ML22132A169
| ML22132A169 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/12/2022 |
| From: | Fleming J Holtec Decommissioning International |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| HDI-IPEC-22-042 | |
| Download: ML22132A169 (16) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 50.90 10 CFR 50.54(q)
HDI-IPEC-22-042 May 12, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Indian Point Energy Center Provisional Operating License No. DPR-05 Renewed Facility License No. DPR-26 and DPR-64 NRC Docket Nos. 50-03, 50-247, and 50-286
Subject:
Response to Requests for Additional Information related to Exemption Request and License Amendment Request to Revise the Facilitys Emergency Plan
References:
- 1) Letter from Holtec Decommissioning International, LLC (HDI) to US Nuclear Regulatory Commission (NRC) dated December 22, 2021, as supplemented by letter dated February 4, 2022, License Amendment Request to Revise the Emergency Plan and Emergency Action Level Scheme to Address the Permanently Defueled Condition," (ADAMS Accession No. ML21356B704 and ML22035A121).
- 2) Letter from HDI to US NRC dated December 22, 2021, as supplemented by letter dated February 2, 2022, "Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47 and 10 CFR Part 50, Appendix E," (ADAMS Accession Nos. ML21356B693 and ML22032A117).
- 3) NRC Electronic Mail from Z. Cruz-Perez (NRC) to J. Fleming (HDI), Request for Additional Information: License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled condition for Indian Point Energy Center, (ADAMS Accession No. ML22103A244) dated April 13, 2022.
- 4) NRC Electronic Mail from Z. Cruz-Perez (NRC) to J. Fleming (HDI), Request for Additional Information related to Request for Exemption from portions of 10 CFR 50.47 and Part 50 Appendix E for Indian Point Energy Center, (ADAMS Accession No. ML22104A034) dated April 13, 2022.
In Reference 1, 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), submitted a request for an amendment to Provisional Operating License No. DPR-5 for IP1, Renewed Facility License No. DPR-26 for IP2, and
Renewed Facility Operating License No. DPR-64 for IP3. The requested license amendments would revise the IPEC Emergency Plan and Emergency Action Level (EAL) scheme for the permanently shutdown and defueled condition at IPEC. The proposed changes were submitted to the U.S. Nuclear Regulatory Commission (NRC) for approval prior to implementation, as required under 10 CRF 50.54(q)(4) and 10 CFR Part 50, Appendix E, Section IV.B.2.
In Reference 2, HDI on behalf of IPEC submitted a request for exemptions from portions of 10 CRF 50.47(b), 10 CFR 50.47(c)(2) and 10 CFR Part 50, Appendix E, Section IV. The requested exemptions would allow HDI to reduce the IPEC emergency preparedness and planning (EP) requirements consistent with the permanently shutdown and defueled condition of IP1, IP2 and IP3.
In References 3 and 4, the NRC transmitted requests for additional information (RAI) concerning the proposed license amendments and associated exemption requests. The Enclosures to this letter respond to the RAIs.
If there are any questions regarding the enclosed responses or should you wish to discuss further, please do not hesitate to contact Walter Wittich at (914) 254-7212 or myself at (856) 797-0900, ext. 3578.
Sincerely, Jean A. Fleming Vice President, Licensing, Regulatory Affairs and PSA Corporate Engineering Division Holtec International, LLC
Enclosure:
- 1. Response to Request for Additional Information: License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled Condition for Indian Point Energy Center
- 2. Response to Request for Additional Information related to Request for Exemption from portions of 10 CFR 50.47 and Part 50 Appendix E for Indian Point Energy Center cc:
NRC Senior Project Manager, NRC NMSS NRC Region l Regional Administrator NRC Senior Regional Inspector, Indian Point Energy Center New York State Liaison Officer Designee, NYSERDA New York State (NYS) Public Service Commission Jean A.
Fleming Digitally signed by Jean A. Fleming Date: 2022.05.12 13:08:15 -04'00'
ENCLOSURE 1 TO HDI-IPEC-22-042 Response to Request for Additional Information: License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled Condition for Indian Point Energy Center (5 pages not including this cover page) to HDI-IPEC-22-042 Page 1 of 5 Response to Request for Additional Information: License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled Condition for Indian Point Energy Center By letter dated December 22, 2021, as supplemented by letter dated February 4, 2022, 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 an amendment to Provisional Operating License No. DPR-5 for IP1, Renewed Facility License No. DPR-26 for IP2, and Renewed Facility Operating License No.
DPR-64 for IP3. The requested license amendments would revise the IPEC Emergency Plan and Emergency Action Level (EAL) scheme for the permanently shutdown and defueled condition at IPEC.
Issue: Enclosure, Description and Evaluation of Proposed Changes, Section 3.2.3, Accidental Release of Waste Gas, 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 14).
Additionally, Section 2.1, Permanently Defueled Facility, of Attachment 2, Permanently Defueled Emergency Action Level Technical Bases Document, states in part, HDI has confirmed that the source term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergency or General Emergency.
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:
Control Room - Whole Body Dose 0.77 rem - under limit of 5 rem; EAB - Whole Body Dose 0.30 rem - under limit of 0.5 rem, and LPZ - Whole Body Dose 0.11 rem - under limit of 0.5 rem.
Both of these documents reference the same calculation, Calculation IP-CALC-19-00003.
Request: Describe how the elimination of the requirements for a Site Area Emergency, as well as associated emergency action levels, are justified based on the whole body dose at the Exclusion Area Boundary from this accident.
Response
Calculation IP-CALC-19-00003, Revision 0, dated March 2019 analyzed that the dose at the site boundary after a Fuel Handling Accident (FHA) or Waste Gas release accident would remain well below the Environmental Protection Agency (EPA)
Protective Action Guide (PAG) limit of 1 rem total effective dose equivalent (TEDE).
The calculation demonstrated that significant margin exists as the dose at the Exclusion Area Boundary (EAB) was calculated at 0.3 rem at the EAB for a waste gas decay tank rupture. The methodology of using this calculation with dose values below PAG limits is consistent with precedent and is aligned with the analyses described in Section 5.0 of NSIR/DPR-ISG-02, Interim Staff Guidance (ISG-02), which states that applicable Design Basis Accidents (DBAs) would not result in a radiological release that exceed the limits of EPA PAGs at the EAB. This is also consistent with ISG-02, Table 1 which states that no offsite protective actions are anticipated to be necessary, so classification above an Alert is not required.
Revision 1 to calculation IP-CALC-19-00003 was issued in April 2022 to reflect the removal of the Waste Gas Decay Tank(s) from operation and to reevaluate the dose from a Fuel Handling Accident at 15 months after shutdown of Indian Point 3 (IP3).
The radiological consequences of a postulated waste gas decay tank rupture are negligible because the tanks are depressurized and vented to atmosphere. The radiological consequences of a postulated Fuel Handling Accident at 15 months after shutdown is 1.23 mrem TEDE, which is well below the 100 mrem TEDE threshold for declaration of a Site Area Emergency (SAE) resulting from a release of gaseous radioactivity, based on Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors."
Because the potential whole body dose at the EAB from an accidental release of waste gas is negligible, and the potential dose from the FHA DBA is well below the EAL threshold for declaration of a SAE, elimination of the requirements for a SAE is justified. Note: Calculation IP-CALC-19-00003, Revision 1, dated April 2022 is available on the HDI-NRC SharePoint.
RAI 2.
Issue: Attachment 1, Permanently Defueled Emergency Plan, Section A, Assignment of Responsibility, states, in part:
When an off-normal, natural phenomenon, or accident event becomes apparent, the Shift Manager shall assess the condition; make an emergency declaration, if appropriate; and assume the position of Emergency Director, with the overall responsibility to direct and control the emergency response. The Emergency Director does not have concurrent duties which conflict with these responsibilities.
However, Attachment 1, Section B.1.1, Normal Plant Organization, identifies one (1) Shift Manager assigned to each unit (IP2 and IP3).
Request: Describe how the Shift Managers would assume the Emergency Director duties for a site event vs. a unit specific event, and where is this direction/instruction documented.
Response
The implementing procedures for the Permanently Defueled Emergency Plan (PDEP) are in development and will be issued to support implementation of the PDEP. The current Post Shutdown Emergency Plan (PSEP) implementing procedures contain guidance for the Shift Managers to assume the Emergency Director duties for a site event. Per procedures IP-EP-120, Emergency Classification, and IP-EP-210 Central Control Rooms, the Unit 3 Shift Manager (or Unit 2 Shift Manager if the Unit 3 Shift Manager is incapacitated) shall implement the appropriate procedures for any related decommissioning initial emergency classifications. For classifiable events that potentially impact both units (Security, Natural or Man Made), the Unit 3 Shift Manager will confer with the Unit 2 Shift Manager and SHALL declare the event in accordance with the procedure. The Shift Manager emergency response protocols for a multi-unit event does not change with the transition from the PSEP to the PDEP.
Procedures IP-EP-120 Emergency Classification and IP-EP-210 Central Control Rooms are available on the HDI-NRC SharePoint.
RAI 3.
Issue: Attachment 1 Section E.1.1, Initial Notification, states, in part:
The initial emergency message will include the following information, if it is known and appropriate: [a list is provided]
Request: Describe if the content of the initial, as well as subsequent emergency messages, have been coordinated and agreed upon with the applicable State and local organizations.
Response
The information contained in the initial emergency message as well as subsequent messages to the Offsite Response Organizations have been agreed upon and shared with the parties involved at the December 2020 New York State Power Pool meeting.
The information in the existing Part 1 notification form will remain the same and will allow for additional information and messages, as appropriate.
The presentation from the December 2020 New York State Power Pool meeting is available on the HDI-NRC SharePoint.
RAI 4.
Requirement:
10 CFR 50.47(b)(9), as proposed to be exempted, requires, in part that adequate methods, systems, and equipment for assessing and monitoring actual or potential consequences of a radiological emergency condition are in use.
Associated guidance in NUREG-0654, as modified by NSIR/DPR/ISG-02, Evaluation Criterion I.2 requires, onsite capability and resources to provide initial values and continuing assessment throughout the course of an accident shall include radiation monitors.
Issue: Attachment 1 Section I.2, Dose Assessment, states, in part:
Dose assessment is the responsibility of the Emergency Director and is initially performed by qualified on-shift personnel.
Request: What position on-shift is designated to perform initial dose assessment and is this a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days a week position?
Response
The Emergency Director (ED) is responsible to ensure that the dose assessment is performed by qualified on-shift personnel. All Certified Fuel Handlers (CFH) are qualified to perform dose assessment. This position is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days per week.
ENCLOSURE 2 TO HDI-IPEC-22-042 Response to Request for Additional Information related to Request for Exemption from portions of 10 CFR 50.47 and Part 50 Appendix E for Indian Point Energy Center (7 pages not including this cover page) to HDI-IPEC-22-042 Page 1 of 7 Response to Request for Additional Information related to Request for Exemption from portions of 10 CFR 50.47 and Part 50 Appendix E for Indian Point Energy Center By letter dated December 22, 2021, as supplemented by letter dated February 1, 2022, 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).
2 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.
Response
Calculation IP-CALC-19-00003, Revision 0, dated March 2019 analyzed that the dose at the site boundary after a Fuel Handling Accident (FHA) or Waste Gas release accident would remain well below the Environmental Protection Agency (EPA)
Protective Action Guide (PAG) limit of 1 rem total effective dose equivalent (TEDE).
The calculation demonstrated that significant margin exists as the dose at the Exclusion Area Boundary (EAB) was calculated at 0.3 rem at the EAB for a waste gas decay tank rupture. The methodology of using this calculation with dose values below PAG limits is consistent with precedent and is aligned with the analyses described in Section 5.0 of NSIR/DPR-ISG-02, Interim Staff Guidance (ISG-02), which states that applicable Design Basis Accidents (DBAs) would not result in a radiological release that exceed the limits of EPA PAGs at the EAB. This is also consistent with ISG-02, Table 1 which states that no offsite protective actions are anticipated to be necessary, so classification above an Alert is not required.
Revision 1 to calculation IP-CALC-19-00003 was issued in April 2022 to reflect the removal of the Waste Gas Decay Tank(s) from operation and to reevaluate the dose from a Fuel Handling Accident at 15 months after shutdown of Indian Point 3 (IP3).
The radiological consequences of a postulated waste gas decay tank rupture are negligible because the tanks are depressurized and vented to atmosphere. The radiological consequences of a postulated Fuel Handling Accident at 15 months after shutdown is 1.23 mrem TEDE, which is well below the 100 mrem TEDE threshold for declaration of a Site Area Emergency (SAE) resulting from a release of gaseous radioactivity, based on Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors."
Because the potential whole body dose at the EAB from an accidental release of waste gas is negligible, and the potential dose from the FHA DBA is well below the EAL threshold for declaration of a SAE, elimination of the requirements for a SAE is justified. Note: Calculation IP-CALC-19-00003, Revision 1, dated April 2022 is available on the HDI-NRC SharePoint.
3 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.
Response
The regulation wording for item #80 in Table 2 has been updated to reflect the current wording of the regulation. The corrected pages are provided in Attachment 1 to this Enclosure and replace the corresponding pages in HDIs December 22, 2021, request for exemption from portions of 10 CFR 50.47 and Part 50 Appendix E (ADAMS Accession No. ML21356B693).
4 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.
5
6 ATTACHMENT TO HDI-IPEC-22-042 HDI-IPEC-21-015 Enclosure Page 45 of 98 (Amended by HDI-IPEC-22-042)
Table 2 Exemptions Requested from 10 CFR 50, Appendix E Item #
10 CFR Part 50, Appendix E Basis for Exemption Part 50, Appendix E,Section IV.1 (Item 2 in Table 2), regarding "hostile action."
80 F.2.j. The exercises conducted under paragraph 2 of this section by nuclear power reactor licensees must provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to implement the principal functional areas of emergency response identified in paragraph 2.b of this section.(ii) Each exercise must provide the opportunity for the ERO to demonstrate key skills specific to emergency response duties in the control room, TSC, OSC, EOF, and joint information center.(iii) In each 8-calendar-year exercise cycle, nuclear power reactor licensees shall vary the content of scenarios during exercises conducted under paragraph 2 of this section to provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to respond to the following scenario elements:(1) Hostile action directed at the plant site;(2) No radiological release or an unplanned minimal radiological release that does not require public protective actions;(3) An initial classification of, or rapid escalation to, a Site Area Emergency or General Emergency;(4) Implementation of strategies, procedures, and guidance under § 50.155(b)(2); and(5) Integration of offsite resources with onsite response.(iv) The licensee shall maintain a record of exercises conducted during each 8-year exercise cycle that documents the content of scenarios used to comply with the requirements of section IV.F.2.j of this appendix.(v) Each licensee shall conduct a hostile action exercise for each of its sites no later than December 31, 2015.(vi) The first 8-year exercise cycle for a site will begin in the calendar year in which the first hostile action exercise is conducted.. For a site licensed under Part 52, the first Refer to the basis for 10 CFR Part 50, Appendix E, Section IV.F.2.
Also, refer to the basis for 10 CFR 50.47(b)(5) (Item 6 in Table 1) regarding 10 CFR 50.155(b)(2) (formerly 10 CFR 50.54(hh)(2)) and 10CFR Part 50, Appendix E, Section IV.1 (Item 2 in Table 2), regarding 'hostile action."
7 ATTACHMENT TO HDI-IPEC-22-042 HDI-IPEC-21-015 Enclosure Page 46 of 98 (Amended by HDI-IPEC-22-042)
Table 2 Exemptions Requested from 10 CFR 50, Appendix E Item #
10 CFR Part 50, Appendix E Basis for Exemption eight-year exercise cycle begins in the calendar year of the initial exercise required by Section IV.F.2.a.
81 G. Maintaining Emergency Preparedness Provisions to be employed to ensure that the emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date shall be described.
No exemption is requested.
82 H. Recovery Criteria to be used to determine when, following an accident, reentry of the facility would be appropriate or when operation could be resumed shall be described.
No exemption is requested.
83 I. Onsite Protective Actions During Hostile Action By June 20, 2012, for nuclear power reactor licensees, a range of protective actions to protect onsite personnel during hostile action must be developed to ensure the continued ability of the licenseeto safely shut down the reactor and perform the functions of the licensees emergency plan.
Refer to the basis for 10 CFR Part 50, Appendix E, Section IV.1 (Item 2 in Table 2).
84 10 CFR 50 Appendix E V. Implementing Procedures No less than 180 days before the scheduled issuance of an operating license for a nuclear power reactor or a license to possess nuclear material, or the scheduled date for initial loading No exemption is requested.