ML23192A100

Response to Request for Additional Information Regarding License Amendment Request to Revise the Emergency Plan and Emergency Action Level Scheme

ML23192A100
Person / Time
Site:	Indian Point
Issue date:	07/11/2023
From:	Fleming J Holtec Decommissioning International
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
HDI-IPEC-23-031
Download: ML23192A100 (1)

Text

KrishnaP.Singh TechnologyCampus, 1Holtec Blvd.,Camden,NJ 08104 Telephone(856)797-0900 Fax(856)797-0909

10 CFR 50.90 10 CFR 50.54 (q)

July 11, 2023

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Indian Point Energy Center Provisional Operating License No. DPR-05 Facility License No. DPR-26and DPR-64 NRC Docket Nos. 50-03, 50-247, and 50-286

Subject:

Response to Request for Additional Information Regarding License Amendment Request to Revise theEmergency Plan and Emergency Action Level Scheme

References:

1. Holtec Decommissioning International LLC, Letter HDI-IPEC-22-080, to U.S. Nuclear Regulatory Commission, License Amendment Request to Approve the Independent Spent Fuel Storage Installation-Only Emergency Plan, (NRC ADAMS Accession Number ML22321A148), dated November 17, 20 22.

2. U.S. Nuclear Regulatory Commission E-mail to Holtec International, LLC, Request for Additional Informationrelated to IPEC LAR to Revise the Emergency Plan and Emergency Action Level Scheme (EPID No. L-2022-LLA-0195), (NRC ADAMS Accession Package Number ML23171B038), dated June 23, 2023.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.90, "Application for amendment of license, construction permit, or early site permit," HoltecDecommissioning International, LLC (HDI), on behalf of Holtec Indian Point 2, LLC (IP1 & IP2) and Holtec Indian Point 3, LLC (IP3), collectively referred to as Indian Point Energy Center (IPEC)requested U.S. Nuclear Regulatory Commission (NRC) review and approval of the IPEC Independent Spent Fuel Storage Installation Facility (ISFSI)-Only Emergency Plan (IOEP) and associated Emergency Action Level (EAL) scheme to reflect removal of all spent nuclear fuel from the IP2 and IP3 Spent Fuel Pits (SFPs) todry cask storage within a site controlled ISFSI.The proposed changes were submitted to the U.S. Nuclear Regulatory Commission (NRC) for approval prior to implementation, as required by 10 CFR 50.54,Conditions of licenses, paragraph (q)(4) and 10 CFR Part 50, Appendix E,Emergency Planning and Preparedness for Productionand UtilizationFacilities,Section IV,Content of Emergency Plans, paragraph B.2.

In Reference 2, HDI received a request for additional information (RAI) from the NRC on the SubjectLAR. The HDI response to the RAI is provided in the enclosureofthis letter.

Thislettercontainsno new regulatorycommitments.

HDI-IPEC-23-031 KrishnaP.Singh Technology Campus, 1 Holtec Blvd.,Camden,NJ08104 Telephone (856)797-0900 Fax (856)797-0909

In accordance with 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b), a copy of this RAI response, with enclosure, is being provided to the designated State Official.

The response to the RAI does not affect the No Significant Hazards Consideration Determination and the Environmental Evaluation provided in Reference 1.

If you have any questions or need further information, please contact Mr. Walter Wittich, IPEC Licensingat 914-254-7212.

I declare under penalty of perjury; the foregoing is true and correct. Executed on July 12, 2023.

Sincerely,

Jean A. Fleming Vice President,Licensing,Regulatory Affairsand PSA HoltecInternational

Enclosure:

Response to Request for Additional Information Regarding License Amendment Request to Revise the Emergency Plan and Emergency Action Level Scheme

cc: NRC Senior Project Manager, NRC NMSS NRC Region l Regional Administrator NRC Senior Regional Inspector, Indian Point Energy Center New York State Liaison Officer Designee, NYSERDA New York State (NYS) Public Service Commission

HDI-IPEC-23-031 KrishnaP.SinghTechnologyCampus,1Holtec Blvd.,Camden,NJ08104 Telephone(856)797-0900 Fax(856)797-0909

ENCLOSURE TO HDI-IPEC-23-031

Respons e to Request for Addi tional Inf ormation Regarding License Amendment Request to Revis e t he Emergency Plan and E mergency Action Lev el Scheme

HDI-IPEC-23-031 HDI-IPEC-23-031 Enclosure Page 1 of 2

Response to Request for Additional Information Regarding License Amendment Request to Revise the Emergency Plan and Emergency Action Level Scheme

NRC RAI

By letter dated November 17, 2022, (Agencywide Documents Access and Management System Accession No. ML22321A148), Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Indian Point 2, LLC (IP1 and IP2) and Holtec Indian Point 3, LLC (IP3),

collectively referred to as Indian Point Energy Center (IPEC), requests an amendment to Provisional Operating License No. DPR-5 for IP1, Renewed Facility License No. DPR-26 for IP2, and Renewed Facility Operating License No. DPR-64 for IP3. The licenseamendments requested U.S. Nuclear Regulatory Commission (NRC) review and approval of the IPEC Independent Spent Fuel Storage Installation Facility (ISFSI)-Only Emergency Plan (IOEP) and associated Emergency Action Level (EAL) scheme to reflect removal of all spent nuclear fuel from the IP2 and IP3 Spent Fuel Pits (SFPs) to dry cask storage within a site controlled ISFSI.

The proposed changes are being submitted to the NRC for approval prior to implementation, as required under Title 10 of the Code ofFederal Regulations (10 CFR) Paragraph 50.54(q)(4),

Conditions of licenses-Emergency plans.

The proposed amendment would modify the IPEC license by replacing the IPEC Permanently Defueled Emergency Plan (PDEP) and the associated EAL scheme with the IOEP and its associated EAL scheme to reflect the storage of all IPEC fuel on the ISFSI. The proposed changes reduce the scope of onsite emergency planning requirements to reflect the reduced scope of potential radiological accidents with all IPEC spent fuel in dry cask storage within the ISFSI. After all spent fuel is in dry cask storage within the ISFSI, the number and severity of potential radiological accidents possible at IPEC are substantially lower.

The following request for additional information (RAI) is needed to facilitate the technical review being conducted by the Division of Preparedness and Response, Reactor Licensing Branch staff. Timely and accurate response to the draft RAI is requested in order to continue the staffs review of the IPEC PDEP and the associated EAL scheme with the IOEP and its associated EAL scheme to reflect the storage of all IPEC fuel on the ISFSI.

RAI 1

Requirement:

10 CFR 50.47(b)(12), Emergency plans, as proposed to be exempted, states, in part:

Arrangements are made for medical services for contaminated injured individuals.

Associated guidance in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (FEMA-REP-1), as modified by NSIR/DPR/ISG-02, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants, Evaluation Criterion O.3, states: Trainingfor individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross First Aid, CPR, Automated External Defibrillators (AED) for Lay Responders or equivalent.

HDI-IPEC-23-031 Enclosure Page 2 of 2

However, Section O of the proposed ISFSI IOEP, Item 1.1(1), First Aid Response, states:

First Aid training is provided to personnel assigned on-shift in accordance with site training and qualification plan.

Issue:

HDI does not provide information that the first aid training offered to personnel assigned on-shift is equivalent to Red Cross First Aid, Cardiopulmonary Resuscitation (CPR), or AED.

Request:

Please provide what level of training is offered to on-shift personnel assigned to respond to medical emergencies at IPEC.

HDI Response to RAI 1

IPEC personnel receive First Aid, Cardiopulmonary Resuscitation (CPR) and Automated External Defibrillator (AED) training. The training classesareAmerican Red Cross (ARC)

Adult and Pediatric First Aid/CPR/AED certifiedor equivalent. Qua li fied pe rsonnel a reon-site andavailable on a 24-hour-per-day basis.