VR-SECY-22-0102, Request by Holtec Decommissioning International, LLC for Exemptions from Certain Emergency Planning Requirements for Indian Point Nuclear Generating Unit Nos. 1, 2, and 3 (Crowell)
| ML23296A212 | |
| Person / Time | |
|---|---|
| Issue date: | 10/23/2023 |
| From: | Crowell B NRC/OCM |
| To: | |
| Shared Package | |
| ML23296A196 | List:
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| References | |
| SECY-22-0102 VR-SECY-22-0102 | |
| Download: ML23296A212 (1) | |
Text
POLICY ISSUE NOTATION VOTE RESPONSE SHEET TO:
Brooke P. Clark, Secretary FROM:
Commissioner Crowell
SUBJECT:
SECY-22-0102: Request by Holtec Decommissioning International, LLC for Exemptions from Certain Emergency Planning Requirements for Indian Point Nuclear Generating Unit Nos. 1, 2, and 3 Approved X Disapproved Abstain Not Participating COMMENTS:
Below Attached X
None Signature Entered in STAR Yes X
No Bradley R.
Crowell Digitally signed by Bradley R.
Crowell Date: 2023.10.23 12:19:27 -04'00'
Comments of Commissioner Crowell on SECY-22-0102, Request by Holtec Decommissioning International, LLC for Exemptions from Certain Emergency Planning Requirements for Indian Point Nuclear Generating Unit Nos. 1, 2, and 3 Since 1987, NRC has issued exemptions from dedicated radiological offsite emergency planning (EP) requirements, including emergency planning zones, for nineteen nuclear power plants that transitioned from operations to decommissioning. Because the spectrum of accidents at a decommissioning reactor that can result in significant offsite radiological consequences is reduced as compared to operating reactors, these exemptions were requested to establish a level of EP commensurate with the risk of a radiological emergency at a decommissioning power reactor site.1 However, while the risk of significant offsite radiological consequences is reduced at decommissioning plants, it is not eliminated. Specifically, such risks are present at decommissioning sites before all spent fuel is transitioned to dry cask storage. In such instances, there remains a beyond design basis accident scenario - a major loss of water inventory from the spent fuel pool, followed by heat-up of the spent fuel to the point where substantial zirconium cladding oxidation (fire) and fuel damage can occur.2 The NRC staff acknowledged that, in the early months after a shutdown, the consequences resulting from an accident at a decommissioning reactor can be similar to an accident at an operating reactor because the offsite consequences of a zirconium fire [in the spent fuel pool] may be comparable to those from operating reactor postulated severe accidents.3 The Federal Emergency Management Agency,4 the Conference on Radiation Control Program Directors,5 and the State of New York6 all commented that the NRC should not rely on either the low probability of such an event, or the amount of time (10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />) that might be available between when spent fuel cooling is lost and the hottest fuel reaches 900oC, to replace offsite radiological emergency planning with a more generalized all-hazards approach. Based on these concerns, these commenters recommend that NRC require dedicated radiological emergency planning, including a 10-mile EPZ, until all spent nuclear fuel at a site is removed from the spent fuel pool and placed in passive, dry cask storage. I support this approach, which would provide defense-in-depth to protect the public, while ensuring that FEMA will continue to play its vital role in assessing the adequacy of offsite emergency response plans at decommissioning nuclear power plants. At the Indian Point Energy Center, the licensee has just completed transfer of all spent fuel from spent fuel pools to dry cask storage. For this reason, I approve issuance of the requested emergency planning exemptions.
1 SECY-22-0102 at 2.
2 SECY-22-0102, Enclosure 1 at 1.
3 Draft Regulatory Analysis, Proposed Rule (May 2018) at 42 (ML18012A019).
4 Letter from Jonathan Hoyes, Director, Technical Hazards Division, FEMA to NRC (June 13, 2017).
5 Comment of Conference of Radiation Control Program Directors (June 14, 2017).
6 Comment of New York State Energy Research and Development Authority (Nov. 22, 2022); Comment of New York State Department of Public Service (Jan. 6, 2023).