ML22138A285

(TMl-2) - License Amendment Request - Three Mile Island, Unit 2, Decommissioning Technical Specifications, Response to Questions

ML22138A285
Person / Time
Site:	Three Mile Island
Issue date:	05/16/2022
From:	Lackey M TMI-2 Solutions
To:	Office of Nuclear Material Safety and Safeguards
References
TMl2-RA-COR-2022-0013
Download: ML22138A285 (6)

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TMl-2 SOLUTIONS May 16, 2022 TMl2-RA-COR-2022-0013 10 CFR 50.90 10 CFR 2.390 10 CFR 50.91 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 2 (TMl-2)

NRC Possession Only License No. DPR 73 NRC Docket No. 50-320

Subject:

License Amendment Request- Three Mile Island, Unit 2, Decommissioning Technical Specifications, Response to Questions

References:

1) "TMl2 Accident Analyses Questions," dated February 7, 2022 (ML22038A936)

2) Letter TMl2-RA-COR-2022-0002, from Van Noordennen, G. P. (TMl-2 Solutions, LLC),

"License Amendment Request- Three Mile Island, Unit 2, Decommissioning Technical Specifications, Supplemental Information," dated January 7, 2022 (ML22013A177)

3) Letter TMl2-RA-COR-2022-0007, from Van Noordennen, G. P. (TMl-2 Solutions, LLC),

"License Amendment Request- Three Mile Island, Unit 2, Decommissioning Technical Specifications, Supplemental Information," dated April 8, 2022 Reference 1 requested additional information to aid in the review of potential events at TMl-2 described by Reference 2. Reference 3 committed to submit a revision of the GPU Nuclear Calculation Reactor Building Fire Analysis 4440-7380-90-017 by May '15, 2022. Via discussions with the NRC PM, this date was extended to May 16, 2022.

The amended responses to the TMl-2 Accident Analysis questions are provided as Attachment

1. A copy of the revised Reactor Building Fire Analysis is provided as Attachment 2. TMl-2 Solutions requests that this information be withheld from public disclosure pursuant to 10 CFR 2.390, as described in the Affidavit provided in Attachment 3.

TMl-2 Solutions requests review and approval of this proposed amendment by December 31, 2022, to allow for implementation prior to entering into Decommissioning which is scheduled.::._ SD}

to occur in January 2023. fJ H ~.I:..

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In accordance with 10 CFR 50.91 (7)(b)(1 ), a copy of this submittal has been sent to the Commonwealth of Pennsylvania.

There are no Regulatory Commitments contained in this submittal.

In the event that the NRC has any questions with respect to the content of this document or wishes to obtain any additional information, please contact me at 509-420-3078 or Mr. Tim Devik, TMl-2 Licensing Manager, at 603-384-0239.

Sincerely,

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CN_::Mlchoel 8_ Lackey, 1 , E11 m~Lilckey@emergysolut1ons com

'Reason:1iimtheauthorofthis B- La CkL' ey~~:: 0 1 n~ v1sion oa,e:2022-os-1s,4*s2:01 Mike LackeY FoKitPhantomPDFVorsion:9.7.0 Senior Vice President D&D Operations Energy Solutions Attachments:

1) Attachment 1 - Amended Response to Questions

2) Attachment 2 - "GPU Nuclear Calculation 4440-7380-90-017, Revision 4, PDMS SAR Section 8.2.5 Fire Analysis Source Terms" (PROPRIETARY)

3) Attachment 3 - 10 CFR 2.390 Proprietary Information Affidavit cc: w/Attachments Regional Administrator- NRC Region I NRC Lead Inspector- Three Mile Island Nuclear Station - Unit 2 NRC Project Manager- Three Mile Island Nuclear Station - Unit 2

TMl-2 Service List Ken Robuck Director, Bureau of Radiation Protection, President and CEO Department of Environmental Protection, Energy Solutions Commonwealth of Pennsylvania 299 South Main Street, Suite 1700 Rachel Carson State Office BLDG.

Salt Lake City, UT 84111 13TH Floor P.O. Box 8469 John Sauger Harrisburg, PA 17105-8469 President and Chief Nuclear Officer Reactor D&D Chief, Division of Nuclear Safety, Bureau Energy Solutions of Radiation Protection, 121 W. Trade Street, Suite 2700 Department of Environmental Protection, Charlotte, NC 28202 Commonwealth of Pennsylvania Rachael Carson State Office BLDG.

Mike Lackey 13TH Floor Senior Vice President P.O. BOX 8469 D&D Operations Harrisburg, PA 17105-8469 Energy Solutions 121 W. Trade Street, Suite 2700 Chairman, Board of County Charlotte, NC 28202 Commissioners, Dauphin County 112 Market Street Frank Helin 7th Floor Project Director Harrisburg, PA 17101 TMl-2 Solutions 121 W. Trade Street, Suite 2700 Trevor Orth Charlotte, NC 28202 Site Decommissioning Director Three Mile Island Generating Station Russ Workman Route 441 South General Counsel Middletown, PA 17057 Energy Solutions 299 South Main Street, Suite 1700 Craig Smith Salt Lake City, UT 84111 Site Decommissioning Regulatory Assurance Lead Daniel F. Stenger Three Mile Island Generation Station Hogan Lovells US LLP Route 441 South 555 13th St NW Middletown, PA 17057 Washington, D.C. 20004

Attachment 3 l,,i~ense Amendment Request Three Mile lslc1r1cl Nucle&1r Station, Unit 2 NRC Possession 'Only License No. DPR-73 1o CFR 2.390. Proprietary Information Affidavit TMl-2 SolutiQm~ Proprieqary informatic:m Affidavit Affidavit of Mike Lackey, Senior Vice President D&D Operations, EnergySolutions.

TMl-2 Solutions, LLC; contracted with Sargf:!nt & Lyndy respect to the preparation of the following document which is the property of TMl-2 Solutions, LLC, and Which is provided in support of this License Amendment Request:

"GPU Nuclear Calculation 4440-7380-90-017, Revision 4, PDMS .SAR Section 8.2.5 Fire Analysi$ Sourc~ Terrns" This document consists of proprietary information tnaJTMl-2 $olutions, I-LC considers confidential.

Release of this information would ca1.,1se irreparabie hann to the competithie position of TMl-2 Solutions, LJ;.¢. This.basis for this decla'ration is:

• I. This information is owned iand maint~in¢d a:$ propdetary l:!y TMI"'2 Solutions, LLC,

11. . Thi$ information is routinely held in confidence by TMl-2 Solutions, LLC, and not disclosed to the public.

Iii. This information is being requested to be held*in co.nfid~:mce by the NRG by this petition,

• Thls information is not available in public sources, This information would cause substantial harm to TMl-2 Solutions, LLC, if it were released publicly, and VI. The information to be withhel.d was transmiUed to the NRC in confidence.

I, Mike Lackey; being duly sworn, state that I am the person who subscribes my name tp the fQregoing statement, I am authorized to execute the Affidavit on behalf of TM!-2 Solutions, LL;C, and that the matters and facts set forth in the statement are true tp the be$t of my knowledge, information, and

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• EnergySo/u(ions Sworn To And Subscribed Before Me This 16th Day of May, 2022 My Commission Expires 1/ece.Jl(-beY-

Attachment 1 License Amendment Request Three Mile Island Nuclear Station, Unit 2 NRC Possession Only License No. DPR-73 Amended Response to Questions TMl2 Accident Analyses Questions, Amended Responses

2) The reactor building fire appears to be most limiting of the currently analyzed scenarios. Is credit being taken for the reactor building or not? If the doors are open, would this analyzed scenario be most limiting?

The basic changes in the Reactor Building in going from PDMS to DEGON is removal of the Equipment Hatch, squaring off of the hole left from Equipment Hatch Removal, and installation of a barrier at the interface between the Reactor Building and the outside structure.

Credit is being taken for the Reactor Building as a passive radiological barrier to the extent that the door between the Reactor Building and the outside structure would only be open for the period of time necessary to allow passage of material or personnel between the two structures.

Additionally, during DEGON, other openings may be made in the containment structure.

Following good ALARA practices these openings will also include passive radiological barriers.

During normal operation, any air flow would be into containment due to operation of the Reactor Building Purge Exhaust System. In the unlikely event that a fire occurs while this interface door is open, it will be closed by personnel involved in the material transfer and/or entry into or exit from the Reactor Building. Additionally, as the Reactor Building Exhaust Ventilation would be operational at that time, the release would be through a filtered pathway.

If the Reactor Building Exhaust Ventilation is secured during repairs or maintenance, the interface door will be closed. Work in the Reactor Building may be allowed on a case-by-case basis as determined by RP Management and consistent with the TMl-2 Fire Protection Program.

This most limiting scenario, Reactor Building fire, is not based on any specific event. Its main purpose is to demonstrate that even if HEPA Filtration was bypassed, the event would not exceed 100 mrem to the maximally-exposed individual, the standard for declaring a Site Area Emergency at an operating nuclear power plant. Because of the concerns expressed in Question 5 below, the Reactor Building Fire scenario has been reanalyzed to '

demonstrate the additional margin that exists. The calculation incorporated a more appropriate fractional airborne release factor as used in NUREG/CR-0130.

Attachment 1 License Amendment Request Three Mile Island Nuclear Station, Unit 2 NRC Possession Only License No. DPR-73 Amended Response to Questions

5) References cite the source term uncertainty as plus or minus 50%. Given the 97 mrem dose result is very close to the 100 mrem limit, how has uncertainty in the source term been accounted for?

With respect to the current most limiting accident of the Reactor Building Fire on the Operations Level of the Reactor Building (305' and 347') the offsite whole-body dose is calculated taking credit for the HEPA filtration present in the Reactor Building Exhaust path and using the fractional airborne release factor of 1.SE-4 used in NUREG/CR-0130 rather than 1E-3 used by GPU Nuclear in its 2019 and earlier calculations. The Reactor Building ventilation will be running when active work is being performed. If secured for maintenance or other reasons, work will be limited to reduce the risk of an unfiltered release from the Reactor Building. Any Reactor Building work allowed when the Reactor Building ventilation is not in operation will be approved on a case-by-case basis as determined by RP Management. The calculated result of an offsite dose from a puff release without benefit of the HEPA filters is 14.6 mrem. Considering that the Reactor Building doors would be closed as described in the response to Question 2, the fire would be contained within the Reactor Building, and significant plate out would occur within the Reactor Building and the offsite dose would not approach 14.6 mrem. Additionally, as D&D progresses, the source term available for release is diminished through decontamination, dismantlement, packaging, and removal from the areas. These processes will be administratively controlled to further reduce the risk.

9) Please provide the reference "Reactor Building Fire Analysis."

The reference has been provided as Attachment 2.

10) It is good to establish limits (dose rate cutoffs) substantially below the regulations to allow for a factor of safety and account for uncertainties. NRC staff would like to be able to establish how those limits were derived.

The reanalysis of a Reactor Building Fire using a more realistic Airborne Release Fraction provides a substantial Safety Margin with a Factor of Safety of approximately 6.