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| #REDIRECT [[NOC-AE-220039, Clarification on STPNOC Response to Request for Additional Information Regarding Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material]] | | {{Adams |
| | | number = ML22326A296 |
| | | issue date = 11/22/2022 |
| | | title = Clarification on STPNOC Response to Request for Additional Information Regarding Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material |
| | | author name = Harshaw K |
| | | author affiliation = South Texas Project Nuclear Operating Co |
| | | addressee name = |
| | | addressee affiliation = NRC/NRR, NRC/Document Control Desk |
| | | docket = 05000498, 05000499 |
| | | license number = |
| | | contact person = |
| | | case reference number = NOC-AE-22003931, EPID L 2021-LLL-0022 |
| | | document type = Letter, Response to Request for Additional Information (RAI) |
| | | page count = 1 |
| | | project = EPID:L-2021-LLL-0022 |
| | | stage = Response to RAI |
| | }} |
| | |
| | =Text= |
| | {{#Wiki_filter:November 22, 2022 NOC-AE-22003931 10 CFR 20.2002 STI: 35400482 Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Clarification on STPNOC Response to Request for Additional Information Regarding Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material (EPID: L 2021-LLL-0022) |
| | |
| | ==Reference:== |
| | |
| | Letter from K. Harshaw, STPNOC; to NRC; STPNOC Response to Request for Additional Information Regarding Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material (EPID: L 2021-LLL-0022); August 19, 2022; NOC-AE-22003912; ML22231A469. |
| | STP Nuclear Operating Company (STPNOC) submitted the letter referenced in response to NRC requests for additional information (RAI) regarding STPNOCs request for approval of alternate disposal procedures for very low-level radioactive material. Attachment 1 clarifies and updates information provided in the STPNOC RAI response regarding the total disposal volume being requested and the list of potentially included radionuclides and their limiting concentrations and activity. |
| | There are no commitments in this letter. |
| | If there are any questions regarding this letter, please contact Zachary Dibbern at (361) 972-4336 or me at (361) 972-4778. |
| | I declare under penalty of perjury that the foregoing is true and correct. |
| | Executed on _______________________ |
| | Kimberly A. Harshaw Executive VP and CNO Attachments: |
| | : 1. STPNOC Clarification on Total Disposal Volume and List of Radionuclides |
| | : 2. Revised RESRAD Summary Report for Onsite of the Generic Landfill |
| | |
| | NOC-AE-22003931 Page 2 of 2 cc: |
| | Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511 Dennis Galvin Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Licensing Project Branch 4 Gregory Kolcum Senior Resident Inspector, South Texas Project U.S. Nuclear Regulatory Commission Chad Stott Resident Inspector, South Texas Project U.S. Nuclear Regulatory Commission |
| | |
| | NOC-AE-22003931 Attachment 1 Attachment 1 STPNOC Clarification on Total Disposal Volume and List of Radionuclides |
| | |
| | NOC-AE-22003931 Attachment 1 Page 1 of 2 STPNOC Clarification on Total Disposal Volume and List of Radionuclides Total Disposal Volume STPNOC is requesting approval to dispose of a total volume of 5,000 cubic meters of very low-level radioactive material over the lifetime of this request. |
| | Revised Response to RAI-3.a STPNOC is revising the response to RAI-3.a, previously submitted in the {{letter dated|date=August 19, 2022|text=August 19, 2022 letter}}, to include additional potential radionuclides that may be present in shipments. STPNOC is specifying an administrative concentration limit for each radionuclide as part of this 10 CFR 20.2002 Alternate Disposal Procedure request. Also listed for each radionuclide are the corresponding limiting concentrations and activity per the Texas Administrative Code (TAC). |
| | : a. Provide a summary of the input parameters for the sites being considered for disposal under the requested action and resulting doses from the RESRAD [RESidual RADioactive]-ONSITE and RESRAD-OFFSITE analyses (these could be the summary reports) as well as any other technical analyses performed for this submittal. Also provide the basis for considering specific modeling assumptions used in these calculations. |
| | STP Response: |
| | List of Potential Radionuclides, Concentration Limits, and The list of potential Activity Limits radionuclides and their limiting concentrations and activity STP TAC limits are provided in the table Potential Administrative TAC Activity Concentration on the right titled List of Isotopes Concentration Limit pCi Potential Radionuclides, Limit pCi/gm Limit pCi/gm Concentration Limits, and Be7 1.00E+00 2.0E+04 None Activity Limits. This table C14 1.00E+00 8.0E+03 1.00E+08 includes the expected radionuclides that have been Co57 1.00E+00 5.0E+03 1.00E+08 detected in previous Co58 1.00E+00 1.0E+03 1.00E+07 shipments as well as Co60 5.00E-01 1.00E+06 5.0E+02 additional radionuclides that are not necessarily expected Cr51 2.00E+00 2.0E+04 1.00E+09 but could potentially be Cs137 1.50E-01 None 1.00E+07 included in the future. Fe55 1.00E+01 8.0E+03 1.00E+08 H3 2.00E+01 3.0E+04 1.00E+09 Radionuclides not listed or in excess of the STP Mn54 1.00E+00 1.0E+03 1.00E+07 Administrative Concentration Ni63 6.00E+00 None 1.00E+07 Limits in the List of Potential Sb125 4.00E+00 1.0E+03 1.00E+07 Radionuclides, Concentration 1.00E-05 1.00E+05 Sr90 None Limits, and Activity Limits would not be included in any Zn65 1.00E+00 1.0E+03 1.00E+07 shipments allowed by this Zr95 1.00E+00 6.0E+02 1.00E+07 request. |
| | |
| | NOC-AE-22003931 Attachment 1 Page 2 of 2 See Attachment 2, Revised RESRAD Summary Report for Onsite of the Generic Landfill, for the input parameters. Note that the input parameters for the Revised RESRAD Summary Report are based on the expected average shipment. |
| | The basis for the specific modeling assumptions were developed from a generic landfill based in Southeast Texas. The parameters for disposal of waste at this generic site were used, and from these parameters conservative assumptions were used to demonstrate compliance. Any landfill used for disposal of the very low-level radioactive waste would be analyzed to meet these bases. |
| | For activities occurring offsite, RESRAD calculations were performed to verify anticipated dose to a member of the public, landfill workers, and drivers were below 5 mrem per year, which is lower than the minimum of 100 mrem/hr required in 10 CFR 20.1301. Specific considerations were incorporated into RESRAD where appropriate for local pathways. |
| | Overall, potential dose and health impacts to the public and to workers from the disposal activities are expected to be small and maintained ALARA. |
| | |
| | NOC-AE-22003931 Attachment 2 Attachment 2 Revised RESRAD Summary Report for Onsite of the Generic Landfill}} |
Letter Sequence Response to RAI |
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EPID:L-2021-LLL-0022, (CPNPP) - Relief Request 1A4-3 for Continued Use of a Risk-Informed Process as an Alternative for the Selection of Class 1 and 2 Piping Welds for Unit 1 Inservice Inspection (Open) |
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Category:Letter
MONTHYEARIR 05000498/20240022024-08-0909 August 2024 Integrated Inspection Report 05000498/2024002 and 05000499/2024002 IR 05000498/20240102024-08-0808 August 2024 Biennial Problem Identification and Resolution Inspection Report 05000498/2024010 and 05000499/2024010 NOC-AE-240040, Application for Order Consenting to Direct Transfer of Licenses2024-07-31031 July 2024 Application for Order Consenting to Direct Transfer of Licenses ML24218A1462024-07-26026 July 2024 2. EPA Comments on South Texas Project Exemption Ea/Fonsi ML24207A1782024-07-25025 July 2024 Licensed Operator Positive Fitness-For-Duty Test IR 05000498/20244042024-06-0303 June 2024 Cyber Security Inspection Report 05000498/2024404 (Cover Letter) ML24141A0482024-05-17017 May 2024 EN 56958_1 Ametek Solidstate Controls, Inc ML24136A2842024-05-15015 May 2024 Independent Spent Fuel Storage Installation Supplement to Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance ML24136A2872024-05-15015 May 2024 Submittal of 2024 Nrc/Fema Evaluated Exercise Scenario Manual NOC-AE-240040, Operator Licensinq Examination Schedule Revision 32024-05-15015 May 2024 Operator Licensinq Examination Schedule Revision 3 ML24128A1572024-05-0707 May 2024 Independent Spent Fuel Storage Installation Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance IR 05000498/20240012024-05-0606 May 2024 Integrated Inspection Report 05000498/2024001 & 05000499/2024001 ML24116A3032024-04-25025 April 2024 Operations Quality Assurance Plan Condition Adverse to Quality Definition Change Resulting in a Reduction in Commitment ML24116A2282024-04-25025 April 2024 Annual Environmental Operating Report ML24117A1602024-04-24024 April 2024 2023 Radioactive Effluent Release Report ML24102A2452024-04-23023 April 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0046 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML24113A3122024-04-22022 April 2024 Cycle 24 Core Operating Limits Report NOC-AE-240040, Relief Request Number RR-ENG-4-07 – Request for an Alternative to ASME Code Case N-729-6 for Reactor Vessel Head Penetration 752024-04-0606 April 2024 Relief Request Number RR-ENG-4-07 – Request for an Alternative to ASME Code Case N-729-6 for Reactor Vessel Head Penetration 75 NOC-AE-240040, Financial Assurance for Decommissioning - 2024 Update2024-03-28028 March 2024 Financial Assurance for Decommissioning - 2024 Update ML24081A3972024-03-21021 March 2024 Response to Request for Additional Information for Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML24080A2902024-03-19019 March 2024 Nuclear Liability Certificates of Insurance ML24079A1312024-03-0505 March 2024 Nuclear Insurance Protection ML24060A1742024-02-28028 February 2024 Submittal of Annual Fitness for Duty Performance Report for 2023 IR 05000498/20230062024-02-28028 February 2024 Annual Assessment Letter for South Texas Project Electric Generating Station, Units 1 and 2 (Report 05000498/2023006 and 05000499/2023006) IR 05000498/20240132024-02-27027 February 2024 Design Basis Assurance Inspection (Programs) Commercial Grade Dedication IR 05000498/2024013 and 05000499/2024013 ML24050A0082024-02-19019 February 2024 Evidence of Financial Protection ML24045A0922024-02-16016 February 2024 Response to STP FOF Move Letter (2024) NOC-AE-240040, Unit L & 2, Supplement to Modify the Implementation Date for License Amendment Request to Revise Alternate Source Term Dose Calculation2024-02-0808 February 2024 Unit L & 2, Supplement to Modify the Implementation Date for License Amendment Request to Revise Alternate Source Term Dose Calculation ML24039A1112024-02-0808 February 2024 Operator Licensing Examination Schedule Revision 2 ML24038A3342024-02-0707 February 2024 Change to South Texas Project Electric Generating Station (Stepgs) Emergency Plan ML24033A3002024-02-0707 February 2024 Summary of Regulatory Audit Regarding a Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections ML24029A2752024-01-29029 January 2024 Request to Reschedule Evaluated Force-on-Force Drill IR 05000498/20230042024-01-29029 January 2024 Integrated Inspection Report 05000498/2023004 and 05000499/2023004 ML24024A1162024-01-24024 January 2024 STP Unit 2 Request for Information IR 05000498/20230032023-12-28028 December 2023 Acknowledgment of Reply to a Notice of Violation (NRC Inspection Report 05000498/2023003 and 05000499/2023003) ML23360A1692023-12-26026 December 2023 FEMA, Submittal of Radiological Emergency Preparedness Final Report for the South Texas Project Medical Services Drill Evaluated on August 31, 2023 NOC-AE-230040, Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06)2023-12-14014 December 2023 Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06) NOC-AE-230039, Docket Nos. Stn 50-498, Stn 50-499 - Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/20230032023-12-12012 December 2023 Docket Nos. Stn 50-498, Stn 50-499 - Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/2023003 ML23339A1902023-12-0505 December 2023 Update Foreign Ownership, Control, or Influence (FOCI) ML23326A2592023-12-0505 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report IR 05000498/20234012023-12-0404 December 2023 Security Baseline Inspection Report 05000498/2023401 and 05000499/2023401 ML23324A0102023-11-16016 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23310A2282023-11-13013 November 2023 Integrated Inspection Report 05000498/2023003 and 05000499/2023003, and Notice of Violation ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23298A0002023-11-0101 November 2023 the Associated Independent Spent Fuel Storage Installation - Issuance of Amendment Nos. 226 and 211 Related to Order Approving Indirect Transfer of Licenses and Conforming License Amendments ML23279A0342023-10-30030 October 2023 Associated Independent Spent Fuel Storage Installation - Order Approving Indirect Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0004) (Letter) ML23303A0782023-10-30030 October 2023 Submittal of Supplemental Information in Response to Order Consenting to License Transfers and Approval of Draft Conforming License Amendments IR 05000498/20234032023-10-26026 October 2023 Material Control and Accounting Program Inspection Report 05000498/2023403 and 05000499/2023403 (Cover Letter) ML23317A1262023-10-12012 October 2023 South. Texas Project Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program Revision 26 ML23279A1382023-10-0505 October 2023 Responses to Requests for Additional Information Related to Application for Order Approving Indirect Transfer of Control of Licenses 2024-08-09
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML24081A3972024-03-21021 March 2024 Response to Request for Additional Information for Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML22326A2962022-11-22022 November 2022 Clarification on STPNOC Response to Request for Additional Information Regarding Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material ML22244A1152022-09-0101 September 2022 Response to NRC Comments on Relief Request RR-ENG-3-25 ML22231A4692022-08-19019 August 2022 STPNOC Response to Request for Additional Information Regarding Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material ML22091A3082022-04-0101 April 2022 Supplement to Request for Exemption from Certificate of Compliance (CoC) Inspection Requirement for One Multipurpose Canister ML21308A6032021-11-0404 November 2021 Response to End of Enforcement Discretion and Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material NOC-AE-21003846, Response to End of Enforcement Discretion and Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material2021-11-0404 November 2021 Response to End of Enforcement Discretion and Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material ML21067A7722021-03-0808 March 2021 Response to Request for Additional Information Regarding 1RE22 Inspection Summary Report for Steam Generator Tubing NOC-AE-21003784, Response to Request for Additional Information Regarding 1RE22 Inspection Summary Report for Steam Generator Tubing2021-03-0808 March 2021 Response to Request for Additional Information Regarding 1RE22 Inspection Summary Report for Steam Generator Tubing ML20154K7652020-06-0202 June 2020 Supplemental Response Regarding Bulletin 2012-01 NOC-AE-20003735, Supplemental Response Regarding Bulletin 2012-012020-06-0202 June 2020 Supplemental Response Regarding Bulletin 2012-01 NOC-AE-20003733, Response to Request for Additional Information for Proposed Alternatives to ASME OM Code 2012 Edition for the Fourth Inservice Test Interval (Relief Request PRR-01)2020-05-18018 May 2020 Response to Request for Additional Information for Proposed Alternatives to ASME OM Code 2012 Edition for the Fourth Inservice Test Interval (Relief Request PRR-01) ML20139A2162020-05-18018 May 2020 Response to Request for Additional Information for Proposed Alternatives to ASME OM Code 2012 Edition for the Fourth Inservice Test Interval (Relief Request PRR-01) NOC-AE-20003716, Request for Additional Information for Proposed Alternative to ASME Section XI Requirements for the Repair/Replacement of Essential Cooling Water System Class 3 Buried Piping2020-03-0909 March 2020 Request for Additional Information for Proposed Alternative to ASME Section XI Requirements for the Repair/Replacement of Essential Cooling Water System Class 3 Buried Piping ML20069L4992020-03-0909 March 2020 Request for Additional Information for Proposed Alternative to ASME Section XI Requirements for the Repair/Replacement of Essential Cooling Water System Class 3 Buried Piping NOC-AE-19003673, Response to Request for Additional Information for South Texas Project (STP) Units 1 & 2 License Amendment Request to Revise Technical Specification 3.8.1.1 (A.C. Sources, Operating) (L-2018-LLA-00782019-06-25025 June 2019 Response to Request for Additional Information for South Texas Project (STP) Units 1 & 2 License Amendment Request to Revise Technical Specification 3.8.1.1 (A.C. Sources, Operating) (L-2018-LLA-0078 NOC-AE-19003637, Supplement to South Texas Project (STP) Units 1 & 2 License Amendment Request to Revise Technical Specification 3.8.1.1 (A.C. Sources, Operating) (L-2018-LLA-0078)2019-05-16016 May 2019 Supplement to South Texas Project (STP) Units 1 & 2 License Amendment Request to Revise Technical Specification 3.8.1.1 (A.C. Sources, Operating) (L-2018-LLA-0078) NOC-AE-18003602, Response to Request for Additional Information for License Amendment Request to Revise Technical Specification 3.8.1.1 (A.C. Sources, Operating)2018-12-0606 December 2018 Response to Request for Additional Information for License Amendment Request to Revise Technical Specification 3.8.1.1 (A.C. Sources, Operating) NOC-AE-18003598, Response to Request for Additional Information Request for Relief from the Third 10-Year Interval ISI Program ASME Section Xl Code Requirements for Category B-N-2 and B-N-3 Welds (Relief Request RR-ENG-3-16)2018-09-26026 September 2018 Response to Request for Additional Information Request for Relief from the Third 10-Year Interval ISI Program ASME Section Xl Code Requirements for Category B-N-2 and B-N-3 Welds (Relief Request RR-ENG-3-16) NOC-AE-18003574, Response to Request for Additional Information Regarding Request for Exemption from 10 CFR 55.472018-05-21021 May 2018 Response to Request for Additional Information Regarding Request for Exemption from 10 CFR 55.47 NOC-AE-17003441, Revised Response Request for Additional Information for the Review of the South Texas Project License Renewal Application2017-02-0909 February 2017 Revised Response Request for Additional Information for the Review of the South Texas Project License Renewal Application NOC-AE-17003434, Response to Request for Additional Information on Revised Applicability Matrix for Questions Regarding Risk-Informed GSI-191 Licensing Application2017-01-19019 January 2017 Response to Request for Additional Information on Revised Applicability Matrix for Questions Regarding Risk-Informed GSI-191 Licensing Application NOC-AE-17003435, Response to NRC Security Reactive Inspection Report 05000498/2016407, 05000499/2016407, EA-16-2502017-01-19019 January 2017 Response to NRC Security Reactive Inspection Report 05000498/2016407, 05000499/2016407, EA-16-250 IR 05000498/20164072017-01-19019 January 2017 South Texas Project, Units 1 and 2 - Response to NRC Security Reactive Inspection Report 05000498/2016407, 05000499/2016407, EA-16-250 NOC-AE-16003428, Response to Request for Additional Information for the Review of License Renewal Application2017-01-12012 January 2017 Response to Request for Additional Information for the Review of License Renewal Application NOC-AE-16003429, Response to Requests for Additional Information for Review License Renewal Application - RAI 82.1.8-32017-01-0505 January 2017 Response to Requests for Additional Information for Review License Renewal Application - RAI 82.1.8-3 NOC-AE-16003427, Revised Applicability Matrix for Response to Request for Additional Information Questions APLA-1a and APLA-1b Regarding STP Risk-Informed GSl-191 Licensing Application2016-12-0707 December 2016 Revised Applicability Matrix for Response to Request for Additional Information Questions APLA-1a and APLA-1b Regarding STP Risk-Informed GSl-191 Licensing Application ML16321A4072016-11-0909 November 2016 Response to Request for Additional Information Regarding Sensitivity Studies for STPNOC Risk-Informed Pilot GSl-191 Application NOC-AE-16003356, Flooding Mitigating Strategies Assessment (MSA) Report Submittal2016-09-29029 September 2016 Flooding Mitigating Strategies Assessment (MSA) Report Submittal NOC-AE-16003404, Response to Request for Additional Information for the Review of License Renewal Severe Accident Mitigation Alternatives2016-09-27027 September 2016 Response to Request for Additional Information for the Review of License Renewal Severe Accident Mitigation Alternatives NOC-AE-16003412, Revised Response to Request for Additional Information APLA-4-4 STP Risk-Informed GSI-191 Licensing Application2016-09-12012 September 2016 Revised Response to Request for Additional Information APLA-4-4 STP Risk-Informed GSI-191 Licensing Application NOC-AE-16003394, Additional Information for the Review of the South Texas Project, Units 1 and 2, License Renewal Application - Aluminum Bronze AMP (TAC Nos. ME4936 and ME4937)2016-07-28028 July 2016 Additional Information for the Review of the South Texas Project, Units 1 and 2, License Renewal Application - Aluminum Bronze AMP (TAC Nos. ME4936 and ME4937) ML16230A2322016-07-21021 July 2016 Responses to Apla Round 4 Requests for Additional Information Regarding STP Risk-Informed GSl-191 Licensing Application NOC-AE-16003395, Third Set of Responses to Requests for Additional Information STP Risk-Informed GSI-191 Licensing Application2016-07-21021 July 2016 Third Set of Responses to Requests for Additional Information STP Risk-Informed GSI-191 Licensing Application NOC-AE-16003368, Third Sets of Responses to April 11, 2016 Requests for Additional Information Regarding STP Risk-Informed GSI-191 Licensing Application2016-07-18018 July 2016 Third Sets of Responses to April 11, 2016 Requests for Additional Information Regarding STP Risk-Informed GSI-191 Licensing Application NOC-AE-16003328, Second Supplement to Response to RAI for Information Pursuant to 10 CFR 50.54(f) Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident: Phase 2 Staffing Assessment2016-06-30030 June 2016 Second Supplement to Response to RAI for Information Pursuant to 10 CFR 50.54(f) Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident: Phase 2 Staffing Assessment NOC-AE-16003367, Second Set of Responses to April 11, 2016 Requests for Additional Information Regarding Risk-Informed GSI-191 Licensing Application2016-06-16016 June 2016 Second Set of Responses to April 11, 2016 Requests for Additional Information Regarding Risk-Informed GSI-191 Licensing Application NOC-AE-16003380, Request for Additional Information Set 35 for the Review of the South Texas Project, Units 1 and 2, License Renewal Application (TAC Nos. ME4936 and ME4937)2016-05-19019 May 2016 Request for Additional Information Set 35 for the Review of the South Texas Project, Units 1 and 2, License Renewal Application (TAC Nos. ME4936 and ME4937) NOC-AE-16003366, First Set of Responses to April 11, 2016 Requests for Additional Information Regarding STP Risk-Informed GSl-191 Licensing Application2016-05-11011 May 2016 First Set of Responses to April 11, 2016 Requests for Additional Information Regarding STP Risk-Informed GSl-191 Licensing Application NOC-AE-16003357, Revision to Proposed Exemption to 10CFR50.46 Described in Pilot Submittal and Requests for Exemptions and License Amendment for a Risk-Informed Approach to Address Generic Safety Issue (GSl)-191 and Respond To..2016-04-13013 April 2016 Revision to Proposed Exemption to 10CFR50.46 Described in Pilot Submittal and Requests for Exemptions and License Amendment for a Risk-Informed Approach to Address Generic Safety Issue (GSl)-191 and Respond To.. NOC-AE-16003347, Response to Request for Additional Information Regarding the License Amendment Request for Extension of Containment Leakage Rate Testing Program2016-03-17017 March 2016 Response to Request for Additional Information Regarding the License Amendment Request for Extension of Containment Leakage Rate Testing Program NOC-AE-16003348, Response to Request for Additional Information for License Renewal Application 2014 Annual Update (Tac. Nos. ME4936 and ME4937)2016-03-10010 March 2016 Response to Request for Additional Information for License Renewal Application 2014 Annual Update (Tac. Nos. ME4936 and ME4937) NOC-AE-15003320, Response to Request for Additional Information Set 34 for the Review of the License Renewal Application2015-12-17017 December 2015 Response to Request for Additional Information Set 34 for the Review of the License Renewal Application NOC-AE-15003318, Response to Request for Additional Information and Supplement to Emergency License Amendment Request to Revise Technical Specification 5.3.2 to Allow Operation with 56 Full-Length Control Rod Assemblies for Cycle 202015-12-0909 December 2015 Response to Request for Additional Information and Supplement to Emergency License Amendment Request to Revise Technical Specification 5.3.2 to Allow Operation with 56 Full-Length Control Rod Assemblies for Cycle 20 NOC-AE-15003303, Response to Request for Additional Information for the Review of the License Renewal Application - Set 322015-11-12012 November 2015 Response to Request for Additional Information for the Review of the License Renewal Application - Set 32 NOC-AE-15003296, Request for Additional Information Regarding the License Amendment Request for Extension of Containment Leakage Rate Testing Program2015-10-0808 October 2015 Request for Additional Information Regarding the License Amendment Request for Extension of Containment Leakage Rate Testing Program ML15251A2492015-10-0505 October 2015 Summary of Telephone Conference Call Held on August 6, 2015, Between the U.S. Nuclear Regulatory Commission and STP Nuclear Operating Company, Concerning Request for Additional Information, Set 32, Pertaining to the South Texas Project, Lic ML15246A1282015-08-20020 August 2015 Attachment 1-5 Response to 2009 RAIs Through 1-6 Responses to Round 2 RAIs NOC-AE-15003278, Response to Request for Additional Information for the Review of License Renewal Application - Set 312015-07-29029 July 2015 Response to Request for Additional Information for the Review of License Renewal Application - Set 31 NOC-AE-15003276, Response to Request for Additional Information Regarding Relief Request RR-ENG-3-17 Regarding Deferral of Inservice Inspection of Reactor Pressure Vessel Cold Leg Nozzle Dissimilar Metal Butt Welds2015-07-22022 July 2015 Response to Request for Additional Information Regarding Relief Request RR-ENG-3-17 Regarding Deferral of Inservice Inspection of Reactor Pressure Vessel Cold Leg Nozzle Dissimilar Metal Butt Welds 2024-03-21
[Table view] |
Text
November 22, 2022 NOC-AE-22003931 10 CFR 20.2002 STI: 35400482 Attention: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 Clarification on STPNOC Response to Request for Additional Information Regarding Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material (EPID: L 2021-LLL-0022)
Reference:
Letter from K. Harshaw, STPNOC; to NRC; STPNOC Response to Request for Additional Information Regarding Request for Approval of Alternate Disposal Procedures for Very Low-Level Radioactive Material (EPID: L 2021-LLL-0022); August 19, 2022; NOC-AE-22003912; ML22231A469.
STP Nuclear Operating Company (STPNOC) submitted the letter referenced in response to NRC requests for additional information (RAI) regarding STPNOCs request for approval of alternate disposal procedures for very low-level radioactive material. Attachment 1 clarifies and updates information provided in the STPNOC RAI response regarding the total disposal volume being requested and the list of potentially included radionuclides and their limiting concentrations and activity.
There are no commitments in this letter.
If there are any questions regarding this letter, please contact Zachary Dibbern at (361) 972-4336 or me at (361) 972-4778.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on _______________________
Kimberly A. Harshaw Executive VP and CNO Attachments:
- 1. STPNOC Clarification on Total Disposal Volume and List of Radionuclides
- 2. Revised RESRAD Summary Report for Onsite of the Generic Landfill
NOC-AE-22003931 Page 2 of 2 cc:
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511 Dennis Galvin Project Manager U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Licensing Project Branch 4 Gregory Kolcum Senior Resident Inspector, South Texas Project U.S. Nuclear Regulatory Commission Chad Stott Resident Inspector, South Texas Project U.S. Nuclear Regulatory Commission
NOC-AE-22003931 Attachment 1 Attachment 1 STPNOC Clarification on Total Disposal Volume and List of Radionuclides
NOC-AE-22003931 Attachment 1 Page 1 of 2 STPNOC Clarification on Total Disposal Volume and List of Radionuclides Total Disposal Volume STPNOC is requesting approval to dispose of a total volume of 5,000 cubic meters of very low-level radioactive material over the lifetime of this request.
Revised Response to RAI-3.a STPNOC is revising the response to RAI-3.a, previously submitted in the August 19, 2022 letter, to include additional potential radionuclides that may be present in shipments. STPNOC is specifying an administrative concentration limit for each radionuclide as part of this 10 CFR 20.2002 Alternate Disposal Procedure request. Also listed for each radionuclide are the corresponding limiting concentrations and activity per the Texas Administrative Code (TAC).
- a. Provide a summary of the input parameters for the sites being considered for disposal under the requested action and resulting doses from the RESRAD [RESidual RADioactive]-ONSITE and RESRAD-OFFSITE analyses (these could be the summary reports) as well as any other technical analyses performed for this submittal. Also provide the basis for considering specific modeling assumptions used in these calculations.
STP Response:
List of Potential Radionuclides, Concentration Limits, and The list of potential Activity Limits radionuclides and their limiting concentrations and activity STP TAC limits are provided in the table Potential Administrative TAC Activity Concentration on the right titled List of Isotopes Concentration Limit pCi Potential Radionuclides, Limit pCi/gm Limit pCi/gm Concentration Limits, and Be7 1.00E+00 2.0E+04 None Activity Limits. This table C14 1.00E+00 8.0E+03 1.00E+08 includes the expected radionuclides that have been Co57 1.00E+00 5.0E+03 1.00E+08 detected in previous Co58 1.00E+00 1.0E+03 1.00E+07 shipments as well as Co60 5.00E-01 1.00E+06 5.0E+02 additional radionuclides that are not necessarily expected Cr51 2.00E+00 2.0E+04 1.00E+09 but could potentially be Cs137 1.50E-01 None 1.00E+07 included in the future. Fe55 1.00E+01 8.0E+03 1.00E+08 H3 2.00E+01 3.0E+04 1.00E+09 Radionuclides not listed or in excess of the STP Mn54 1.00E+00 1.0E+03 1.00E+07 Administrative Concentration Ni63 6.00E+00 None 1.00E+07 Limits in the List of Potential Sb125 4.00E+00 1.0E+03 1.00E+07 Radionuclides, Concentration 1.00E-05 1.00E+05 Sr90 None Limits, and Activity Limits would not be included in any Zn65 1.00E+00 1.0E+03 1.00E+07 shipments allowed by this Zr95 1.00E+00 6.0E+02 1.00E+07 request.
NOC-AE-22003931 Attachment 1 Page 2 of 2 See Attachment 2, Revised RESRAD Summary Report for Onsite of the Generic Landfill, for the input parameters. Note that the input parameters for the Revised RESRAD Summary Report are based on the expected average shipment.
The basis for the specific modeling assumptions were developed from a generic landfill based in Southeast Texas. The parameters for disposal of waste at this generic site were used, and from these parameters conservative assumptions were used to demonstrate compliance. Any landfill used for disposal of the very low-level radioactive waste would be analyzed to meet these bases.
For activities occurring offsite, RESRAD calculations were performed to verify anticipated dose to a member of the public, landfill workers, and drivers were below 5 mrem per year, which is lower than the minimum of 100 mrem/hr required in 10 CFR 20.1301. Specific considerations were incorporated into RESRAD where appropriate for local pathways.
Overall, potential dose and health impacts to the public and to workers from the disposal activities are expected to be small and maintained ALARA.
NOC-AE-22003931 Attachment 2 Attachment 2 Revised RESRAD Summary Report for Onsite of the Generic Landfill