ML22313A050
| ML22313A050 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/07/2022 |
| From: | Lackey M Energy Solutions, TMI-2 Solutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| TMl2-RA-COR-2022-0023 | |
| Download: ML22313A050 (3) | |
Text
November 7, 2022 TMl2-RA-COR-2022-0023
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TMl-2 SOLUTIONS 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 10 CFR 50.90 10 CFR 50.91 10 CFR 20
Subject:
License Amendment Request - Three Mile Island, Unit 2, Decommissioning Technical Specifications, Response to Request for Information Regarding Radiation Protection Program Ventilation Controls
References:
(1)
Letter TMI2-RA-COR-2022-0021 from van Noordennen, G.P. (TMl-2 Solutions, LLC) to Document Control Desk (U.S. NRC), "License Amendment Request-Three Mile Island, Unit 2, Decommissioning Technical Specifications," dated 19 February 2021 (ML21057A046)
Reference 1, as supplemented, is currently undergoing an acceptance review for approval by the NRC in order for TMl-2 to transition into active decommissioning (DE CON) from its current Post-Defueling Monitored Storage (PDMS) condition. Reference 1 stated that the TMl-2 Radiation Protection Program (RPP) will identify the controls that will be implemented through procedures for DECON activities occurring inside the TMl-2 Reactor Building. Implementation of these procedures take into account detailed planning and execution of the DEGON work and support activities, including measures to maintain occupational dose As Low As Reasonably Achievable (ALARA) and below the occupational dose limits in 10 CFR 20 during DEGON.
During a clarification call on September 29, 2022, TMl-2 Solutions discussed the ventilation requirements for DECON based on the RPP and that there are no safety-related systems, structures, or components needed for DECON. In an email from the NRC Project Manager following the clarification call, the NRC Technical Reviewers requested more information on the proposed RPP discussions and commitments with regards to ventilation and containment.
TMl-2 Solutions is submitting this correspondence to supplement Reference 1 with this additional information.
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As stated above, control of requirements for Reactor Building ventilation while work is being performed during DEGON will be controlled by the RPP procedures. The ALARA Planning procedure allows work that has a potential to create airborne contamination (e.g., cutting, welding, grinding on contaminated components, breach of contaminated system, lifts of large, contaminated components or heavy lifts over areas with high levels of contamination) to occur provided:
Personnel and equipment access openings are closed, and Reactor Building Ventilation system is in operation, or The work is locally controlled with an enclosure and HEPA ventilation.
In the event that the NRC has any questions with respect to the content of this submittal, please contact Mr. Timothy Devik, TMl-2 Licensing Manager, at 603-384-0239.
In accordance with 10 CFR 50.91(7)(b)(1), a copy of this submittal has been sent to the Commonwealth of Pennsylvania.
I declare under penalty of perjury that the foregoing is true and correct. Executed on 7 November 2022.
Sincerely, *
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Mike Lackey Senior Vice President D&D Operations EnergySolutions cc:
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 President and CEO Energy Solutions 299 South Main Street, Suite 1700 Sal_t Lake City, UT 84111 John Sauger President and Chief Nuclear Officer Reactor D&D Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Mike Lackey Senior Vice President D&D Operations Energy Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Frank Helin Project Director TMl-2 Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Russ Workman General Counsel Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 Daniel F. Stenger Hogan Lovells US LLP 555 13th St NW Washington, D.C. 20004 Director, Bureau of Radiation Protection, Department of Environmental Protection, Commonwealth of Pennsylvania Rachel Carson State Office BLDG.
13TH Floor P.O. Box 8469 Harrisburg, PA 17105-8469 Chief, Division of Nuclear Safety, Bureau of Radiation Protection, Department of Environmental Protection, Commonwealth of Pennsylvania Rachael Carson State Office BLDG.
13TH Floor P.O. BOX 8469 Harrisburg, PA 17105-8469 Chairman, Board of County Commissioners, Dauphin County 112 Market Street 7th Floor Harrisburg, PA 17101 3