Additionally, Section 5.2, Consequences of Design Basis Events, of the Enclosure states in
- part, The analysis concludes that without crediting any mitigating systems or the Plant Auxiliary Building (PAB) ventilation system, the calculated TEDE to the Control Room is less than the limit set forth in 10 CFR 50.67 and the whole-body dose value of 500 millirem (mrem) at the EAB. The dose consequences from a waste gas tank decay tank rupture are less than the dose consequences following an FHA and meet the applicable radiological dose criteria at the Control Room, EAB, and Low Population Zone (LPZ) (Reference 25).
However, the NRC staff reviewed the letter dated April 28, 2020, Indian Point Nuclear Generating Unit No. 2 - Issuance of Amendment No. 294 Re: Permanently Defueled Technical Specifications (EPID L-2019-LLA-0079) (ADAMS Accession No. ML20081J402), and it states in part, The calculated radiological consequences following a waste gas decay tank rupture without credit for any mitigating systems or the primary auxiliary building ventilation system post shutdown are as follows:
Both the exemption request and the amendment reference the same calculation, Calculation IP-CALC-19-00003.
Request: Describe how the exemption from the requirements for a Site Area Emergency is justified based on the whole-body dose at the EAB from this accident.
Issue: The regulation wording for item #80 in Table 2, Exemptions Requested from 10 CFR 50, Appendix E, of the Enclosure, Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR Part 50, Appendix E, is not consistent with the current regulation language of Paragraph IV.F 2.j of Appendix E to 10 CFR Part 50.
Request: Please revise the application to correct this inconsistency.
Issue: Item #7 of Table 3, Interim Staff Guidance-02 Comparison, of the Enclosure states in part, These diverse strategies provide defense-in-depth and ample time to provide makeup water or spray to the IP2 and IP3 SFPs prior to the onset of zirconium cladding ignition when considering very low probability beyond design basis events affecting the SFPs.
Request: Please provide additional details regarding the mitigation strategies, to include the identification of the primary and backup (portable) pumps, the capacities of these pumps, and the primary and backup sources of makeup water for these mitigation strategies.