ML22103A244

Attachment - Request for Additional Information - License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled Condition for Indian Point Energy Center

ML22103A244
Person / Time
Site:	Indian Point
Issue date:	04/13/2022
From:	Cruz-Perez Z Reactor Decommissioning Branch
To:	Fleming J Holtec Decommissioning International
Cruz-Perez Z
Shared Package
ML22103A241	List: ML22103A243 ML22103A244
References
Download: ML22103A244 (3)

Text

REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE THE EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME HOLTEC DECOMMISSIONING INTERNATIONAL, LLC INDIAN POINT ENERGY CENTER DOCKET NOS.50-003, 50-247 AND 50-286 By letter dated December 22, 2021, as supplemented by letter dated February 4, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21356B704 and ML22035A121, respectively)), 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 requested license amendments would revise the IPEC Emergency Plan and Emergency Action Level (EAL) scheme for the permanently shutdown and defueled condition at IPEC.

Issue: Enclosure, Description and Evaluation of Proposed Changes, Section 3.2.3, Accidental Release of Waste Gas, states, in part:

The analysis concludes that without crediting any mitigating systems or the Plant Auxiliary Building (PAB) ventilation system, the calculated TEDE to the Control Room is less than the limit set forth in 10 CFR 50.67 and the whole-body dose

value of 500 millirem (mrem) at the EAB. The dose consequences from a waste gas tank decay tank rupture are less than the dose consequences following an FHA and meet the applicable radiological dose criteria at the Control Room, EAB, and Low Population Zone (LPZ) (Reference 14).

Additionally, Section 2.1, Permanently Defueled Facility, of Attachment 2, Permanently Defueled Emergency Action Level Technical Bases Document, states in part, HDI has confirmed that the source term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergency or General Emergency.

However, the NRC staff reviewed the letter dated April 28, 2020, Indian Point Nuclear Generating Unit No. 2 - Issuance of Amendment No. 294 Re: Permanently Defueled Technical Specifications (EPID L-2019-LLA-0079) (ADAMS Accession No. ML20081J402), and it states in part, The calculated radiological consequences following a waste gas decay tank rupture without credit for any mitigating systems or the primary auxiliary building ventilation system post shutdown are as follows:

• Control Room - Whole Body Dose 0.77 rem - under limit of 5 rem;

• EAB - Whole Body Dose 0.30 rem - under limit of 0.5 rem, and

• LPZ - Whole Body Dose 0.11 rem - under limit of 0.5 rem.

Both of these documents reference the same calculation, Calculation IP-CALC-19-00003.

Request: Describe how the elimination of the requirements for a Site Area Emergency, as well as associated emergency action levels, are justified based on the whole body dose at the Exclusion Area Boundary from this accident.

RAI 2.

Issue: Attachment 1, Permanently Defueled Emergency Plan, Section A, Assignment of Responsibility, states, in part:

When an off-normal, natural phenomenon, or accident event becomes apparent, the Shift Manager shall assess the condition; make an emergency declaration, if appropriate; and assume the position of Emergency Director, with the overall

responsibility to direct and control the emergency response. The Emergency Director does not have concurrent duties which conflict with these responsibilities.

However, Attachment 1, Section B.1.1, Normal Plant Organization, identifies one (1) Shift Manager assigned to each unit (IP2 and IP3).

Request: Describe how the Shift Managers would assume the Emergency Director duties for a site event vs. a unit specific event, and where is this direction/instruction documented.

RAI 3.

Issue: Attachment 1 Section E.1.1, Initial Notification, states, in part:

The initial emergency message will include the following information, if it is known and appropriate: [a list is provided]

Request: Describe if the content of the initial, as well as subsequent emergency messages, have been coordinated and agreed upon with the applicable State and local organizations.

RAI 4.

Requirement:

• 10 CFR 50.47(b)(9), as proposed to be exempted, requires, in part that adequate methods, systems, and equipment for assessing and monitoring actual or potential consequences of a radiological emergency condition are in use.

• Associated guidance in NUREG-0654, as modified by NSIR/DPR/ISG-02, Evaluation Criterion I.2 requires, onsite capability and resources to provide initial values and continuing assessment throughout the course of an accident shall include radiation monitors.

Issue: Attachment 1 Section I.2, Dose Assessment, states, in part:

Dose assessment is the responsibility of the Emergency Director and is initially performed by qualified on-shift personnel.

Request: What position on-shift is designated to perform initial dose assessment and is this a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7 days a week position?