ML22307A082
| ML22307A082 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 10/31/2022 |
| From: | Lackey M EnergySolutions, TMI-2 Solutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| TMl2-RA-COR-2022-0021 | |
| Download: ML22307A082 (1) | |
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TMl-2 SOLUTIONS October 31 , 2022 TMl2-RA-COR-2022-0021 10 CFR 50 .90 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 , Supplement to Response to Request for Additional Information References :
(1) Letter TMl2-RA-COR-2022-0019 from Lackey , M.B. (EnergySolutions) to Document Control Desk (U.S. NRC) , "License Amendment Request - Three Mile Island , Unit 2, Decommissioning Technical Specifications , Response to Request for Additional Information ," dated September 29 , 2022 (ML22276A024)
(2) Letter to Sauger, J.T. (TMl-2 Solutions , LLC) from Snyder, A.M . (U.S . NRC) ,
"Three Mile Island , Unit 2 - Request for Additional Information for Requested Licensing Action Regarding Decommissioning Technical Specifications ," dated July 29 , 2022 (ML22210A080 , pkg ; RAI Enclosure ML22210A088)
This letter supplements TMl-2 Solutions' responses provided in Reference 1 to the NRC's Request for Additional Information (Reference 2). supplements TMl-2 Solutions' response to RAI 3. Attachment 2 provides revised Technical Specification (TS) change pages to address RAI 8 which will be incorporated into the amended License Amendment Request (LAR) submittal. includes a revised List of Regulatory Commitments which supersede the list provided in Reference 1.
In accordance with 10 CFR 50 .91 (b)(1 ), a copy of this submittal has been sent to the Commonwealth of Pennsylvania.
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In the event that the NRC has any questions with re spect to the content of this document or wishes to obtain additional information , please contact the TMl-2 Licensing Manager, Mr. Timothy Devik at 603-384-0239 , or by email at trdevik@energysolutions.com .
I declare under penalty of perjury that the foregoing is true and correct. Executed on 31 October 2022 .
Sincerely, Mike Lackey Senior Vice President D&D Operations EnergySolutions , LLC Attachments :
- 1. Supplemental Response to RAI 3
- 2. Supplemental Response to RAI 8 - TS Excerpt Markup
- 3. Revised List of Regulatory Commitments 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 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 TM 1-2 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 3
ATTACHMENT 1 Supplemental Response to RAI 3 4
THREE MILE ISLAND, UNIT No. 2 - REQUEST FOR ADDITIONAL INFORMATION FOR REQUESTED LICENSING ACTION REGARDING DECOMMISSINING TECHNICAL SPECIFICATIONS EPID: L-2021-LLA-0038 ACCIDENT ANALYSIS:
By letter dated February 19, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21057A046), TMl-2 Solutions, LLC (TMl-2 Solutions or licensee) submitted a License Amendment Request (LAR) to remove certain requirements from the TMl-2 Technical Specifications (TS) that restrict activities in the TMl-2 Reactor Building during Post-Defueling Monitored Storage (PDMS) . The licensee would like to progress to actively decommissioning the remaining structures , systems , and components that were contaminated in the 1979 accident. Previously, the licensee had evaluated the impacts of a fire in a High Integrity Container (H IC) containing spent ion exchange resins. Subsequently, the licensee determined that the HIC fire scenario was not representative of the activities that wou ld be occurring during decommissioning and submitted supplemental information on January 7, 2022 (ML22013A177).
The U.S. Nuclear Regulatory Commission (NRC) staff provided preliminary questions on the information on February 7, 2022 (ML22038A936). The licensee provided a response on April 7, 2022 (ML22101A077), including references and additional analyses on May 8, 2022 (ML22138A302). This request for additional information (RAI) is in response to the latest information provided .
Fire is one of the largest risks at a nuclear facility (U .S. Department of Energy (DOE) , 1994).
Fire risk is a product of the likelihood of a fire occurring and the consequences if a fire were to occur. Though minor in impact, fires have occurred at nuclear reactors undergoing decommissioning (e.g ., Crystal River, Ft. Calhoun , Indian Point). By the introduction of fuel and energy sources combined with the diverse activities that are necessary to complete decommissioning , the frequency of occurrence of fires has been higher during decommissioning than during operations or, in the case of TMl-2 , PDMS .
When responding to RAls , the licensee may identify alternative approaches such as management controls, procedures , calculations, or conditions that will ensure the impacts from potential fires during decommissioning will meet established criteria for protection of human health.
RAI 3 Offsite Dose Calculations Comment: The offsite dose calculations lack transparency and traceability .
Basis: Offsite doses resulting from a potential fire were described in TMl2-RA-COR-2022-0007, LAR TMI- 2 "GPU Nuclear Calculation 4440-7380-90-017 , Revision 4 , PDMS Safety Analysis Report (SAR) Section 8.2 .5 Fire Analysis Source Terms") of ML22138A302 (May 13, 2022 , ) . The licensee described modifications to previous calculations (revision 3) to account for additional decay and ingrowth , the presence of additional loose contamination , and use of updated dose conversion factors (revision 4). These changes were sufficiently described and appropriate.
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Staff were able to verify the dose conversion factors that were used and most other parameters, as well as the calculated decay and ingrowth. However, the approach taken for the amount of source material (inventory) that is released as a result of the fire was not clear. In revision 3 of the analysis , the amount released was calculated as a product of two factors : the amount of material available and the fraction of available material that was released to the air. The amount of fuel elements available (e.g. , Pu , Am) was assumed to be 100 percent or a fraction of 1.0.
The amount of Cs and Sr available was assumed to be 1 percent or a fraction of 0.01 for a fire in the reactor basement. These were then multiplied by factors of 8 x 10-4 for actinides and apparently 1.5 x 10-3 for Cs and Sr. Staff could only replicate the basement fire dose of 0.889 mrem by using these factors. The impact is the dose for new ARF of 1.5 x 10-4 does not decrease by a factor of 6.67 but instead would be 0.80 mrem for the basement fire (note RAI #1 on the basis for the ARF).
Path Forward: Please verify the combined factors of material available and airborne fraction released in revision 3 of the fire analysis source terms and update the revision 4 analyses as appropriate .
RESPONSE
TMl-2 Solutions is in the process of re-performing the fire calculation analysis as the bases of the original source term used in the legacy PDMS calculations and subsequent updates referenced above was not able to be located or reproduced .
TMl-2 Solutions will be analyzing the amount of material available for a fire to determine the necessary volume and type necessary to exceed values at the site boundary for a ground release and an elevated release for a given source term. Administrative limits will be placed on the activity content of combustibles available for a fire to limit the fire severity to prevent having a fire that will cause a release corresponding to the dose associated with 2 times the ODCM limit at the site boundary or above. This will ensure that the release levels will remain below the Notice of Unusual Event (NOUE) limit for the site.
Since the new calculation is changing from a non-deterministic ana lysis to a deterministic analysis a review of an oxy-acetylene explosion to determine the limits of activity inside an enclosure in which cutting operations are to be performed is being developed. A review of the existing Zeolyte drop analysis is also being performed to ensure what the administrative limits are for this incident.
The calculations are being finalized and will go through the TMl-2S acceptance process. It is expected to complete this on or before November 22 nd , 2022. Once the calculation is accepted by TMl-2 Solutions, it will be formally transmitted to the NRC via separate letter.
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ATTACHMENT 2 Supplemental Response to RAI 8 - TS Excerpt Markup 7
TECHNICAL SPECIFICATIONS RAI 8 Annual Effluent Monitoring Report In TMl-2 Solutions' application , as supplemented , TMl-2 Solutions proposed deletion of this Technical Specification below and relocation to the Decommissioning Quality Assurance Plan:
ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT "6.8.1.2 The Annual Radiologica l Effluent Release Report covering the operation of the wm facility during the previous calendar year shall be submitted before May 1 each year.
The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility. The material provided shall be (1) consistent with the objectives outlined in the ODCM and (2) in conformance with 10 CFR 50 .36a and Section IV. 8.1 of Appendix I to 10 CFR Part 50."
Comment: The licensee did not address the requirement that the annual effluent monitoring reporting is required by regulation to be in the technical specifications .
Basis: As TMl-2 Solutions holds a part 50 license , then Title 10 of the Code of Federal Regulations (1 0 CFR) 50.36a(a)(2) , "Technical specifications on effluents from nuclear power reactors ," continues to require TMl-2's TS to contain this TS. This is because 50.36a states :
a) [E]ach licensee of a nuclear power reactor ... will include technical specifications that
... require that:
(1) .. .
(2) Each holder of an operating license ... shall submit a report to the Commission annually that specifies the quantity of each of the principal radionuclides released to unrestricted areas in liquid and in gaseous effluents during the previous 12 months, including any other information as may be required by the Commission to estimate maximum potential annual radiation doses to the public resulting from effluent releases. The report must be submitted as specified in § 50.4 , and the time between submission of the reports must be no longer than 12 months. If quantities of radioactive materials released during the reporting period are significantly above design objectives , the report must cover this specifically . On the basis of these reports and any additional information the Commission may obtain from the licensee or others, the Commission may require the licensee to take action as the Commission deems appropriate.
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Path Forward: Therefore , granting TMl-2 Solutions LAR (for removal of TS Section 6.8.1.2) would cause the TS to cease meeting 50.36a(a)(2) ; the license may only be amended in the requested fashion only if the licensee is first exempted from 50.36(a)(2) .
Alternatively , TMl-2 Solutions may supplement its application to request including TS Section 6 .8.1.2 in its TS for the staff s consideration in its review of the February 21 ,
2021 amendment application , as amended . TMl-2 Solutions should include a markup of the proposed TS change , if it decides to pursue this option .
RESPONSE
An excerpt of the Technical Specifications (TS ) to retain TS Section 6.8.1.2 is included as a markup in the following pages. TMl-2 Solutions will supplement its License Amendment Request (LAR) under separate cover which will include these proposed TS changes.
Reference Three Mile Island Nuclear Station Unit 2 (TMl-2) , "License Amendment Request - Three Mile Island , Unit 2, Decommissioning Technical Specifications ," TMl2-RA-COR-2021-0002 , dated February 19, 2021 (ML21057A046) 9
1 ODEFJN ITIONS FREQUENCY NOTATION 1.8 The FREQUE~JCY ~JOTATION specified for the performance of surveillance requirements shall correspond to the intervals defined in Table 1.1.
CONTAINMENT ISOLATION 1.9 CONTAINMENT ISOL/\TION shall exist when :
- a. Each penetration is:
- 1. Closed by a manual valve , a welded or bolted blind flange , a deactivated automatic valve secured in a closed position or other equivalent mechanical closure to provide isolation of each penetration , or
- 2. Open and the pathway to the environment provided with HEPA filter, or
- 3. Open in accordance with approved procedures. Controls shall be implemented to minimize the time the penetration is allo*.ved open and to specify the conditions for which the penetration is open. Penetrations shall be expeditiously closed upon completion of the conditions specified in the approved procedures , and
- b. The Equipment Hatch is closed , and
- c. Each Containment Airlock is operable pursuant to Technical Specification 3.1.1.3.
BATCH RELEASE 1.10 A BATCH RELE/\SE is the discharge of a discrete volume.
CONTINUOUS RELEASE 1.11 A CONTINUOUS RELEASE is the discharge of a non discrete volume , e.g., from a volume or system that has an input flow during the continuous release.
OFF-SITE DOSE CALCULATION MANUAL 1.12 OFF-SITE DOSE CALCULATION MANUAL (ODCM) shall contain the methodology and parameters used in the calculation of off-site doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm/trip setpoints , and in the conduct of the Radiological Environmental Monitoring Program. The ODCM shall also contain (1) the programs required by Section 6.7.4 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Reports required by Specifications 6.8.1 .2 and 6.8.1 .3.
Three Mile Island - Unit 2 1-2 Amendm ent 4&, 67
ADMINISTRATIVE CONTROLS 6.7 PROCEDURES AND PROGRAMS (can ' t)
I. ~fl.4onitoring, sampling, anal)*sis, and reporting of radiation and radionuclides in the environment in accordance with the rnethodolog)' and parameters in the ODCM .
- 2. A Land Use Census to ensure that changes in the use of areas at and be)'O nd the SJTE BOUNDARY are identified and that modifications to the monitoring program are made if required b;* the results of the census, and
- 3. Participation in an lnterlaboratory Comparison Program to ensure that the independent checks on the precision and accuracy of the measurements of radioactive materials in enYiro11111ental san1ple matrices are performed as part of the quality assurance program for environmental n10nitoring.
6.8 REPORTING REQUIREMENTS ROUTINE REPORTS 6.8.1 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations , the follov,ing reports shall be in accordance with 10 CFR 50.4 unless otherwise noted. Some of the reporting requirernents of Title 10, Code of Federal Regulations are repeated below:
ANNUAL RADlOLOGJCAL ENVIRONMENTAL OPERATll'J:G REPORT 6.8 . l . I The ,i\nnual Radiological Em*ironmental Operating Report co~*ering the operation of the unit during the pre,.*ious ca lendar year shall be submitted before May I of each )'ear. The report shall include summaries, interpretations, and analysis of trends of the resu lts of the Radiological Em*ironmental Monitoring Program for the reporting period. The material pro:vided shall be consistent with the ob:jecti¥es outlined in (1) the ODCM and (2) Sections IV.B.2 , IV.B .3, and JV.C ofAppendiJc I to 10 CFR Part 50.
ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT 6.8.1.2 The Annual Radiological Effluent Release Report covering the operation of the unit during the previous calendar year shall be s ubmitted before May I each year. The report shall include a s ummary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit. The material provided shall be ( 1) consistent with the objectives out! ined in the ODCM and (2) in conformance with IO CFR 50.36a and Section IV.B. l of Appendix I to IO CFR Part 50 .
Three Mile Island - Unit 2 6-10 Amendment 4-&,- 67
ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS The table included in this attachment identifies the regulatory commitments in this document. The type of commitment and associated schedule for implementation are prov ided . Any other statements in this submittal represent intended or planned actions .
They are provided for information purposes and are not considered to be regulatory commitments .
Type Scheduled Regulatory Commitment Completion Date One-Time Action Continuing Compliance TMl-2 Solutions will supplement its License Amendment Request (LAR) under separate cover which X November 22 , 2022 will include the proposed Technical Specification changes.
TMl-2 Solutions will submit calculations to support the source term limitations and X November 22, 2022 controls for RAI 3.
TMl-2 Solutions will establish a work planning instruction which will evaluate specific hydrogen concerns relevant X December 31 , 2022 to a given scope of work and include appropriate hydrogen mitigation measures appropriate for that work.
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