ML22112A010

Acceptance Review: Request for Exemption from 10 CFR 50.54(w)(1) Concerning Indian Point Energy Center Onsite Property Damage Insurance

ML22112A010
Person / Time
Site:	Indian Point
Issue date:	04/21/2022
From:	Cruz-Perez Z Reactor Decommissioning Branch
To:	Fleming J Holtec Decommissioning International
Cruz-Perez Z
References
Download: ML22112A010 (2)

Text

From: Cruz Perez, Zahira To: Jean Fleming Cc: Bill Noval; Matthew Johnson; Walter Wittich; Watson, Bruce

Subject:

Acceptance Review: Request for Exemption from 10 CFR 50.54(w)(1) Concerning Indian Point Energy Center Onsite Property Damage Insurance Date: Thursday, April 21, 2022 2:36:00 PM

Dear Ms. Fleming:

By letter dated March 18, 2022 (Agencywide Documents Access and Management System

[ADAMS]) Accession No. Main Library [ML] ML22077A132), Holtec Decommissioning International, LLC (HDI) submitted an exemption request for Indian Point Nuclear Generating Units Nos. 1, 2 and 3, collectively referred to as Indian Point Energy Center (IPEC). The exemption request from Paragraph 50.54(w)(1) of Title 10 of the Code of Federal Regulations (10 CFR) would allow HDI to reduce the IPEC minimum onsite insurance coverage to $50 million.

HDI has performed analyses showing that 15 months after Indian Point Unit 3s shutdown, the spent fuel stored in each of the unit's spent fuel pools (SFP) will have decayed sufficiently such that there is a significant reduction in risk from a theoretical SFP draindown event. HDIs analyses reflecting this anticipated reduction in risk may support the basis for the proposed exemption from 10 CFR 50.54(w)(1). The 15-month spent fuel decay period for Indian Point Unit 3 will expire by August 1, 2022. Therefore, HDI requests NRC review and approval of the requested exemption by July 1, 2022, with an effective date of August 1, 2022, and a 30-day implementation period from the effective date.

The purpose of this e-mail is to provide the results of the NRC staffs acceptance review of this request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

The NRC staff has reviewed your request and concluded that it does provide technical information in sufficient detail to enable the NRC staff to complete its detailed technical review and make an independent assessment regarding the acceptability of the proposed amendment in terms of regulatory requirements and the protection of public health and safety and the environment. Given the lesser scope and depth of the acceptance review as compared to the detailed technical review, there may be instances in which issues that impact the NRC staffs ability to complete the detailed technical review are identified despite completion of an adequate acceptance review. If additional information is needed, you will be advised through separate correspondence by mid-June 2022, and a response will be due 30 days from the receipt of the request for additional information.

The proposed exemption request from 10 CFR 50.54(w)(1) is predicated on current NRC staffs review of technical basis for approval of requests for exemptions from portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E, Section IV, which requires Commission approval. Therefore, the NRC staff expects to complete this review by February 3, 2023 (approximately 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br />). If there are emergent complexities or challenges in our review that would cause changes to the initial forecasted completion date, the reasons for the changes, along with a new estimate, will be communicated during the

routine interactions with the assigned project manager.

In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this email will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.

If you have any questions, please contact me.

Zahira Zahira Cruz (Pronouns: She/Her/Hers)

Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Reactor Decommissioning Branch Mail Stop: T-5A10 Rockville, MD 20852 Zahira.Cruz@nrc.gov 301-415-3808