L-22-041, Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension
| ML22343A165 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/09/2022 |
| From: | Fleming J Holtec Decommissioning International |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| HDI-PIL-22-041 | |
| Download: ML22343A165 (1) | |
Text
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 72.7 December 9, 2022 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044
Subject:
Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension
References:
- 1. Letter from Holtec Decommissioning International, LLC (HDI) to US NRC, Request for Exemption from 10 CFR 72.212(a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim ISFSI Annual Radioactive Effluent Release Report, August 28, 2022 (ML22241A112).
- 2. US Nuclear Regulatory Commission (NRC) clarification call with Holtec Decommissioning International, LLC (HDI) regarding the August 29, 2022 exemption request for the Annual Radioactive Effluents Reporting Requirements, November 15, 2022 (ML223335A273).
By letter dated August 28, 2022 (Reference 1) Holtec Decommissioning International, LLC, (HDI) submitted an exemption request for Pilgrim Nuclear Power Station (PNPS). The proposed exemption addressed an exemption from the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 72.212 (a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim Nuclear Power Station (PNPS) Independent Spent Fuel Storage Installation (ISFSI) Annual Radioactive Effluent Release Report (ARERR). TheUHTXLUHPHQWVRI10 CFR 72.212 identify that Pilgrim must follow the Certificate of Compliance (CoC) technical specifications (TS) for the spent fuel casks it uses. Relevant cask TSs require Pilgrim to submit an ISFSI ARERR to the NRC in accordance with 10 CFR 72.44(d)(3), which effectively requires report submittal within 60 days after the end of the 12-month monitoring period which begins on January 1 and ends on December 31st each year. Specifically, Pilgrim requested exemption from the 60-day cask TS reporting requirement so that the report can instead be incorporated into and submitted with the Site Annual Radioactive Effluent Release Report (ARERR) on or before May15th each year.
Discussion with the NRC Project Manager assigned to review the exemption for Pilgrim Station identified concerns where additional clarity was requested (Reference 2). Attachment 1 to this letter identifies the requests for supplemental information (RSI) and provides the additional exemption support details requested.
HDI has reviewed the information provided in this RSI submittal and determined that the finding of No Significant Hazards Consideration provided to the NRC in Reference 1 was not affected. In HDI-PIL-22-041 Page 1 of 2
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
There are no regulatory commitments contained in this submittal.
If you have any questions or require additional information, please contact me at (856) 797-0900, ext. 3578.
I declare under penalty of perjury that the foregoing is true and correct. Executed on December 9, 2022.
Sincerely, Digitally signed by Jean A.
Jean A. Fleming Fleming Date: 2022.12.09 12:57:09 -05'00' Jean A. Fleming Vice President, Licensing, Regulatory Affairs, & PSA Holtec International . Exemption Submittal Supplement for the Pilgrim ISFSI Annual Radioactive Effluent Release Report cc:
USNRC Regional Administrator, Region I USNRC Project Manager, NMSS - Pilgrim Nuclear Power Station USNRC Region I, Lead Inspector - Pilgrim Nuclear Power Station Director, Massachusetts Emergency Management Agency Deputy Regional Director Bureau of Air & Waste, Massachusetts DEP Environmental Analyst Surface Water Discharge Permitting Program , Massachusetts DEP Director, Massachusetts Department of Public Health Radiation Control Program HDI-PIL-22-041 Page 2 of 2
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-22-041 Attachment 1 Exemption Submittal Supplement for the Pilgrim ISFSI Annual Radioactive Effluent Release Report
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909
SUMMARY
By letter dated August 29, 2022 (Agencywide Documents Access Management System [ADAMS]
Accession No. ML22241A112), Holtec Decommissioning International, LLC, (HDI) submitted an request to the U.S. Nuclear Regulatory Commission (NRC) for an exemption from Title 10 of the Code of Federal Regulations (10 CFR) 72.212 (a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim Nuclear Power Station (PNPS or Pilgrim) Independent Spent Fuel Storage Installation (ISFSI) Annual Radioactive Effluent Release Report (ARERR). The staff has identified the following questions as part of the screening process for acceptance review.
The following information is identified to ensure that our exemption request identifies complete information relative to the following:
RSI - 1:
The NRC staff notes that HDI is requesting the timing of Pilgrim ISFSI ARERR submittal to be aligned with the timing of the overall site ARERR under 10 CFR 50 requirements. Given that Pilgrim is in active decommissioning status, discuss how the timing of Pilgrim ISFSI ARERR reporting requirements be addressed when Pilgrims decommissioning activities are complete, and its 10 CFR 50 reactor license terminated in the foreseeable future.
Response :
Pilgrim Station operates the Independent Spent Fuel Storage Installation (ISFSI) under a general license LQDFFRUGDQFHZLWK10 CFR Part 72 which was approved based on the site having a 10 CFR 50 license. HDI would be required to notify the NRC of any plan to change this ISFSI licensing configuration prior to implementing a license change. The license change process would evaluate overall licensing compliance strategy for a ISFSI Only 10 CFR 72 specific license, to include aligning the annual ARERR report in accordance with 10 CFR 72.44(d)(3).
72.44(d)(3) An annual report be submitted to the Commission in accordance with Sec. 72.4, specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents during the previous 12 months of operation and such other information as may be required by the Commission to estimate maximum potential radiation dose commitment to the public resulting from effluent releases. On the basis of this report and any additional information that the Commission may obtain from the licensee or others, the Commission may from time to time require the licensee to take such action as the Commission deems appropriate. The report must be submitted within 60 days after the end of the 12-month monitoring period.
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Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 RSI - 2:
The exemption request states that PNPS Defueled Safety Analysis (DSAR), Appendix B, Section B-5.6.3, Radioactive Effluent Release Report, provides licensing basis requirements for reporting quantities of radioactive liquid and gaseous effluents and solid waste released from the facility.
Provide corresponding PNPS Technical Specifications (TS) for the same requirements, including the relevant TS section citation related to ARERR reporting requirements.
Response
The NRC reviewed and approved removal of direct reference to Technical Specification Requirements related to ARERR reporting requirements in their approval of License Amendment
- 256 to the Renewed Facility Operating License No DPR-35 for Pilgrim station. This review and approval are addressed in NRC letter dated August 24, 2021 (ML21203A042).
The NRC Safety Evaluation specifically addresses a license and technical specifications for a plant configuration that reflects removal of all spent fuel from the spent fuel pool and storage of spent fuel in an on-site ISFSI. The change addressed and removed technical specification Administrative Section 5.0 Administrative Controls and the associated requirements in previous TS 5.6, Reporting Requirements for providing the Annual Radiological Environmental Operating Report (per previous TS 5.6.2) and the Annual Radioactive Effluent Release Report ARERR report (per previous TS 5.6.3). Removal of these previous TSs were reviewed and approved by the NRC for removal from the Renewed Facility License and relocated into Appendix B to the Stations Defueled Safety Analysis, which is a license basis document controlled under 10 CFR 50.59.
The Renewed Facility Operating License continues to generically invoke the annual effluent reporting requirements per 10 CFR 50, and the more specific requirements identified in 10 CFR 50.4, 10 CFR 50.36(a)(2), and 10 CFR 50.59.
RSI - 3:
List relevant PNPS plant procedure(s) related to the reporting of ARERR for the overall Pilgrim site and ISFSI, respectively.
Response
The following site procedures are used to implement the ARERR program for the overall site:
Offsite Dose Calculation Manual - ODCM 7.3.25 - Particulate and Iodine Monitoring at the Main Stack and the Reactor Building Vent 7.3.31 - Tritium Sampling 7.8.1 - Chemistry Sample and Analysis Program 7.9 Liquid Releases with RETDAS 7.9 Dose Assessment 7.10 Reactor Building Vent, and Radwaste PRM Functional Check and Source Check P-EN-CY-130 Radiological Environmental Monitoring Program (REMP)
P-EN-CY-131- Annual Radioactive Effluent Release Report HDI-PIL-22-041 Page 2 of 3
Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Note - These same implementation procedures are used for the ISFSI ARERR monitoring program.
based on the design of the ISFSI and the Cask Storage Systems.
Excerpt from Site License Basis Document - PNPS Hi-Storm 100 10 CFR 72.212 Evaluation Report Rev 10, dated 03/02/2022. Section 3.30, (pg. 55 of 151),
72.126(c): Effluent and direct radiation monitoring. (1) As appropriate for the handling and storage system, effluent systems must be provided. Means for measuring the amount of radionuclides in effluents during normal operations and under accident conditions must be provided for these systems. A means of measuring the flow of the diluting medium, either air or water, must also be provided.
(2) Areas containing radioactive materials must be provided with systems for measuring the direct radiation levels in and around these areas.
The MPCs have redundant seal-welded closures, so no gaseous radioactive material leak path to the environment is available and no routine monitoring of effluents from the HI-STORM casks is required. HDI maintains an extensive network of thermo-luminescent dosimeters (TLDs) around the plant site, including within the Owner-Controlled Area (OCA) and along the fence of the protected area. This network of TLDs is sufficient to detect any significant radiation dose emitted from the casks at the ISFSI.
72.126(d): Effluent control. The ISFSI or MRS must be designed to provide means to limit to levels as low as is reasonably achievable the release of radioactive materials in effluents during normal operations; and control the release of radioactive materials under accident conditions. Analyses must be made to show that releases to the general environment during normal operations and anticipated occurrences will be within the exposure limit given in §72.104. Analyses of design basis accidents must be made to show that releases to the general environment will be within the exposure limit given in §72.106. Systems designed to monitor the release of radioactive materials must have a means for calibration and testing their operability.
The MPCs have redundant seal-welded closures, so no gaseous radioactive material leak path to the environment is available and no routine monitoring of effluents from the HI-STORM casks is required. The MPC design has been shown by analysis to maintain the confinement boundary integrity under all normal, off-normal, and accident conditions of service as discussed in Chapter 3 of the HI-STORM 100 System FSAR. The MPC lid-to-shell closure weld design meets the guidance in ISG-18 and the MPC vent and drain port cover plates are leak tested to a leaktight acceptance criterion as defined in ANSI N14.5 and as discussed in Chapter 7 of the HI-STORM 100 System FSAR. Based on these two factors, leakage from the MPC confinement boundary is considered non-credible and no effluent controls or dose analysis is required.
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