ML23090A216

Supplement to License Amendment Request - Proposed Changes to TMI-2 Possession Only License and Technical Specifications

ML23090A216
Person / Time
Site:	Crane
Issue date:	03/30/2023
From:	Hazelhoff A TMI-2 Solutions
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
TMI2-RA-COR-2023-0008
Download: ML23090A216 (1)

Text

March 30, 2023 TMI2-RA-COR-2023-0008 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 (TMI-2)

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

Subject:

Supplement to License Amendment Request - Proposed Changes to TMI-2 Possession Only License and Technical Specifications

References:

(1)

Letter TMI2-RA-COR-2023-0002 from Hazelhoff, A. C. (EnergySolutions, LLC) to Document Control Desk (U.S. Nuclear Regulatory Commission), License Amendment Request - Proposed Changes to TMI-2 Possession Only License and Technical Specifications, dated January 27, 2023 (ML23033A103).

(2)

Letter TMI2-RA-COR-2022-0019 from Lackey, M. B. (TMI-2 Solutions, LLC),

License Amendment Request - Three Mile Island, Unit 2, Decommissioning Technical Specifications, Response to Requests for Additional Information, dated September 29, 2022 (ML22276A024)

TMI-2 Solutions submitted a License Amendment Request (LAR) Supplement (Reference 1) to revise the TMI-2 Possession Only License (POL) to support the transition of TMI-2 from a Post-Defueling Monitored Storage (PDMS) condition to that of a facility undergoing radiological decommissioning (DECON).

Reference 1 contained a typographical error in that the Section numbering for the High Radiation Area Technical Specification was incorrect (See Attachment 7, POL and TS Clean Pages, Reference 1). Attachment 1 of this submittal contains the revised Technical Specification pages associated with this error.

Additionally, the response to RAI-5 contained in Reference 2 has been amended to replace work planning instruction with the more generic work package term. This Regulatory Commitment change was communicated to the NRC Project Manager via eMail on February 14, 2023.

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

If there are questions with respect to the content of this document, please contact the TMI-2 Solutions 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 30 March 2023.

Sincerely, Amy C. Hazelhoff Vice President, Regulatory Affairs EnergySolutions, LLC Attachments:

1. Corrected Technical Specification Pages

2. Revised RAI-5 Response 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 Amy C Hazelhoff Digitally signed by Amy C Hazelhoff Date: 2023.03.30 17:00:56

-04'00'

TMI-2 Service List Ken Robuck President and CEO EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 John Sauger President and Chief Nuclear Officer Reactor D&D EnergySolutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Sam Bambino Senior Vice President D&D Operations EnergySolutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 David Del Vecchio Project Director TMI-2 Solutions 121 W. Trade Street, Suite 2700 Charlotte, NC 28202 Russ Workman General Counsel EnergySolutions 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 Amy C. Hazelhoff Vice President, Regulatory Affairs EnergySolutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 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 Steve Minnick Site Decommissioning Director Three Mile Island Generating Station Route 441 South Middletown, PA 17057 Craig Smith Site Decommissioning Regulatory Assurance Lead Three Mile Island Generation Station Route 441 South Middletown, PA 17057 Tim Devik TMI-2 Licensing Manager Three Mile Island Generating Station Route 441 South Middletown, PA 17057

ATTACHMENT 1 TMI2-RA-COR-2023-0008 Corrected Technical Specifications Pages 2 Pages Follow

1 6.0 ADMINISTRATIVE CONTROLS 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 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 unit. 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.B.1 of Appendix I to 10 CFR Part 50.

6.11 HIGH RADIATION AREA Pursuant to 10 CFR Part 20, paragraph 20.1601(c), in lieu of the requirements of paragraph 20.1601(a) and 20.1601(b) of 10 CFR Part 20:

6.11.1 Access to each high radiation area, as defined in 10 CFR 20, in which an individual could receive a deep dose equivalent > 0.1 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation) shall be controlled as described below to prevent unauthorized entry.

a. Each area shall be barricaded and conspicuously posted as a high radiation area. Such barricades may be opened as necessary to permit entry or exit of personnel or equipment.

b. Entrance shall be controlled by requiring issuance of a Radiation Work Permit (RWP) or equivalent that includes specification of radiation dose rate in the immediate work area(s) and other appropriate radiation protection equipment and measures.

c. Individuals qualified in radiation protection procedures or personnel continuously escorted by such individuals may, for the performance of their assigned duties in high radiation areas, be exempt from the preceding requirements for issuance of an RWP or equivalent provided they are otherwise following plant radiation protection procedures for entry into, exit from, and work in such high radiation areas.

d. Each individual or group of individuals permitted to enter such areas shall possess, or be accompanied by, one or more of the following:

1. A radiation monitoring device that continuously indicates the radiation dose rate in the area.

2. A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset setpoint is reached.

Entry into high radiation areas with this monitoring device may be made after the dose rate in the area has been determined and personnel have been made knowledgeable of it.

3. A radiation monitoring device that continuously transmits dose rate and cumulative dose information to a remote receiver monitored by radiation protection personnel responsible for controlling personnel radiation

2 exposure within the area.

4. An individual qualified in radiation protection procedures equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive radiation protection control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by radiation protection supervision.

6.11.2 In addition to the requirements of Specification 6.11.1, high radiation areas in which an individual could receive a deep dose equivalent > 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation), but less than 500 rads/hour (at 1 meter from the radiation source or from any surface penetrated by the radiation) shall be provided with a locked or continuously guarded door, or gate, or equivalent to prevent unauthorized entry.

a. The keys to such locked doors or gates, or equivalent, shall be administratively controlled in accordance with a program approved by the radiation protection manager.

b. Doors and gates, or equivalent, shall remain locked except during periods of access by personnel under an approved RWP, or equivalent, to ensure individuals are informed of the dose rate in the immediate work areas prior to entry.

c. Individual high radiation areas in which an individual could receive a deep dose equivalent> 1.0 rem in one hour (at 30 centimeters from the radiation source or from any surface penetrated by the radiation),

accessible to personnel, that are located within larger areas where no enclosure exists to enable locking, or that are not continuously guarded, and where no lockable enclosure can be reasonably constructed around the individual area require both of the following access controls:

1. Each area shall be barricaded and conspicuously posted.

2. A flashing light shall be activated as a warning device.

ATTACHMENT 2 TMI2-RA-COR-2023-0008 Revised RAI-5 Response 1 Page Follows

1 RAI 5 Buildup of Radiolytic Gas Comment: The licensee did not provide sufficient information of radiolytic gases (primarily Hydrogen (H2)) that could pose an explosion hazard.

Basis: Interaction of radiation with water or other materials can result in the production of radiolytic gases, primarily hydrogen. In sufficient concentrations and with oxygen present, hydrogen is flammable. Through operation of the Submerged Demineralizer System and packaging of the generated waste for disposal, it was observed that TMI-2 debris could generate H2 inshort-term storage that could reach Lower Flammability Limits (LFL). Licensing of the dry cask storage system in Idaho for TMI-2 debris applied multiple controls and systems in order to prevent buildup of H2 gas to the LFL (ML18296A527). Canisters were vacuumed dried prior to storage and the systems included a HEPA filter to vent hydrogen. Monitoring of hydrogen levels is performed (ML19259A017) and observed hydrogen levels have been around 0.04 percent where the LFL with oxygen present is 5 percent - the venting has been very effective but hydrogen generation is continual.

Though a large fraction of the radioactivity has been removed from the TMI-2 systems, high radiation fields remain. The deactivated reactor systems have dead end and closed portions (e.g., high points in unused piping) where H2 gas could collect. Significant moisture is present in many systems and components. Decades have passed since the accident where H2 could be generated.

Path Forward: Please demonstrate the impacts of a hydrogen explosion initiated by decommissioning activities is bound by the fire scenarios evaluated, or please describe management controls and procedures such as circulation of air and monitoring for flammable gases that will be used prior to cutting or introduction of flame to systems being decommissioned.

RESPONSE

In preparation for entry into PDMS, the plant systems were vented, drained, and the remaining water volumes were processed for disposal. As a result, there are no significant water volumes remaining in TMI-2. However, TMI-2 Solutions recognizes there may be small, localized hydrogen gas pockets remaining within the highly contaminated portions of plant systems and components that could lead to hydrogen production. TMI-2 Solutions will establish work packages which will evaluate specific hydrogen concerns relevant to a given scope of work and include appropriate hydrogen mitigation measures appropriate for that work.