RS-15-235, Revised Response to Request for Additional Information (RAI) TR-09 Re License Renewal Application, Environmental Review
| ML15240A002 | |
| Person / Time | |
|---|---|
| Site: |  |
| Issue date: | 08/28/2015 |
| From: | Gallagher M Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-15-235 | |
| Download: ML15240A002 (5) | |
Text
Michael P. Gallagher Vice President, License Renewal Exelon Generation Exelon Nuclear 200 Exelon Way Kennett Square. PA 19348 610 765 5958 Office 610 765 5956 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50 10 CFR 51 10 CFR 54 RS-15-235 August 28, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374
Subject:
Revised Response to Request for Additional Information (RAI) #TR-09 Regarding the LaSalle County Station, Units 1 and 2, License Renewal Application, Environmental Review
References:
- 1. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon Generation), to U.S. Nuclear Regulatory Commission (NRC) Document Control Desk, "Application for Renewed Operating Licenses," dated December 9, 2014
- 2. Letter from David Drucker, NRC, to Michael P. Gallagher, Exelon Generation, "Requests for Additional Information for the Review of the LaSalle County Station, Units 1 and 2, License Renewal Application," dated June 25, 2015
- 3. Letter from Michael P. Gallagher, Exelon Generation, to NRC Document Control Desk, "Response to NRC Request for Additional Information, dated June 25, 2015, Regarding the LaSalle County Station, Units 1 and 2, License Renewal Application, Environmental Review," dated July 24, 2015 In the Reference 1 letter, Exelon Generation submitted the License Renewal Application (LRA) for the LaSalle County Station, Units 1 and 2 (LSCS). In the Reference 2 letter, NRC itemized requests for additional information (RAls) concerning the transportation impacts analysis described in Section 4.13 of Appendix E (Environmental Report) to the LSCS LRA. In the Reference 3 letter, Exelon Generation responded to the RAls in Reference 2, including RAI # TR-09. During a telephone conference on August 5, 2015, NRC Staff and contractor personnel asked Exelon Generation to clarify its response to RAI # TR-09. The enclosure to this letter provides the requested clarification in the form of a revised response sheet for RAI # TR-09. Locations of revised text on the response sheet are indicated by vertical bars in the right-hand margin.
August 28, 2015 U.S. Nuclear Regulatory Commission Page2 This letter and its enclosure contain no regulatory commitments.
If you have any questions, please contact Ms. Nancy Ranek, Environmental Lead, Exelon Generation License Renewal, at 610-765-5369.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on:
Respectfully, Michael P. Gallagher Vice President - License Renewal Projects Exelon Generation Company, LLC
Enclosure:
LaSalle County Station, Units 1 & 2 Response to NRC License Renewal Environmental Review Request for Additional Information # TR-09 (Revised 8/28/2015) cc: Regional Administrator - NRC Region Ill (w/o Enclosures)
NRC Project Manager (Environmental Review), NRA-DLR (w/o Enclosures)
NRC Project Manager (Safety Review), NRA-DLR (w/o Enclosures)
NRC Project Manager, NRA-DORL LaSalle County Station (w/o Enclosures)
NRC Senior Resident Inspector, LaSalle County Station (w/o Enclosures)
Illinois Emergency Management Agency - Division of Nuclear Safety (w/o Enclosures)
RS-15-235 Enclosure Page 1 of 3 RS-15-235 ENCLOSURE LaSalle County Station, Units 1 & 2 Response to NRC License Renewal Environmental Review Request for Additional Information # TR-09 (Revised 8/28/2015)
RS-15-235 Enclosure Page 2 of 3 THIS PAGE INTENTIONALLY BLANK
RS-15-235 Enclosure Page 3 of 3 LaSalle Environmental Audit Response to Request for Additional Information (Revised 08/28/2015)
Index#: 000 RAI #: TR-09 Category: Transportation Statement of Question:
Provide a revised analysis of incident-free and transportation accident impacts by applying the TRAGIS highway route controlled quantity (HRCQ) option and TRAGIS state-specific distances and population densities in urban, suburban, and rural areas.
The TRAGIS analysis for LSCS to Yucca Mountain was run using the assumption that a commercial route would be used with state-specific distances and generic population densities in urban, suburban, and rural areas. However, prior NRC sponsored or reviewed spent nuclear fuel shipment assessments (e.g., NRC's NUREG-2125 and the Department of Energy's Yucca Mountain EIS) analyzed the routing as a HRCQ shipment as well as applied state-specific distances and population densities in urban, suburban, and rural areas. Both features are available in current online version of TRAGIS.
Response
Exelon Generation has revised both CALC-194-4735-02 and the Transportation Calculation Package using an updated RADTRAN analysis for LSCS high-burnup spent fuel. The revised RADTRAN analysis used routing from WebTRAGIS that specified HRCQ routes - an option not available at the time of the original analysis. The HRCQ routing and associated state-specific distances are presented in the revised CALC-194-4735-02 (CALC-194-4735-02, Revision 1).
State-specific population densities were unavailable because the WebTRAGIS download function was not functioning properly, making the file PopulationDensityByState.csv inaccessible.
In CALC-194-4735-02, Revision 2, two calculations of the total number of exposed persons along the HRCQ transportation route are presented. One uses state- and route-specific population densities from the file "PopulationDensityByState.csv (obtained directly from ORNL personnel after CALC-194-4735-02, Revision 1, was completed because the file was not available from WebTRAGIS). The other uses the assumed population density values entered into the updated RADTRAN analysis, which were based on the definitions specified for the non-state-specific WebTRAGIS population density categories (rural, suburban, urban). Those assumed population density values include the upper ends of the ranges of population density for both the rural and suburban categories. These two categories make up 98 percent of the HRCQ route used in the RADTRAN analysis. Hence, assuming the maximum value for the population density in both cases conservatively estimates the potential consequences to the exposed population, even though the density for the urban category was set at the low end of its range. When the total numbers of exposed persons along the HRCQ transportation route for the two cases are compared in CALC-194-4735-02, Revision 2, the non-state-specific case proved to be conservative by a factor of approximately 2.8. Exelon Generation believes this comparison adequately demonstrates the conservatism of using the non-state-specific population densities based on generic density category definitions for the LaSalle RADTRAN analysis rather than on state-specific densities.