Letter Sequence Draft RAI |
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EPID:L-2021-LLL-0022, (CPNPP) - Relief Request 1A4-3 for Continued Use of a Risk-Informed Process as an Alternative for the Selection of Class 1 and 2 Piping Welds for Unit 1 Inservice Inspection (Open) |
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Category:E-Mail
MONTHYEARML23334A0062023-11-29029 November 2023 NRR E-mail Capture - South Texas Project - Request for Additional Information - Proposed Alternative to ASME BPV Code Requirements ML23319A4442023-11-15015 November 2023 NRR E-mail Capture - South Texas Project - Draft Request for Additional Information - Proposed Alternative to ASME BPV Code Requirements ML23278A1532023-10-0505 October 2023 NRR E-mail Capture - South Texas Project Request for Additional Information - Request for Indirect Transfer of Licenses and Conforming Amendments (L-2023-LLM-0004) ML23264A0972023-09-21021 September 2023 NRR E-mail Capture - South Texas Project - Request for Additional Information - License Amendment Request to Revise the Alternate Source Term Dose Calculation (L-2023-LLA-0047) ML23255A2862023-09-12012 September 2023 NRR E-mail Capture - South Texas Project Draft Request for Additional Information License Amendment Request to Revise the Alternate Source Term Dose Calculation (L-2023-LLA-0047) ML23191A0102023-07-0707 July 2023 NRR E-mail Capture - South Texas Project - Acceptance of Request for Indirect Transfer of Licenses and Conforming Amendments (L-2023-LLM-0004) ML23145A1872023-05-24024 May 2023 July 2023 Emergency Preparedness Program Inspection - Request for Information ML23124A3272023-05-0404 May 2023 NRR E-mail Capture - South Texas Project - Acceptance of License Amendment Request to Revise the Alternate Source Term Dose Calculation (L-2023-LLA-0047) ML23115A0702023-04-24024 April 2023 NRR E-mail Capture - South Texas Project Units 1 and 2 - Audit Plan - Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections ML23096A1592023-04-0606 April 2023 NRR E-mail Capture - South Texas Project - Acceptance of Requested Licensing Action - Proposed Alternative to the Requirements of the ASME Code ML23065A0912023-03-0303 March 2023 NRR E-mail Capture - South Texas Project - Draft Supplemental Information Request - Proposed Alternative to the Requirements of the ASME Code ML23003A8082022-11-28028 November 2022 NRR E-mail Capture - Texas Commission on Environmental Quality (TCEQ) Review/Comment Regarding the Draft Environmental Assessment for the South Texas Project Alternate Disposal Request (L-2021-LLL-0022)) ML22249A0692022-09-0606 September 2022 NRR E-mail Capture - South Texas Project - Acceptance of License Amendment Request Regarding Adoption of TSTF-554, Revise Reactor Coolant Leakage Requirements (L-2002-LLA-0113) ML22206A0142022-07-20020 July 2022 NRR E-mail Capture - South Texas Project - Request for Additional Information - 10 CFR 20.2002 Alternate Disposal Request ML22194A0502022-07-0707 July 2022 NRR E-mail Capture - South Texas Project - Updated Draft Request for Additional Information - 10 CFR 20.2002 Alternate Disposal Request ML22194A0492022-06-0808 June 2022 NRR E-mail Capture - South Texas Project - Draft Request for Additional Information - 10 CFR 20.2002 Alternate Disposal Request ML22123A3272022-05-0303 May 2022 STP EP Exercise Inspection July 2022 RFI ML22115A2632022-04-19019 April 2022 Email Response to David Lochbaum Regarding Interim Configuration of Holtec HI-STORE FW Spent Fuel Multipurpose Canister at South Texas Project Energy Generating Station ML22105A5642022-04-0505 April 2022 Request for Information for Problem Identification and Resolution at STP Nuclear Operating Company ML21344A0072021-12-0909 December 2021 NRR E-mail Capture - South Texas Project - Acceptance of Requested Licensing Action - Alternative Disposal Request ML21305B8022021-11-0101 November 2021 NRR E-mail Capture - South Texas Project - Acceptance of Requested Licensing Action - Inservice Inspection Impracticality ML21257A2262021-09-14014 September 2021 NRR E-mail Capture - South Texas Project - Acceptance of License Amendment Request Regarding Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections (L-2021-LLA-0151) ML21160A1522021-06-0909 June 2021 Request for Information NRC Inspection 2021-003 Public Radiation Safety ML21133A2372021-05-0505 May 2021 Request for Additional Information: STP EP Exercise Inspection - July 2021 ML21117A3242021-04-22022 April 2021 NRR E-mail Capture - (External_Sender) STP Questions About Eplan Amendment SE ML21103A0072021-04-12012 April 2021 NRR E-mail Capture - South Texas Project - Acceptance of License Amendment Request to Add a Note to TS 3.6.3 and to Remove the TS Index (L-2021-LLA-0041) ML21058A0002021-02-26026 February 2021 NRR E-mail Capture - South Texas Units 1 and 2 - License Amendment Request to Revise Moderator Temperature Coefficient SRs - Audit Plan and Setup of Online Document Access (L-2021-LLA-0004) ML21049A2652021-02-16016 February 2021 NRR E-mail Capture - South Texas Project - Acceptance of License Amendment Request to Revise the Moderator Temperature Coefficient Surveillance Requirements (L-2021-LLA-0004) ML21039A8902021-02-0808 February 2021 NRR E-mail Capture - South Texas Project - Request for Additional Information - 1RE22 Inspection Summary Report for Steam Generator Tubing ML21029A3312021-01-29029 January 2021 NRR E-mail Capture - South Texas Project - Draft Request for Additional Information - 1RE22 Inspection Summary Report for Steam Generator Tubing ML20244A0222020-08-28028 August 2020 NRR E-mail Capture - South Texas Project - Acceptance of License Amendment Request to Adopt TSTF-374, Revision to TS 5.5.13 and Associated TS Bases for Diesel Fuel Oil. (L-2020-LLA-0172) ML20135H1982020-05-14014 May 2020 NRR E-mail Capture - South Texas Unit 1 - License Amendment Request to Revise Safety Injection System Accumulator Pressure - Audit Plan and Setup of Online Reference Portal ML20125A3312020-05-0404 May 2020 NRR E-mail Capture - South Texas Project - Acceptance of License Amendment Request to Revise the Emergency Plan (L-2020-LLA-0057) ML20111A0052020-04-17017 April 2020 NRR E-mail Capture - South Texas Project - Request for Additional Information - Proposed Alternative to ASME OM Code 2012 Edition - Relief Request PRR-01 ML20050E1192020-02-19019 February 2020 NRR E-mail Capture - South Texas Project - Acceptance of Requested Licensing Actions - Proposed Alternatives to ASME OM Code Requirements (EPID: L 2020-LLR-0007 to L-2020-LLR-0010) ML19344A0092019-12-0909 December 2019 NRR E-mail Capture - South Texas Project - Acceptance of Requested Licensing Action - Proposed Alternative to ASME Code Requirements for the Repair of Essential Cooling Water System Class 3 Buried Piping ML19309F1412019-11-0404 November 2019 Supplemental Information Request - Proposed Alternative to ASME Code Requirements for the Repair of Essential Cooling Water System Class 3 Buried Piping (EPID L 2019-LLR-0096) (Draft) ML19291A0332019-10-17017 October 2019 NRR E-mail Capture - Acceptance Review Results: STP License Amendment Request Regarding Request to Delete E Bar Definition ML19165A1032019-06-14014 June 2019 NRR E-mail Capture - Draft RAI for STP TS 3.8.1.1 Sbdg SR Change ML19162A1162019-05-22022 May 2019 NRR E-mail Capture - Acceptance Review Results: STP License Amendment Request Regarding TSTF-529 ML19095A6562019-04-0404 April 2019 NRR E-mail Capture - (External_Sender) Handout for 4/10/19 Meeting to Discuss a Proposed Request for South Texas Project, Units 1 and 2, Regarding Repair of Piping Using Carbon Fiber Repair Methods ML19081A1512019-03-21021 March 2019 NRR E-mail Capture - Draft Round 2 RAI - Sbdg Voltage and Frequency LAR (L-2018-LLA-0078) ML19078A3792019-03-19019 March 2019 NRR E-mail Capture - Acceptance Review Results: STP RR-ENG-3-23 (L-2018-LLR-0021) ML18292A7272018-10-19019 October 2018 NRR E-mail Capture - Acceptance Review Results: TSTF-522 (L-2018-LLA-0271) ML18283B9522018-10-10010 October 2018 NRR E-mail Capture - Final RAI - South Texas Standby DG TS Change (L-2018-LLA-0078) ML18263A1432018-09-12012 September 2018 NRR E-mail Capture - Final RAI for South Texas Project RR-ENG-E-16 (L-2018-LLR-0097) ML18190A5002018-07-0909 July 2018 NRR E-mail Capture - Acceptance Review Results - South Texas Unit 1 Relief Request - Relief Request RR-ENG-3-16 (L-2018-LLR-0097) ML18121A0322018-04-30030 April 2018 NRR E-mail Capture - Acceptance Review Results - South Texas Project Technical Specification Change for Standby Diesel Generator Surveillance Requirements Acceptance Criteria (L-2018-LLA-0078) ML18060A3062018-03-0101 March 2018 NRR E-mail Capture - Acceptance Review Results for South Texas Project Relief Request to Extend the Timeframe for Volumetric Exams of B-A and B-D Reactor Vessel Welds (L-2018-LLR-0010) ML18016A1542018-01-16016 January 2018 NRR E-mail Capture - Acceptance Review Results - South Texas Project Relief Request to Use Ultrasonic Examination Techniques in Lieu of Radiography (L-2017-LLR-0154) 2023-09-21
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML24024A1162024-01-24024 January 2024 STP Unit 2 Request for Information ML23334A0062023-11-29029 November 2023 NRR E-mail Capture - South Texas Project - Request for Additional Information - Proposed Alternative to ASME BPV Code Requirements ML23319A4442023-11-15015 November 2023 NRR E-mail Capture - South Texas Project - Draft Request for Additional Information - Proposed Alternative to ASME BPV Code Requirements ML23278A1532023-10-0505 October 2023 NRR E-mail Capture - South Texas Project Request for Additional Information - Request for Indirect Transfer of Licenses and Conforming Amendments (L-2023-LLM-0004) ML23264A0972023-09-21021 September 2023 NRR E-mail Capture - South Texas Project - Request for Additional Information - License Amendment Request to Revise the Alternate Source Term Dose Calculation (L-2023-LLA-0047) ML23255A2862023-09-12012 September 2023 NRR E-mail Capture - South Texas Project Draft Request for Additional Information License Amendment Request to Revise the Alternate Source Term Dose Calculation (L-2023-LLA-0047) ML23145A1872023-05-24024 May 2023 July 2023 Emergency Preparedness Program Inspection - Request for Information ML22255A1542022-09-13013 September 2022 Operating Company Information Request for the Cyber Security Baseline Inspection 05000498/2022401 and 05000499/2022401 ML22206A0142022-07-20020 July 2022 NRR E-mail Capture - South Texas Project - Request for Additional Information - 10 CFR 20.2002 Alternate Disposal Request ML22194A0502022-07-0707 July 2022 NRR E-mail Capture - South Texas Project - Updated Draft Request for Additional Information - 10 CFR 20.2002 Alternate Disposal Request ML22194A0492022-06-0808 June 2022 NRR E-mail Capture - South Texas Project - Draft Request for Additional Information - 10 CFR 20.2002 Alternate Disposal Request ML22123A3272022-05-0303 May 2022 STP EP Exercise Inspection July 2022 RFI ML22084A0762022-04-0404 April 2022 Notification of NRC Design Bases Assurance Inspection (Team) (05000498/2022012 and 05000499/2022012) and Request for Information ML21286A5732021-10-18018 October 2021 Notification of NRC Design Bases Assurance Inspection (Programs) (05000498/2022011 and 05000499/2022011) and Request for Information ML21166A2392021-06-16016 June 2021 Notification of Inspection (NRC Inspection Report 05000498/2021003 and 05000499/2021003) and Request for Information ML21160A1522021-06-0909 June 2021 Request for Information NRC Inspection 2021-003 Public Radiation Safety ML21133A2372021-05-0505 May 2021 Request for Additional Information: STP EP Exercise Inspection - July 2021 ML21039A8902021-02-0808 February 2021 NRR E-mail Capture - South Texas Project - Request for Additional Information - 1RE22 Inspection Summary Report for Steam Generator Tubing ML21029A3312021-01-29029 January 2021 NRR E-mail Capture - South Texas Project - Draft Request for Additional Information - 1RE22 Inspection Summary Report for Steam Generator Tubing ML20280A5452020-08-17017 August 2020 STP 2020 PIR Request for Information ML20111A0052020-04-17017 April 2020 NRR E-mail Capture - South Texas Project - Request for Additional Information - Proposed Alternative to ASME OM Code 2012 Edition - Relief Request PRR-01 ML20070N0222020-03-10010 March 2020 NRC Selection for Onsite Review ML20057G4612020-02-26026 February 2020 05000498/499 Request for Information - Occupational Radiation Safety Inspection ML20045E2172020-02-13013 February 2020 Licensed Operator Positive Fitness-For-Duty Test ML20036F5862020-02-0404 February 2020 Request for Additional Information - Proposed Alternative to ASME Code Requirements for the Repair of Essential Cooling Water System Class 3 Buried Piping (EPID L-2019-LLR-0096)Redacted ML19165A1032019-06-14014 June 2019 NRR E-mail Capture - Draft RAI for STP TS 3.8.1.1 Sbdg SR Change ML19081A1512019-03-21021 March 2019 NRR E-mail Capture - Draft Round 2 RAI - Sbdg Voltage and Frequency LAR (L-2018-LLA-0078) ML18283B9522018-10-10010 October 2018 NRR E-mail Capture - Final RAI - South Texas Standby DG TS Change (L-2018-LLA-0078) ML18263A1432018-09-12012 September 2018 NRR E-mail Capture - Final RAI for South Texas Project RR-ENG-E-16 (L-2018-LLR-0097) ML18197A4172018-07-17017 July 2018 Notification of NRC Triennial Heat Sink Performance Inspection (05000498/2018003 and 05000499/2018003) and Request for Information ML18003B4222018-01-0303 January 2018 NRR E-mail Capture - Final Request for Additional Information Amendment Request to Modify the Emergency Response Organization for South Texas Project ML17229B4672017-08-16016 August 2017 Notification of NRC Inspection 05000499/2017008 and Request for Information ML17132A0712017-05-15015 May 2017 Information Request the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000498/2017407; 05000499/2017407 ML17103A6272017-04-13013 April 2017 Notification of Evaluations of Changes, Tests, and Experiments Inspection (05000498/2017007 and 05000499/2017007) and Request for Information ML16351A1502016-12-16016 December 2016 Correction Letter Closeout of Request for Information Questions That Are No Longer Applicable Associated with the Resolution of Generic Safety Issue 191 (CAC Nos. MF2400 - MF2409) ML16302A4532016-12-12012 December 2016 Closeout of Request for Additional Information Questions That Are No Longer Applicable, Resolution of Generic Safety Issue (GSI) 191 (CAC Nos. MF2400-MF2409) ML16343A0422016-12-0808 December 2016 Request for Additional Information for the Review of the South Texas Project, Units 1 and 2 License Renewal Application (CAC NOS. ME4936, ME4937) ML16340A1022016-12-0505 December 2016 Requests for Additional Information for the Review of the South Texas Project License Renewal Application (CAC Nos. ME4936 and ME4937) ML16246A0952016-09-15015 September 2016 Correction to 8/26/16 Request for Additional Information Enclosure, License Amendment Request to Revise Technical Specification 5.3.2 to Allow Operation with 56 Full-Length Control Rod Assemblies ML16214A2912016-08-26026 August 2016 Summary of June 28-30, 2016, Regulatory Audit at Westinghouse in Rockville, MD, License Amendment Request to Revise Technical Specification 5.3.2 to Allow Operation with 56 Full-Length Control Rod Assemblies ML16187A0522016-07-0707 July 2016 Request for Additional Information Regarding License Renewal Application ML16141B0812016-05-31031 May 2016 Audit Summary, Risk Audit on April 12-13, 2016, at Alumni Center at the University of Texas, Austin, Tx; Pilot Generic Safety Issue 191 Submittal and Exemption Request, and Draft Request for Additional Information ML16125A2902016-05-26026 May 2016 Request for Additional Information, Risk Review, Exemption and License Amendment Request for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 (CAC Nos. MF2400-MF2409) ML16127A4522016-05-12012 May 2016 Supplemental Information Needed for Acceptance of Requested Licensing Action, Amendment Request to Revise Technical Specification 5.3.2 to Allow Operation with 56 Full-Length Control Rod Assemblies ML16104A3522016-04-22022 April 2016 Requests for Additional Information Set 35 for the Review of the South Texas Project License Renewal Application (Tac Nos. ME4936, ME4937) ML16082A5072016-04-11011 April 2016 Request for Additional Information, Phased Response Requested, Exemption and License Amendment Request for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 (CAC Nos. MF2400-MF2409) ML16082A4842016-03-22022 March 2016 NRR E-mail Capture - South Texas Project Units 1 & 2, Draft Request for Additional Information for Risk Review for GSI-191 ML16081A0042016-03-18018 March 2016 NRR E-mail Capture - South Texas Project Units 1 & 2, Draft Request for Additional Information for Thermal-hydraulic Review for GSI-191 ML16053A1872016-03-0101 March 2016 Request for Additional Information, Request to Revise Technical Specification 6.8.3.j, Containment Leakage Rate Testing Program, to Extend Integrated Leak Rate Test Interval from 10 to 15 Years (CAC MF6176-MF6177) ML16060A2872016-02-29029 February 2016 NRR E-mail Capture - Request for Additional Information - STP LRA Safety Review 2024-01-24
[Table view] |
Text
From: Galvin, Dennis Sent: Thursday, July 7, 2022 2:59 PM To: Wendy Brost (webrost@stpegs.com)
Subject:
South Texas Project - Updated Draft Request for Additional Information - 10 CFR 20.2002 Alternate Disposal Request (EPID: L-2021-LLL-0022)
Attachments: STP VLLW 20.2002 ADR Draft RAIs L-2021-LLL-0022 Updated 2022-07-07.pdf
Dear Ms. Brost,
By letter dated November 4, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21308A603) as supplemented by letter dated December 3, 2021 (ML21337A126), South Texas Project (STP) Nuclear Operating Company (STPNOC), the licensee) submitted a request for approval of alternate disposal procedures for very low-level waste (VLLW) to the Nuclear Regulatory Commission (NRC). STPNOC is requesting approval of its current disposal practice for VLLW, for which the NRC is exercising enforcement discretion pending the NRC review of the STPNOC request as described in the August 10, 2021, NRC letter (ML21180A195). The STPNOC request also refers to previously submitted information dated August 14, 2018 (ML18226A352).
To complete its review, the NRC staff has prepared an updated request for additional information (RAI) in DRAFT form. The RAIs were transmitted to the licensee in draft form on June 8, 2022. A clarification was held on June 27, 2022. Following the clarification call, the NRC staff updated the draft RAIs. To arrange a clarification call for the updated draft RAIs and to discuss the due date for the RAI response, please contact me at (301) 415-6256.
Respectfully, Dennis Galvin Project Manager U.S Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Licensing Project Branch 4 301-415-6256 Docket Nos. 50-498 and 50-499
Hearing Identifier: NRR_DRMA Email Number: 1708 Mail Envelope Properties (SA1PR09MB8111C5BA872B225F8A686926FB839)
Subject:
South Texas Project - Updated Draft Request for Additional Information - 10 CFR 20.2002 Alternate Disposal Request (EPID: L-2021-LLL-0022)
Sent Date: 7/7/2022 2:59:20 PM Received Date: 7/7/2022 2:59:00 PM From: Galvin, Dennis Created By: Dennis.Galvin@nrc.gov Recipients:
"Wendy Brost (webrost@stpegs.com)" <webrost@stpegs.com>
Tracking Status: None Post Office: SA1PR09MB8111.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1468 7/7/2022 2:59:00 PM STP VLLW 20.2002 ADR Draft RAIs L-2021-LLL-0022 Updated 2022-07-07.pdf 121726 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
DRAFT REQUEST FOR ADDITIONAL INFORMATION REQUEST FOR APPROVAL OF ALTERNATE DISPOSAL PROCEDURES FOR VERY LOW-LEVEL WASTE STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499 By letter dated November 4, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21308A603) as supplemented by letter dated December 3, 2021 (ML21337A126), South Texas Project (STP) Nuclear Operating Company (STPNOC), the licensee) submitted a request for approval of alternate disposal procedures for very low-level waste (VLLW) to the Nuclear Regulatory Commission (NRC). STPNOC is requesting approval of its current disposal practice for VLLW, for which the NRC is exercising enforcement discretion pending the NRC review of the STPNOC request as described in the August 10, 2021, NRC letter (ML21180A195). The STPNOC request also refers to previously submitted information dated August 14, 2018 (ML18226A352).
To complete its review, the NRC staff requests the following additional information.
RAI-1
Issue:
The submittal does not provide sufficient details to define the specific disposal action requested under 10 CFR 20.2002. Specifically, 20.2002(a) requires a clear understanding of the licensed material being considered for disposal as well as the proposed manner and conditions of the waste disposal. The submittal describes the waste being considered for disposal as dewatered sewage sludge, ion exchange media, desiccant, ventilation filtration media, and soil that is originated from the secondary side of plant operations but does not provide sufficient details related to the volume of material that is being requested for disposal per this approval or provide the NRC staff with a sufficient understanding of the manner and conditions in which STP is proposing to dispose of the material. Much of this information is also considered when assessing doses associated with the proposed action in accordance with 10 CFR 20.2002(d).
The information needed is that which is not covered by the Generic Environmental Impact Statement for License Renewal of Nuclear PlantsFinal Report (GEIS) (NUREG-1437, Revision 1) (GEIS) (ML13106A241) or the NUREG-1437, Supplement 48 (SEIS)
(ML13322A890), which specifically assessed the impacts associated with low-level radioactive waste from reactors at STP during their period of continued operations.
Regulatory Basis:
This information is needed to ensure that the proposed disposal action is understood and that specific details pertaining to the description of the waste and the manner and conditions of
waste disposal discussed in 10 CFR 20.2002(a) and the ability to maintain the doses, including future doses, ALARA per 10 CFR 20.2002(d) are considered.
The GEIS and SEIS discuss disposal of solid radioactive wastes in accordance with applicable requirements addressed in 10 CFR 61, Licensing Requirements for Land Disposal of Radioactive Waste, and 10 CFR Part 71, Packaging and Transportation of Radioactive Material. Further, all such operations are accounted for in the annual radioactive effluent release reports submitted to the NRC to demonstrate compliance with the applicable Federal standards and requirements. The primary standards applicable to all the power plants are contained in 10 CFR Part 20, Standards for Protection Against Radiation, 40 CFR Part 190, Environmental Radiation Protection Standards for Nuclear Power Operations, and Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities.
Path Forward:
- a. Provide specific details regarding the volume of material expected for each shipment, the length of time STP plans to perform the proposed action (the current license is through 2048), and the total volume of material to be disposed should this request be approved. The August 14, 2018, letter from STPNOC to the NRC notes that the State of Texas approval does not include a sunset clause or other time-limiting condition.
However, this information is needed to ensure that the proposed disposal action is understood and that specific details pertaining to the description of the waste discussed in 10 CFR 20.2002(a) and the ability to maintain the doses, including future doses, ALARA per 10 CFR 20.2002(d) are considered.
- b. Identify any processes related to the packaging and shipping of the material from STP to the disposal site that differ from the processes already evaluated in the GEIS or the SEIS.
- c. Clarify the anticipated maximum number of annual shipments of material transferred to the disposal site(s). The discussion in the Proposed Manner and Conditions of Disposal section of the submittal notes that STPNOC performs five shipments per year, on average. However, in the Dose Analyses - Annual Dose to a Material Shipment Driver section of the submittal STPNOC assumes that 12 shipments are made annually.
Also, clarify the statement [w]aste must be received and interred by the end of business on the date received, and clarify the length of time between when the material is packaged and shipped until it received and interred. Also clarify whether individual shipments will contain the same material or a mixture of different material types, the method used to transport the material (e.g., trucks, trains, etc.), and the method for tracking and documenting which materials were shipped to specific landfills.
- d. Describe any alternatives to disposing of the material at Texas Class I or Class II landfills that were considered (e.g., treatment methods, disposal onsite at STP or at licensed low-level waste disposal sites, disposal in landfills outside the State of Texas, etc.) and provide the bases for why such alternatives were or were not considered reasonable.
RAI-2
Issue:
Satisfying 10 CFR 20.2002(b) and (c) requires a clear understanding of the environment surrounding the areas associated with the actions related to the alternate disposal request as well as other potentially affected licensed and unlicensed facilities in the vicinity. Satisfying these requirements for this specific request may be met by providing sufficient details to describe the characteristics of Texas Class 1 or Class 2 industrial landfills in general or the site-specific characteristics of a specific Texas Class 1 or 2 industrial landfill (or landfills) to be considered with this request that will ensure the safe disposal as well as long-term safety to surrounding licensed and unlicensed sites. Although this submittal provides some specific details regarding the current landfill and a criterion that would be used to select future landfill disposal sites, specific details related to the surrounding environment of potentially impacted licensed and unlicensed facilities were not specifically addressed in the submittal. Similar details related to the environment and impacts to areas surrounding STP and, more specifically the environmental yard, were also not provided.
Additionally, the approval of a 10 CFR 20.2002 alternate disposal request is a Federal action that requires an environmental review in accordance with the National Environmental Policy Act (NEPA). As a result, an environmental review of the entirety of the disposal actions associated with this request also needs to be conducted as part of the NRC staffs review.
The information needed is that which is not covered by the GEIS or the SEIS (which are further described in the regulatory basis for RAI 1) and ensures the safe disposal of material at an offsite disposal facility authorized to accept the material in accordance with Texas regulations.
Regulatory Basis:
This information is needed when evaluating specific impacts associated with the proposed disposal action per 10 CFR 20.2002(b) and (c) and to perform an environmental review in support of NEPA requirements.
Path Forward:
- a. Identify the criteria and characteristics used by the State of Texas to classify a specific disposal site as a Texas Class 1 or Class 2 landfill that is acceptable for receiving and disposing of the VLLW material sent from STP or identify specific characteristics of specific site(s) the STP may use for waste disposal during the remainder of the current operating license period, or an alternate period consistent with the duration of the alternate disposal request. Also identify the range of environmental settings (e.g., urban, suburban, rural, etc.) for these disposal site(s) and how the environmental setting impacts their classification as a Texas Class 1 or Class 2 landfill.
- b. Describe the processes associated with the disposal of the material at Texas Class 1 and Class 2 disposal site(s) that are protective of the workers and members of the public at the landfills and in the areas surrounding the landfills. If specific Texas Class 1 and Class 2 disposal sites are being proposed for consideration, describe the processes and safety measures taken by those specific sites to ensure the safety of the workers and members of the public at the landfills and in the surrounding areas.
- c. Describe the environmental impacts associated with this alternate disposal request.
When considering impacts associated with onsite activities STPNOC may use existing environmental analyses, if appropriate, including the GEIS and SEIS, and consider how disposal processes that have already been evaluated compare to the proposed disposal procedures. For activities occurring offsite, describe any environmental impacts specifically associated with the disposal of VLLW at Texas Class 1 and Class 2 disposal sites. If specific Texas Class 1 and Class 2 disposal sites are being proposed, describe any environmental impacts specifically associated with the disposal of VLLW at these sites. STPNOC should consider any new or additional information related to environmental resources not previously considered by the NRC. since the publication of the SEIS. Specific considerations should include impacts to prominent vegetation, wildlife, aquatic habitats, and biota, as well as federally listed species and critical habitats protected under the Endangered Species Act.
- d. Identify the Federal, State, and local regulations that would be used to ensure that industrial landfills accepting VLLW are safe and that surrounding areas are not impacted. Also identify any other Federal, State, and local permits and approvals that are needed or have been already obtained in connection with the proposed action.
RAI-3
Issue:
The submittal does not provide sufficient details related to the doses to workers and members of the public associated with disposing of the waste to meet the requirements in 10 CFR 20.2002(d). This includes a description of the exposure scenarios, exposure pathways, and site-specific parameter values used to calculate doses to onsite facility workers at STP, transportation workers involved with transporting the material to the disposal site, landfill workers involved with the disposal actions at the landfill(s), and potential future intruders that could come into contact with the material once the landfill is no longer used.
Regulatory Basis:
This information is needed when evaluating the dose calculations needed to assess the doses (10 CFR 20.2002(d)) associated with this proposed disposal action in accordance with 10 CFR 20.2002.
Path Forward:
- a. Provide a summary of the input parameters for the sites being considered for disposal under the requested action and resulting doses from the RESRAD [RESidual RADioactive]-ONSITE and RESRAD-OFFSITE analyses (these could be the summary reports) as well as any other technical analyses performed for this submittal. Also provide the basis for considering specific modeling assumptions used in these calculations.
- b. Clarify the different workers involved with these disposal actions, the number of workers associated with each task, whether workers may perform multiple tasks associated with the proposed action, and if additional workers are necessary. Clarify whether the actions related to packaging and preparing the shipments at STP are performed by qualified
radiation workers, members of the public, or someone else and whether any radiation exposure monitoring activities are performed.
- c. Clarify the statement in the section, Dose Analyses - Annual Dose to a Material Shipment Driver that each shipment is assumed to be one-twelfth of an annual activity of 2.00E-05 curies of Cobalt 60 (Co-60). Explain the origin of the 2.00E-05 curie value as it is well below the Co-60 values provided in Table 2 of the submittal and why a fraction of Co-60 is considered but no other radionuclides are being considered for disposal.