Text

Enclosure 7: Draft RAI Responses to RAIs NP-2.2.1, NP-2.2-2 and EP-X (Non-Proprietary Version)
	ML19073A253
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	03/12/2019
From:	; Consolidated Interim Storage Facility
To:	; Division of Spent Fuel Management
Shared Package
ML19073A272	List: ML19073A251; ML19073A252; ML19073A253;
References
	E-53819
	Download: ML19073A253 (66)
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Enclosure 7 Draft RAI Responses to RAls NP-2.2-1, NP-2.2-2 and EP-X (Non-Proprietary Version)

RAls and Responses Safety Analysis Report (SAR), Chapter 2, "Site Characteristics" RAI NP-2.2-1:

Enclosure X to E-XXXX Provide an evaluation and aircraft crash probability impact analysis of airway Vll8, ich passes nearby the proposed WCS CISF, in accordance with guidance and accepta ce r1teria provided in NUREG-1567, Section 2.4.2.

Response to RAI NP-2.2-1:

.8 have been revised as described in the response.

has been added as described in the response.

SAR Table 2-14, Table 2-15, Table 2-16, Table 2-17, Table 2-18, and Table 2-19 have been added as described in the response.

SAR Figure 2-38, Figure 2-39, and Figure 2-40 have been added as described in the response.

Page 1 of 116

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.2 Nearby Industrial, Transportation and Military Facilities The only industrial facilities located within five miles of the WCS CISF boundary are URENCO USA, Permian Basin Materials, the Lea County landfill, a future travel stop and Sundance Services, Inc. (Figure 2-3). URENCO USA is a uranium richment facility that uses centrifuge technology to provide uranium enrichme Waste Control Specialists operates several permitted and licensed immediately south of the WCS CISF, including a RCRA landfi radioactive waste facility and a byproduct materials landfill.

Permian Basin Materials operates a quarry and crush in o sand and gravel are mined, crushed and screened fo making concrete (Permian, 2016[2-29]). Sundan waste disposal services. Sundance Services is Minerals and Natural Resources Departme and also manages produced water, solids a authorized to landfarm solids (Sundance, 201 ted to the southwest and dfill disposes of under New Mexico andfill services Lea andfill does not generate operated by Love's Travel Stops & Country exico State Highway 18 and Hwy 176.

ohway vehicles, is located more than 3.5

*ties within a mile of the WCS CISF. The closest military rce Base is the closest at a distance of approximately 135 ew Mexico Railway (TXN) is a railway consisting of 111 miles of erally run north-south between the Union Pacific lines in Monahans, its termination in Lovington, New Mexico. The railway is 4.8 miles from CISF at its closest point. The existing Waste Control Specialists railroad sp and loop exits the Texas & New Mexico Railway near Eunice, New Mexico as shown in Figure 2-3. This spur continues east until it reaches the existing Waste Control Specialists facility where it forms a loop around the facility. The rail side track to the WCS CISF will begin by connecting to the northwest side of the existing loop and terminate by re-connecting at the north side of the loop.

Page 2-5

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Texas State Highway 176 is a two-lane highway with 3.6 m (12 foot) wide driving lanes, 2.4 m (8 foot) wide shoulders and a 61 m (200 foot) wide right-of-way easement on each side. Access to the site is directly off of Texas State Highway 176. Texas State Highway 176 is approximately 1.5 miles from the WCS CISF. New Mexico Highway 18 is a four-lane highway approximately 3.5 miles from the CISF.

A natural gas pipeline owned by Energy Transfer LP runs parallel Highway 176 within an easement on Waste Control Specialists is approximately 7,700 feet from the WCS CISF at its close to and parallel to the Energy Transfer LP natural gas pipe

14 inch diameter pipeline which is in idle status. The Energy Transfer LP and it has been idle for over 15 buried CO2 pipeline runs along the western and Section 32. This pipeline is over 8,000 feet fr In addition to industrial and transportation common in west Texas. Regionally, the WC west Texas and southeast New Mexico which is field operations are ed in the Permian Basin of rty boundaries, oil and ity within the WCS e immediate area of the producing regions in the United

[2-56]. Significant petroleum WCS CISF. Locally within tH gas activity also is very limited.

CISF footprint area and only one WCS CISF (Figure 2-36). That d een ce ed to the surface and proper plugging and a undocumen borehole served. There is no evidence of any icinity of the WCS CISF. If any open

scovered during the construction process, ted using proper plugging and Texas Regulations. ISP joint venture olds 100% of the Operating Rights for nd other minera s for the area of land where the storage pads for re phases of the WCS CISF would be located. These rights allow ber Waste Control Specialists to prevent any drilling (horizontal pads for oil, gas, and other minerals. Based on Figure 2-36, cation Yo) are dry or no longer producing, which indicates there is lly viab e oil and gas resources within 1 mile of the WCS CISF and leum recovery activities in this area are unlikely. As explained in

.6.2 and in the Probabilistic Seismic Hazard Analysis in Attachment D er 2, it was determined there is a relatively low seismic hazard at the rol Specialists site even with petroleum recovery activities.

hapter 12 Section 12.2 provides evaluations of the potential hazards these faci ities present to the WCS CISF.

Page 2-6

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.2.1 Aircraft Hazard Evaluation ISP performed an aircraft hazards evaluation for the WCS CISF to demonstrate adequate assurance that the risks from aircraft hazards are sufficiently low. NRC regulations pertaining to siting evaluation, 10 CFR 72.90, require that p osed spent fuel storage installations be examined with respect to the frequency erity of external natural and man-induced events that could affect the safe tion of the facility. The NRC accepts that spent fuel storage installations d eed to be designed to withstand aircraft crashes ifthere is less than on

lion (1 x 10-6) annual probability of occurrence [2-42].

For the WCS CISF aircraft hazard evaluation, relev Review Plan NUREG 0800 (Section 3.5.1.6-Airc Although NUREG 0800 is intended for light-estimating aircraft hazard is considered to b This evaluation considers nearby airports, fe patterns, military airports, training routes, and tr taken from a 10 nautical mile (12 mile) radius oftli' year period (2017-2018) was and used to oo frequencies. Airport and airw information available from the of the WCS CISF in the three co olding and approach as. Recorded flight data, CISF, over a recent two-deral airway flight flight map ports within 50 miles

, Gaines County TX and ere i e

d. There is no military base

. Federal airway and military training route Instrument Flight Rules (IFR) Enroute is evaluation, the protected area boundary (0.06 square miles) for phase 1 of this

.21 square miles) of the protected area, es that will be added for the anticipated seven 3.5.1.6 provides proximity screening criteria for evaluating f aircraft crash is less than an order of magnitude to 1 OE-7 WCS CISF site has two Federal airways that pass near ite (V6 and Q20), the conservative NUREG 0800 screening criteria

. In this case, NUREG 0800 states that a detailed review of aircraft rmed. The review seeks a description of aviation uses in the airspace sed site, including airports and approach paths, Federal airways, ays, and military uses.

0800 Section 3.5.1.6 also provides acceptable methods for calculating the pro ability per year of an aircraft crashing into the plant. The evaluation considers in-flight crash rate per mile, width of airway, number of flights per year along the airway, and effective area of the site. Similarly, the evaluation considers civilian and military airport locations. The details of the evaluation are described in the sections below.

Page 2-7

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Jnterim 2.2.1.1 Site Description The WCS CISF has a protected area boundary of 36 acres (0.06 square miles) which contains the Security and Administration Building, the Cask Handling Building and the Storage Area where the cask shipments arrive, and the canisters are loaded and placed into storage. As indicated above, for this evaluation, the prot boundary was increased to 130 acres (0.21 square miles), effectiv future seven phases of the project. Therefore, this evaluation is actual protected area boundary is only 28% of the effective evaluation. The concrete storage casks, which contain ca

on concrete pads located within the protected area bou ar. The robus dry cask storage systems that will be within the pro additional defense-in-depth against radiological (air-cooled) and designed to provide physical 2.2.1.2 Nearby Federal Airways airways within a 10 nautical flight plans are limited to the structure of the National Airsp NAS consists of three strata. Th enroute airspace e enro trspace structure of the irways in the United States ve names that start with the y cover altitudes from approximately to, but not including 18,000 feet above mean altitude airways in the United States all e called Jet Routes. These routes run from ws random operations above flight level navigation (RNA V) routes, which provide users with an ability to een any two points. In conjunction with the high-altitude routing vigation (RNA V) routes have been established to provide for ffic in specific portions of the enroute flight environment.

for thes RNA V routes begins with the letter Q. Low altitude RNA V identified by the letter "T" prefix, followed by a three-digit number (T-ithin a 10 nautical mile radius identified that there are multiple federal ar the WCS CISF: V68, Q20, and 166 [2-45]. The low-altitude airway is a the two high-altitude airways are Q20 and 166. These airways are described ore detail as follows:

Page 2-8

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Low Altitude Airways (Figure 2-38 and Figure 2-39) [2-45]

V68 is a low-altitude east-west route (113° out of Lea County Regional Airport N32°38.29' W103.16.16' toward Midland Airpark Airport N32°00.56' Wl02°1 l.42'). Its centerline passes approximately 4 miles from the lant site and has a width of 9.21 miles (8 nautical miles).

High Altitude Airways (Figure 2-40) [2-45]

Q20 is a high-altitude northwest-southeast RNA V route NM N33°34"00', W104°51"12' toward FUSCO, TX Its centerline passes approximately 4 mi les from t 9.2 miles (8 nautical miles).

166 is a high-altitude east-west Jet route (2 W 101 °29.02' toward Newman, TX N31 passes approximately 12 miles from t nautical miles).

2.2.1.3 Flight Path Movements

HONDS, 0 19"45').

idth of hts was provided by ile radius from the 1, 2017 to December ovements and indicates that there were 2017 and 2018, respectively. Note that te so the flight movements of each airway trapolate on the available data from December 1st to t movements in the first eleven months of 2018 increased by 6.36%

in 2017, the overall flight movements in December 2018 were increase over December 2017 (i.e., 6.36%). Flight movements altitude (> 18,000 ft) and low altitude ( <18,000 ft) flights.

all nu er of flights with no altitude information provided. These nated as 'other' in Table 2-14.

Page 2-9

WCS Consolidated fnterim Storage Facility Safety Analysis Report Revision 3 Interim 2.2.1.4 Military Training Routes Military aircraft would fly within designated Military Training Routes (MTRs), which may or may not be flown under air traffic control. Airspace above the United States from the surface to 10,000 feet above sea level is I im ited to 250 knots C icated airspeed) by FAA regulations. There is a military exception to this re ent, the Military Training Route Program, a joint venture by the FAA and epartment of Defense (DOD), developed for use by military aircraft to gain proficiency ih tactical "low-level" flying. These low-level tr

established below 10,000 feet for speeds in excess of 250 The review of IFR enroute Aeronautical Charts fro MTR in the vicinity of the WCS CISF: IR-128 a IR-128/180) [2-45]. This airway is described Military Training Routes (Figure 2-38 and segment passes approxi miles (7 nautical miles, 4 on the other).

rther away and not 28/180, including their e summary of flight path movements in er of two Air Route Traffic Control

) and ZFW (Ft. Worth, TX) [2-46]. The and ZAB is provided in Table 2-16. There are

~ military operations. It is judged that the ratio of flight classes WCS CISF site within a 10 nautical mile diameter circle is the andled by ZFW and ZAB. Therefore, the military operations CISF site 10 nautical mile diameter circle is calculated as airways, NUREG 0800 Section 3.5.1.6 seeks a description of airports in fthe site. There are twelve (12) local and regional airports close by the

, which are located in Andrews County TX, Gaines County TX, and Lea NM. These airports are within a 50 nautical mile (57.5 mile) radius of the CIS Facility site. Of these airports, only the Lea County Regional (HOB) airport has a Federal Aviation Administration (FAA) funded air traffic control tower [2-48].

Page 2-10

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.2.1.6 A summary of the airplane operations at airports near the WCS CISF are provided in Table 2-17. Airport operation numbers have been gathered from 2 sources, first is the Air Traffic Activity Data System (ATADS), which contains the official NAS air traffic operations data available for public release [2-44]. The other is GRC Inc.'s AirportIQ 5010 [2-48], which is a compilation of FAA form 5010-5 Ai rt Master Records and Reports. A TADS gives data as far back as 1990, where rtIQ gives only the past year's data. Additionally, A TADS only gives data fi orts that have an FAA certified Air traffic control tower, so data for some of lier airports has only been sourced from AirportlQ.

Table 2-17 indicates that the closest airport to the site *

(HOB), which is located 4 miles west of Hobbs, N miles northwest from the plant site of the WCS Airport is classified as a small aircraft airport general aircraft. Recent regional airport sta

approximately 35 flight operations per day approach for estimating the probability per A

PFA = C X N X -w of an aircraft crashing into the plant ash rate er mile for aircraft using airway flights per year along the airway ea of the plant in square miles irway (plus twice the distance from the airway edge to the site when the tside the airway) in miles Page 2-11

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim The commercial aircraft in-flight crash rate (per mile airway), ' C', is recommended to be 4.0E-10 in NUREG 0800. This crash rate was estimated based on a conservative assumption that a non-catastrophic failure will occur somewhere in the U.S. once per year. NUREG 0800 Section 3.5.1.6 states that if the number of flights on a specific corridor exceed 100 per day, then more detailed analysis may be requir It is noted that the busiest airway near the WSP CISF is high-altitude federal ai 66, which has a minimum distance of 7.6 miles from the WSP CISF. Airwa approximately 157 flights per day. Further, as this airway is a ft) east-west corridor, it is judged that most flights on this a*

The technical basis supporting the NUREG 0800 eras reviewed to ensure that this value was appropriate fi 0800 estimate was based on a review of crash ra between 1965 and 1975 [2-46]. During this ti aircraft miles flown per year is 2.396E9. B non-catastrophic fai lure per year [2-46], th derived as the reciprocal of 2.396E9, or appro Flight safety in the U.S. has im time period, the FAA reports decreased by 95 percent [2-49 technological advances in navi improvements in the sharing of s rimarily due to n enhancements, and e U.S. has increased considerably. World ssengers carried on U.S. flights in 2015 is O]. Based on the significant improvements number of flights in the 20 years ( or Jue for in-flight crash rate (per mile) of the 166 airway.

assumption, the military flights were assumed to be 6.37% of the 10 nm radius of the plant. However, it noted that these flights ated on the military training routes IR-128/180, which are away from the WCS CISF (Figure 2-38 and Figure 2-39. In military aircraft, loaded with ordnance, crashed on these flight ce from the plant is such that damage from exploded ordnance would n this basis, it is judged that military flights with ordnance are not a consideration.

s of the evaluation are shown in Table 2-18. Based on site-specific flight tion and nearby airway locations, the annual probabi lity of aircraft crash at the CISF is approximately 3.8I E-7. This is lower than the one-in-one-million (lxl 0-6) annual probability of occurrence required by the NRC (2-42].

Page 2-12

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim To provide an additional conservative value of the aircraft impact crash probability, the hypothetical scenario of all airways passing directly over the site was considered.

Table 2-19 provides results of the evaluation. The annual probability of aircraft crash at the WCS CISF is approximately 7.38E-7, which is also lower than the one-in-one-million (1x10-6) annual probability of occurrence required by the NRC 42].

The evaluation results, based on site-specific flight information a locations, indicate that the annual probability of aircraft crash approximately 3.81E-7. Using a conservative approach (i.e.

site), the annual probability of occurrence is computed to probabilities are below the NRC annual probability of for aircraft crash. An additional conservatism in bo that the effective area is equivalent to the full siz versus the actual area size for Phase 1 (36 acr aircraft crash presents low risk to public he necessary to be included as a design basis c Page 2-1 3 ss over the

-7. Both l.OE-6

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.8 References 2-1 Bally, A.W., C.R. Scotese, and M.I. Ross, 1989, North America; Plate-Tectonic Setting and Tectonic Elements in The Geology of North America-An Overview:

Volume A, Decade of North American Geology, p. 1-15, Geological So *ety of America, Boulder, Colorado.

2-2 Bebout, D.G., and K.J. Meador, 1985, Regional Cross Sections Platform, West Texas: The University of Texas at Austin, Bu Geology, 4 p., 11 plates.

2-3 Blandford, T.N., D.J. Blazer, K.C. Calhoun, A.R. Dutt B.R. Scanlin, 2003, Groundwater Availability ofth Texas and New Mexico Numerical Simulations t Development Board Draft Report, 160 p.

2-4 Bomar, G.W., 1995, Texas Weather, 2nd 2-5 2-6 2-7 2-8 2-9 2-12 2-13 Texas.

the Southern High logical Investigations eorecharge in U.S. High Hydrogeochemistry and Water Resources of exas Panhandle and Eastern New Mexico:

onomic Geology Report of Investigations and Geo o the Permian Basin of Texas and New Mexico, merican Association of Petroleum Geologists, p. 395-446.

Faulting and Salt Dissolution, in Geology and Geohydrology exas Panhandle, A Report on the Progress of Nuclear Waste "bility es (1979): The University of Texas at Austin, Bureau of ogy Circular 80-7, p.83-87.

., and R.J. Finley, 1985, Late Cenozoic Geomorphic Evolution of the le and Northeastern New Mexico: The University of Texas at Austin, onomic Geology Report of Investigations No. 148, 42 p.

., 1963, Late Paleozoic Tectonics and Mountain Ranges, Western Texas to S

rn Colorado, American Association of Petroleum Geologists Bulletin, vol. 47,

p. 1709-1724.

Hills, J.M., 1985, Structural Evolution of the Permian Basin of West Texas and New Mexico, in Structure and Tectonics of Trans-Pecos Texas: West Texas Geological Society, Field Conference Publication 85-81, p. 89-99.

Page 2-45

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2-14 Holzworth, G.C. "Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution Throughout the Contiguous United States." U.S. Environmental Protection Agency, Office of Air Programs. January 1972.

2-15 Jones, LC., 2001, Cenozoic Pecos Alluvium Aquifer, in Aquifers of West Texas:

Texas Water Development Board Report 356, ed. R.E. Mace, W.F. M n III, and E.S. Angle, p. 120-134.

2-16 Lea County Solid Waste Authority. "Lea County Solid Waste http://www.leacounty.net/SWA.html (Accessed 2/16/2016).

2-17 Lehman, T.M, 1994a, The Saga of the Dockum Group an Mexico Boundary Fault: New Mexico Bureau of Mi Bulletin 150, p. 3 7-51.

2-18 Lehman, T.M, 1994b, Save the Dockum Grau Bulletin 34(4), p. 5-10.

2-19 Louisiana Energy Services (LES). "Nationa 2-20 2-21 2-22 2-23 2-27 Report." Revision 4. NRC Docket No.70-310 Mooney, W.

and Uppe Overv*

Am e Seismic Structure of the Continental Crust e Geology of North America - An erican Geology: Geological Society of tent of Cenozoic Faulting in Trans-Pecos Geology of the Trans-Pecos Volcanic Field of Texas, p 19-21.

.D. Johns, and A.E. Fryar, 1997, Playas and Recharge of the Southern High Plains of Texas -

An Examination using e University of Texas at Austin, Bureau of Economic tigations No. 242, 72 p.

Hydro geology and Hydrochemistry of the Ogallala Aquifer, Southern xas Panhandle and Eastern New Mexico: The University of Texas at of Economic Geology Report of Investigations No. 177, 64 p.

nd G.N. Gutierrez, 1988, Hydro geology and Hydrochemistry of Cretaceous s, Texas Panhandle and Eastern New Mexico: The University of Texas at Au m, Bureau of Economic Geology Geological Circular 88-3, 32 p.

NEF. (2005). National Enrichment Facility. URENCO Environmental Report.

Published in April 2005.

Page 2-46

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2-28 Nicholson, A., Jr., and A. Clebsch, Jr., 1961, Geology and Ground-Water Conditions in Southern Lea County, New Mexico: New Mexico Bureau of Mines and Mineral Resources Ground-Water Report 6, Socorro, New Mexico, 123 p.

2-29 Permian Basin Materials. Personal communications between B.J. Oden, Permian Basin Materials, and J. Caldwell, Waste Control Specialists LLC Febr 16, 2016.

2-30 Sundance Services, Inc. Personal communications between A. C Basin Materials, and J. Caldwell, Waste Control Specialists LL 2-31 Texas Commission on Environmental Quality Radioactive R04100 Low Level. Amendment 29. Radioactive Mater Issued in December 2015.

2-32 Texas Commission on Environmental Quality R R05807. Amendment 09. Issued in January 20 2-33 2-34 2-35 2-36 2-37 2-38 2-39 Texas Commission on Environmental Qu Permit for Industrial Solid Waste Managem ial Permit No. 50397.

inment Areas for asin: West Texas Geological iew Plan for Spent Fuel Dry Cask Storage

. 200 Regulatory Commission, Office of uide 1.145, "Atmospheric Dispersion Models for Potential sessments at Nuclear Power Plants," Revision 1, November inimum Design Loads for Buildings and Other Structures," American Engineers (2010).

egulatory Commission, "Memorandum and Order CLI-01-22 in the ndependent Spent Fuel Storage Installation," 2001.

2-43 uclear Regulatory Commission, "NUREG-0800, 3.5.1.6 Aircraft Hazards, R4,"

2-44 "FAA Airport Data and Contact Information." [Online]. Available:

https://www.faa.gov/airports/airport _ safety/airportdata _5010/. [ Accessed: 12-Feb-2019].

Page 2-47

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2-45 "FAA IFR Enroute Aeronautical Charts and Planning." [Online]. Available:

https ://www.faa.gov/air _ traffic/fl ight_info/aeronav /digital _products/ifr/. [ Accessed:

12-Feb-2019].

2-46 "FAA AIS Open Data, MTR IR 128/180 Segment Location." [Online]. Available:

http://ais-faa.opendata.arcgis.com/datasets/Oc6899de28af447c801231 ed7ba7

8. [Accessed: 12-Feb-2019].

2-47 "Air Route Traffic Control Centers (ARTCC)." [Online]. A https://www.faa.gov/about/office _ org/headquarters _ offic c_services/artcc/. [Accessed: 14-Feb-2019].

2-48 "GRC AirportIQ 5010 Airport Master Records an https://www.gcrl.com/501 Oweb/default.cfm. [

2-49 "Fact Sheet - Out Front on Airline Safety:

2-50 2-51 2-52 2-53

[Online]. Available:

https://www.faa.gov/news/fact_sheets/news _

_ sheetsAoc&cid=103_F _S. [Accessed: 25-Feb-

"Air transport, passengers carr*

https://data. worldbank.org/in le:

US. [Accessed: 25-Feb-2019].

the Southeastern New cal Society Guidebook, 44th Texas, 2007. Application for License to adioactive Waste. License R04100, Rev er Cretaceous Strata under the Southern xico Geology, Volume I 0, No. 1, February s,D.W., 2007a, Report on mapping of a trench through e) across a drainage and possible lineament, Waste Control posal Andrews County, TX. Attachme11t 4-la, Appendix 2B, to erial Disposal Facility License Application to TCEQ by WCS, original 04, last revised June 2007.

, Hovorka, S.D., and Gustavson, T.C., 1996, Lithostratigraphy and y of fills in small playa basins on the Southern High Plains, United letin Geological Society of America, v. 108, p. 953-965.

2-56 et. al., 2005, Play analysis and leading-edge oil-reservoir development methods in the Permian basin: Increased recovery through advanced technologies.

AAPG Bulletin, V.89, No. 5 (May 2005), pp. 553-576.

Page 2-49

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table 2-14 Summary of Non-military Flight Path Movements (20 Page 2-62

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table 2-15 Nearby Federal Airway and Military Training Route NUREG 0800 Screening Airway or Pattern V68 Q20 166 IR-1 28/

IR-180 Type Federal Federal Federal MTR MTR Travel Distance Direction to Centerline Either 3.4 Either 3.7 Either 12.2 Wto E 15.2 E to W 15.2 Width left of center

[mi]

4.6 4.6 Military Traffic Handled by Facility Air Carrier ZFW ZAB Page 2-63 Width right of 7 to 12/31/2018 Total 4,640,908 3,203,453 7,844,361 6.36%

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table 2-17 Nearby Airport NUREG 0800 Screenin Airport IQ Distance Average 5010 General Airports City, State from site Annual Operations

[mi]

Operations for 12 J

Heli Ultralight months y

ending:

ANDREWS Andrews, TX 32.0 6228 4/25/2018 29 COUNTY (El I)

TWO LEGGS (ITA5)

Denver City, 34.0 NIA 3

TX SEAGRA YES (F97)

Seagraves, TX 46.0 2100 7

GAINES COUNTY Seminole, TX 28.3 121 25 16 3

(GNC)

HAMILTON AIRCRAFT, INC Seminole, TX 20.5 IA 3

(5TAO)

SEMJNOLE SPRAYING Seminole, TX 26.2 6

SERVICE (39TE)

INDUSTRIAL Hobbs, NM II AIRPARK (NM83)

LEA COUNTY Hobbs, NM 16%

9%

7%

41 6

5 RGNL(HOB)

LEA COUNTY/JAL/

Jal, NM 7

(E26)

LEA COUNTY-ZIP FRANKLIN 100%

11 MEMORJAL(E06)

OR LEA COUNTY GENERAL 12/30/2004 HOSPITAL (NM TATUM (18T) 100%

3 Page 2-64

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table 2-18 Results of Aircraft Hazard Evaluation (Airways Consider Low Altitude High Altitu e Variable Description Variable Units (V68 &other)

J66 Total (W-E)

Jntlight Crash C

- 1 4.00E-IO Rate(NUREG-0800) mt Aircraft Operations within 10 nautical miles N

-1 yr 5142 of WSC CISF in 2018 Width of Airway w

mi 9.2 29.3 9.2 Area of WCS CISF A

2 m,

0.21 0.21 0.21 Probability of inflight aircraft impacting WSC pFA yr -I 1.47E-08 3.81E-07 CISF Page 2-65

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Table 2-19 Probability of In flight Aircraft Impacting WCS CISF (All airw Variable Description Variable Units Air Carrier Air Taxi Total Inflight Crash Rate C

-1 m1 4.00E-10 (NUREG-0800)

Aircraft Class 60.19%

Aircraft Operations N

yr

-1 5142 within 10 nautical miles of WCS CISF in 201 8 Width of Airway w

mi 9.2 Area of WCS CISF A

2 m1 1

0.21 Probability of intlight p FA yr -I 4.69E-08 7.38E-07 aircraft impacting WCS CISF Page 2-66

WCS Consolidated Interim Storage Facility Safety Analysis Report tlf'"'

/

,/

Figure 2-38 w Altitude Air Routes Passing Near the Site Page 2-110 Revision 3 Interim

WCS Consolidated Interim Storage Facility Safety Analysis Report 0

Figure 2-39 w Altitude Air Routes Passing Near the Site Page 2-111 Revision 3 Interim

WCS Consolidated Interim Storage Facility Safety Analysis Report

... ~~-***w:.

T ""'iloJMI~

Figure 2-40 gh Altitude Air Routes Passing Near the Site Page 2-11 2 Revision 3 Interim

RAls and Responses Enclosure X to E-XXXX RAI NP-2.2-2:

Provide the locations of nearby industrial, transportation, military, and nuclear installations.

Describe potential hazards to the proposed WCS CISF from activities or materials at those facilities in accordance with the guidance and acceptance criteria provided in N

-1567, Section 2.4.2.

During the NRC staff's review, the NRC staff determined that ISP identif did not provide potential impact evaluations of these facilities on the g Specifically, ISP identified a railroad, but did not provide details on cts/m transported by rail; the distance of the rail line from the propose c1 y; or the po (if any) on the proposed facility. ISP identified Texas State Hi 176, but not the distance between the highway and the proposed facility. IS ed oil industry pipelin located near the facility in WCS CISF SAR Section 12.2.

did not provide details as t materials are transported in the pipelines; the distanc e pipelines the proposed facility; or the impacts of the pipelines on the propos ility. Diffe aterials can be transported through these pipelines and these differen ials ose different potential hazards to the site.

Also, in accordance with SRP Section 15 hazards near the site have been addre evaluating which external hazards shoul ISP should use a screening criteria of 10-6 criteria, not 1.0E-5, as stated in SAR Secti Commission for ISFSl's in the Private Fuel elucidated in CLl-05-19.

If the required impa staff requests tha the evaluations WCF CISF SA esign basis. When es for the WCS CISF, xcee the applicable dose established by the 22) and further ome other section of the SAR, the NRC ced in SAR Section 2.2, pointing to where dressed for clarity. Provide a revised analyses, and conclusions, as appropriate, re presented in Chapter 12, "Accidents idance and acceptance criteria provided in NUREG-1567, Section

-km (5-mi) radius and all relevant facilities at greater distances should 10n of nearby industrial, transportation, and military facilities. In mentioned in SAR Section 2.2, the section, along with Section 12.3 cl to include New Mexico State Highway 18, the Texas & New Mexico ave! stop, the Waste Control Specialists' rail spur and loop, and the natural gas pipeline runs parallel to Texas State Highway 176. Figure 2-3 in the WCS CISF SAR is revised to include relevant facilities within an 8-km (5-mile) radius.

Page 2 of 116

RAls and Responses Enclosure X to E-XXXX In addition to industrial and transportation facilities, gas and oilfield operations are common in west Texas. Regionally, the WCS CISF is located in the Permian Basin of west Texas and southeast New Mexico which is one of the most important petroleum-producing regions in the United States, containing several thousand oil and gas wells (Dutton et al, 2005) [3]. Significant petroleum storage, however, is not located within 5 miles of the WCS CISF. Loca within the Waste Control Specialists property boundaries, oil and gas activity also is very r

. There is no active oilfield activity within the WCS CISF footprint area and only one do ted dry hole in the immediate area of the WCS CISF (New SAR Figure 2-36). That dfY.

as been cemented to the surface and proper plugging and abandonment protoc served. There is no evidence of undocumented or "orphan" wells in the vicinity of th If any open boreholes indicative of orphan wells are discovered during the con ese will be properly assessed and remediated using proper plugging an ba donment pr accordance with Texas Regulations. ISP joint venture memb ste Control Spec1 holds 100% of the Operating Rights for producing oil, gas, her minerals for the ar land where the storage pads for Phase I and the future s of the WCS CISF would b located. These rights allow ISP joint venture member.

ialists to prevent y

drilling (horizontal or vertical) under storage pads for inerals. RAI NP-2.6-1 details why sinkholes associated with wells in the regio t the WCS CISF. In Figure 1 below, a 2014 survey by The Banks Group (

.com) of oil and gas wells within 1 mile of the WCS CISF shows that two (2) dry holes rilled and one (1) well is no longer producing. Just outside the 1-mil

s of the WCS C e an additional four (4) dry holes and two (2) wells that are no long of oil and gas activity around the WCS CISF, 10 out of 12 loca roducing, which indicates there is little economically viable mile of the WCS CISF and therefore further petroleum recovery a Section 2.6.2 and in the Probabilistic Seismi 2, it was determined ther ively low petroleum recovery a

R Chapter 12, Regulatory Guide 1.91, by facilities and on Transportation Routes determine distances from nearby facilities hich an 10n that might occur is not likely to have an SSCs important-to-safety. The guidance in Regulatory Guide 1.91 essure at SSCs to less than 1 psi from any explosion. The solid or liquid material is calculated by converting the weight their TNT equivalence. Per Regulatory Guide 1.91, a more orting sive materials on these transportation routes would not be rating that the overpressures at the WCS CISF can be shown not to ortation routes include New Mexico Highway 18 to the west of the WCS ay 176 which is to the south of the WCS CISF. New Mexico Highway 18 miles from the WCS CISF and Texas Highway 176 is approximately 1.5 t the closest point to the WCS CISF.

Using the methodology of Regulatory Guide 1.91, the maximum probable hazardous solid cargo for a single highway truck is 50,000 lbs, and detonation of this quantity of explosive could produce a 1 psi overpressure at a distance of approximately 1,660 ft (0.31 mile) from the detonation, which is well short of the WCS CISF.

Page 3 of 116

RAls and Responses Enclosure X to E-XXXX The Texas & New Mexico Railway (TXN) is a rail way consisting of 111 miles of track that run generally north-south between the Union Pacific lines in Monahans, Texas and its termination in Lovington, New Mexico. This rail line, at its closest point, is approximately 4.8 miles from the west OCA boundary of the WCS CISF. The rail line typically carries oilfield commodities including drilling mud, hydrochloric acid, tracking sand, Piping, And Petroleum Pro ucts Including Crude Oil.

Regulatory Guide 1.91, Evaluations of Explosions Postulated to Occur at on Transportation Routes near Nuclear Power Plants, Revision 2, was distances from nearby facilities or transportation routes beyond whic occur is not likely to have an adverse effect on WCS CISF SSCs i guidance in Regulatory Guide 1.91 is based on limiting the over psi from any explosion. The magnitude of explosions of solid converting the weight of potentially explosive materials tot Using the methodology of Regulatory Guide 1.91, the solid explosive ca o (which bounds liquid cargo) for a single box car is 1 ation of this quantity of explosive (using its TNT equivalence) could produce a re at a distance of

approximately 2,300 ft (0.44 mile) from the detonation.

for the possibility that multiple boxcars of explosive material are connected in a si in and multiple boxcars explode in the same event shows that te pletely full boxc lading in the same event produce 1 psi of overpressure at a dist feet from th ation. This distance is much shorter than the distance to the W ight of ex material required to exceed 1 psi of overpressure at the WCS ion e mely unlikely under normal transportation conditions due to the s the length of the train increases each successive rail car gets furt CISF).

The Waste Control Sp Eunice, New Mexic the existing Wast side track to th and terminate o controlled by ISP J Waste Control Speci the s

its the Texas & New Mexico Railway near

3. This spur continues east until it reaches

forms a loop around the facility. The rail the northwest side of the existing loop e loop. This rail line is completely ember ntrol Specialists and limited to approved te shipments and transport casks. Railcars carrying contents with t the WCS CISF will not be permitted on the Waste Control and explosion precautions for the WCS CISF rail side track e SAR.

ned by nergy Transfer LP (previously owned by Sid Richardson y) runs parallel to Texas State Hwy 176 within an easement on Waste

y. This pipeline is approximately 7,700 feet from the WCS CISF at its ion assessing the hazards to the WCS CISF due to a pipeline leak and explosion following the guidance of Regulatory Guide 1.91 determined een the pipeline and the WCS CISF is sufficient to preclude any adverse ity. (Reference [4]) Reference [4] is being submitted along with this response Page 4 of 116

RAls and Responses Enclosure X to E-XXXX Directly adjacent to (within 30 feet) and parallel to the Energy Transfer LP natural gas pipeline is an additional buried 14 inch diameter natural gas pipeline which is in idle status. This pipeline is also owned by Energy Transfer LP and it has been idle since before 2004. Should this pipeline be re-activated in the future, the hazard evaluation performed for the adjacent natural gas pipeline would apply to this as well.

There is a 10 inch diameter buried CO2 pipeline which runs along the wester boundary of New Mexico Section 32. This pipeline does not present a ha based on the nature of the pipeline product and its distance from the W than 8,000 feet at its closest point.

Love's Travel Stops & Country Stores has started construction o at the southeast corner of the intersection of New Mexico Hig Stop will store up to 40,000 gallons of diesel fuel, 28,000 g gallons of non-flammable Diesel Exhaust Fluid (DEF) in Response Guide 128 recommends a 0.5 mile safe dis much less than the 3.5 mile distance from the Trave boundary.

References:

1.

Impact:

s, to include discussion of travel stop. In addition, rrying natural gas.

ded to the section.

o State Highway 18, the

ipeline, eve's travel stop, and

.2. Figure 2-3 is updated to include tory Guide 1.91, Evaluations of Explosions d on Transportation Routes near Nuclear uide 128, Emergency Response Guidebook (2016), U.S.

on, Pipeline and Hazardous Materials Safety Administration 5, Play alysis and leading-edge oil-reservoir development methods in: Increased recovery through advanced technologies. AAPG 5 (May 2005), pp. 553-576.

'Hazard Analysis of Gas Pipeline for WCS CISF," WCS01-0211,

SAR Sections 2.2, 2.8, 12.2.2, and 12.3 and Figure 2-3 have been revised and Figure 2-36 is added as described in the response.

Page 5 of 116

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2.2 Nearby Industrial, Transportation and Military Facilities The only industrial facilities located within five miles of the WCS CISF boundary are URENCO USA, Permian Basin Materials, the Lea County landfill, a future travel stop and Sundance Services, Inc. (Figure 2-3). URENCO USA is a uranium richment facility that uses centrifuge technology to provide uranium enrichme Waste Control Specialists operates several permitted and licensed immediately south of the WCS CISF, including a RCRA landfi radioactive waste facility and a byproduct materials landfill.

Permian Basin Materials operates a quarry and crushin o sand and gravel are mined, crushed and screened fo making concrete (Permian, 20 l 6[2-29]). Sundan waste disposal services. Sundance Services is Minerals and Natural Resources Departme and also manages produced water, solids a authorized to landfarm solids (Sundance, 201 ted to the southwest and dfill disposes of under New Mexico andfill services Lea andfill does not generate operated by Love's Travel Stops & Country exico State Highway 18 and Hwy 176.

hway vehicles, is located more than 3.5

"ties within a mile of the WCS CISF. The closest military rce Base is the closest at a distance of approximately 135 ew Mexico Railway (TXN) is a railway consisting of 111 miles of erally run north-south between the Union Pacific lines in Monahans, its termination in Lovington, New Mexico. The railway is 4.8 miles from CISF at its closest point. The existing Waste Control Specialists railroad sp and loop exits the Texas & New Mexico Railway near Eunice, New Mexico as shown in Figure 2-3. This spur continues east until it reaches the existing Waste Control Specialists facility where it forms a loop around the facility. The rail side track to the WCS CISF will begin by connecting to the northwest side of the existing loop and terminate by re-connecting at the north side of the loop.

Page 2-5

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Texas State Highway 176 is a two-lane highway with 3.6 m (12 foot) wide driving lanes, 2.4 m (8 foot) wide shoulders and a 61m (200 foot) wide right-of-way easement on each side. Access to the site is directly off of Texas State Highway 176. Texas State Highway 176 is approximately 1.5 miles from the WCS CISF. New Mexico Highway 18 is a four-lane highway approximately 3.5 miles from the CISF.

A natural gas pipeline owned by Energy Transfer LP runs parallel Highway 176 within an easement on Waste Control Specialists is approximately 7,700 feet from the WCS CISF at its close to and parallel to the Energy Transfer LP natural gas pipe

14 inch diameter pipeline which is in idle status. The Energy Transfer LP and it has been idle for over 15 buried CO2 pipeline runs along the western and Section 32. This pipeline is over 8,000 feet fr In addition to industrial and transportation common in west Texas. Regionally, the WC west Texas and southeast New Mexico which is field operations are ed in the Permian Basin of rty boundaries, oil and ity within the WCS e immediate area of the producing regions in the United

[2-56]. Significant petroleum WCS CJSF. Locally within tH gas activity also is very limited.

CISF footprint area and only one WCS CISF (Figure 2-36). That d een ce ed to the surface and proper plugging and a undocumen borehole served. There is no evidence of any icinity of the WCS CISF. If any open

scovered during the construction process, ted using proper plugging and Texas Regulations. ISP joint venture olds 100% of the Operating Rights for nd other minera s for the area of land where the storage pads for re phases of the WCS CISF would be located. These rights allow ber Waste Control Specialists to prevent any drilling (horizontal pads for oil, gas, and other minerals. Based on Figure 2-36, cation Yo) are dry or no longer producing, which indicates there is lly viab e oil and gas resources within 1 mile of the WCS CISF and leum recovery activities in this area are unlikely. As explained in

.6.2 and in the Probabilistic Seismic Hazard Analysis in Attachment D er 2, it was determined there is a relatively low seismic hazard at the rol Specialists site even with petroleum recovery activities.

hapter 12 Section 12.2 provides evaluations of the potential hazards these faci ities present to the WCS CISF.

Page 2-6

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 2-45 "FAA IFR Enroute Aeronautical Charts and Planning." [Online]. Available:

https ://www.faa.gov/ai r _ traffic/fl ight_info/aeronav Id igital_products/ifr/. [Accessed:

12-Feb-2019].

2-46 "FAA AIS Open Data, MTR IR 128/180 Segment Location." [Online]. Available:

http://ais-faa.opendata.arcgis.com/datasets/Oc6899de28af447c801231 ed7ba7

8. [Accessed: 12-Feb-2019].

2-47 "Air Route Traffic Control Centers (ARTCC)." [Online]. A https://www.faa.gov/about/office _ org/headquarters _ offic c_services/artcc/. [Accessed: 14-Feb-2019].

2-48 "GRC AirportIQ 5010 Airport Master Records an 2-49 2-50 2-51 2-52 2-53 https://www.gcrl.com/5010web/default.cfm. [

"Air transport, passengers carr*

https://data. worldbank.org/in 2019].

the Southeastern New cal Society Guidebook, 44th Texas, 2007. Application for License to adioactive Waste. License R04100, Rev wer Cretaceous Strata under the Southern xico Geology, Volume 10, No. 1, February s,D.W., 2007a, Report on mapping of a trench through e) across a drainage and possible lineament, Waste Control posal Andrews County, TX. Attachment 4-1 a, Appendix 28, to erial Disposal Facility License Application to TCEQ by WCS, original 04, last revised June 2007.

, Hovorka, S.D., and Gustavson, T.C., 1996, Lithostratigraphy and y of fills in small playa basins on the Southern High Plains, United letin Geological Society of America, v. 108, p. 953-965.

2-56 et. al., 2005, Play analysis and leading-edge oil-reservoir development methods in the Permian basin: Increased recovery through advanced technologies.

AAPG Bulletin, V.89, No. 5 (May 2005), pp. 553-576.

Page 2-49

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Figure 2-3 Proposed WCS CISF 5-mile Radius Page 2-71

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Figure 2-36 CISF 1-Mile Radius Oil and Gas Activity Page 2-111

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 12.2.1.3 Analysis of Fire It is conservatively assumed that the CTS fire is 2-meter from the transfer cask surface, with a heat flux of 29.3 kW/m2 on the cask surface. A 3-D half symmetry finite element model is used to perform a transient analysis. The heat fl of 29.3 kW/me2 is applied from bottom of the TFR to 1 meter from bottom, zero at 2 meter from bottom. The source of the fire is considered gasoline and the fire is sustained for 3.5 minutes. The transien 3.5 min of fire and 30 min. post-fire.

The analysis results indicate that the TFR surface tern 12.2.1.4 Corrective Actions 12.2.1.5 12.2.2 ncrete, loss of shielding, t cask performance.

ir activities are 1guration.

equences for this accident. There may be eutron shield properties during the fire ction in shielding effectiveness and an s on the cask surface.

ndustrial, Transportation and Military Facilities," indicates that t could contribute to the potential for significant explosions five m f the CISF facility. There are no chemical processing eum re meries, natural gas facilities or munition depots that could potential for significant explosions located within five miles of the Page 12-5

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim The neighboring facility to the west of the WCS CISF is a uranium enrichment facility, URENCO, and the distance is approximately 7,277 feet from the interior fence of the CISF to the closest building. The process used is a physical rather than a chemical process, and no chemical reactions are initiated although process hazards include possible chemical reactions in some accident scenarios. Some mica!

reactions that may take place at URENCO are controlled by utility s s that decontaminate equipment and remove contaminants from effluen lubricating oil [12-4]. Process Hazards identified by URENCO

and toxicity of UF6 release were found to be intermediate a potential accident sequences and consequences are discu Section 3.7 of the Integrated Safety Analysis (ISA) S facility [12-4]. In the event of an accidental re leas hour and 8-hour Total Effective Dose Equivalen and they are 3.1 mSv (310 mRem) and 8.0 m s

include the prompt gamma radiation and t accident meteorology (51h percentile). Figu corresponding doses as a function of distance WCS CISF is over 2,000 meters from the UREN the consequences of a postulat iticality event up beyond the site boundary wo

erably belo intermediate consequence eve O CFR 7 d to Occur at Nearby uclear er Plants, Revision 2, was cilities or transportation routes beyond ot likely to have an adverse effect on WCS nee in Regulatory Guide 1.91 is based on an 1 psi from any explosion. The liquid materials is calculated by converting rials to their TNT equivalence. Per

.91, a more detailed review of transporting explosive materials on routes would not be required beyond demonstrating that the CS CISF can be shown not to exceed I psi for any explosion.

f Regulatory Guide 1.91, the nearest truck transportation ted mu rther from the CISF than the distances to exceed I psi ased on the Regulatory Guide, the maximum probable hazardous solid le highway truck is 50,000 lb, and detonation of this quantity of d produce a I psi overpressure at a distance of approximately 1,660 ft m the detonation. Since Texas Highway 176 is approximately 8,000 es) from the southernmost edge of the storage pad for the canisters, ns involving vehicles travelling on this road would not produce significant ressures at these locations.

Page 12-6

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim The Texas & New Mexico Railway at its closest point, is approximately 4.8 miles from the west OCA boundary of the WCS CISF. Using the methodology of Regulatory Guide 1.91, the maximum probable hazardous solid cargo for a single box car is 132,000 lbs, and detonation of this quantity of explosive could produce a 1 psi overpressure at a distance of approximately 2,300 ft (0.44 mile) from t which does not approach the location of the WCS CISF.

The Waste Control Specialists rail spur and loop exits the Texa Railway near Eunice, New Mexico as shown in updated Fig continues east until it reaches the existing Waste Control forms a loop around the facility. The rail side track to connecting to the northwest side of the existing loo spur where it

n by

ng at the north side of the loop. This rail line is comp I member Waste Control Specialists and limite waste shipments and transport casks. Rail adversely affect the CISF will not be perm, spur and loop. Fire and explosion precautions discussed in Section 3.3.6 of the SAR.

din the SAR 12.1.2, E.12.2.2, The effects of explosions on Appendices, Sections A.12.2.

F.12.1.2 and G.12.1.2, and it is effects of explosions. Overpress required to cause damage to the c nisters protected from the Permian Ba*

periodica outso bey than 1 psi would be located northwest of the facility. The quarry or quarrying materials; however, this is s are stored onsite. The quarry is located nd thus any accidental explosions would psi to cause damage at the CISF.

of the proposed WCS CISF is the currently operating Waste mmercial waste disposal facility. The site has two propane tanks d 1,000 gallons and several smaller propane tanks. The vapor s of these propane tanks would not impact the CISF. Listed istances of various gasoline and diesel storage locations that could be a ion source; however, each location is over 1,660 feet (0.31 mile) from ne of the locations have quantities that would create overpressures in at the CISF.

trol Specialists Gasoline and Diesel Locations, Quantities and Distance oposed CISF:

Mixed Waste Treatment Facility (MWTF) - Gas Storage Tank - 5,000 gallons -

4,732 feet from CISF MWTF - Diesel Storage Tank - 8,000 gallons - 4,732 feet from CISF MWTF - Diesel Storage Tank (Green Fuel) - 500 gallons - 4,732 feet from CISF Page 12-7

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim Low Level Radioactive Waste Facility-Diesel Storage Tank-3,384 gallons -

3,478 feet from CISF Fire Pump - 850 gallons Diesel - 3,205 feet from CISF 4 Generators - Diesel - 350 gallons each-3,205 feet to 5,885 feet 3 Mobile Storage Tanks - Diesel - 475 gallons each - 3,483 fi from CISF Oil industry pipelines are located near the facility. A natu Energy Transfer LP (previously owned by Sid Richardso runs parallel to Texas State Hwy 176 within an ease property. An evaluation assessing the hazards to and subsequent vapor cloud explosion followi 1.91 determined that the distance between t to preclude any adverse impacts to the fac*

owned by ompany) ialists eak There is a IO inch diameter bu southern boundary of New Mex hazard to the WCS CISF based o g the western and from the WCS C

eline oes not present a product and its distance 0 feet at its closest point.

s started construction on a travel stop in New ection of New Mexico Highway 18 and 0,000 gallons of diesel fuel, 28,000 ns of non-flammable Diesel Exhaust Fluid an s.

Response Guide 128 [12-4] recommends a ce for ignitable liquid tank fires which is much less than the 3.5 he Travel Stop to the closest point at the WCS CISF boundary.

aluated in the Appendices Chapter 12 ( e.g., A.I 2, B.12, etc.) for each siders adiabatic heat up is the "Blockage of Air Inlets/Outlets." An io using the blockage of air inlets and outlets to analyze adiabatic heat t with the guidance given to NRC reviewers in NUREG 1567 [12-5].

pie, NUREG-1567, Section 6.5.1, "Decay Heat Removal Systems" describes ockage of ventilation passages" as a required thermal analysis for determining the performance of cask heat removal systems. Likewise, Section 15.5.2.8 of NUREG-1567, "Adiabatic Heatup," states that "the reviewer should verify that the configuration of the SSCs has been defined, (i.e., all inlets and outlets blocked (for casks) and cooling systems or pumps inoperable (for pools))."

Page 12-8

WCS Consolidated Interim Storage Facility Safety Analysis Report Revision 3 Interim 12.3 References 12-1 NRC Regulatory Guide 3.48, "Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel Storage Installation or Monitored Retrievable Storage Installation (Dry Storage)," Rev. 1.

12-2 American National Standards Institute, American Nuclear Society, 1984, Design Criteria for an Independent Spent Fuel Storage Ins Type).

12-3 Proposed SNM-1050, WCS Consolidated Interim Storage Specifications, Amendment 0.

12-4 Emergency Response Guide 128, Emergency Res Department of Transportation, Pipeline and Ha 12-5 12-6 12-7 Administration.

NUREG-1567, "Standard Review Plan for Revision 0, U.S. Nuclear Regulatory Commi and Safeguards, March 2000.

NUREG-1536, "Standard Revi General License Facility," R of Nuclear Material Safety an ISP Calculation "Hazard Analys Revision 0.

Page 12-10 age Facilities,"

uclear Material Safety Storage Systems at a y Commission, Office

RAls and Responses Consolidated Emergency Response Plan (CERP)

RAI EP-1:

Clarify the approval authority for the proposed CERP.

The regulation in 10 CFR 72.44{f), states, in part: "A licensee shall follow an emergency plan that is approved by the Commission." However, th March 16, 2017, states:

A Draft WCS Emergency Response Plan (ERP) is included as WCS is required to seek agreement state approval for chan a draft version is provided until such time that NRC appro agreement state approval may be sought.

This information is necessary to determine complian Response to RAI EP-1:

Enclosure X to E-XXXX The proposed CERP must be approved Environmental Quality (TCEQ) before it NRC to comply with the provisions in 10 follow and maintain in effect an emergenc TCEQ must approve the proposed CERP Emergency Response Plan ERP) in place ommission on ust be approved by the

"A licensee shall facilities at the Waste Co

alists site Material License (RM Impact:

response activities for both the WCS facilities. A consolidated plan is ntrol Specialists SP&D facilities would ersonne,

in close proximity. It also ensures the edness activities (e.g., development, coordination, drills, ery planning activities) for all facilities and would help assure of responders as to what to do in an emergency.

d consolidated CERP first by the NRC, with the intent of RC's approval and any proposed revisions. The TCEQ review will be effects that the amended plan has on Waste Control Specialists SP&D

) suggested by the TCEQ will be re-submitted to the NRC for a final P will not become effective until it is approved by both the NRC and ority and process for amending the CERP once it has been initially approved and TCEQ are discussed in the response to RAI EP-16.

No change as a result of this RAI.

Page 75 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-2:

Identify any part of the CERP that does not apply to the 10 CFR 72.32(a) requirements for the CISF.

Section 3.1, "Classification System," of RG 3.67 states in part:

The licensee should clearly identify any part of the emergency plan doe licensed by the NRG.

This information is necessary to determine compliance with 10 C Response to RAI EP-2:

ISP has revised the draft CERP to better differentiate requirements (including those in 1 O CFR 72.32(a)),

TCEQ requirements.

Impact:

Page 76 of 116

RAls and Responses -

Enclosure X to E-XXXX RAI EP-3:

Provide the location where emergency response personnel will observe indications for fire and smoke alarms and for radiation monitoring instrumentation.

Section 2.2, "Detection of Accidents," of the proposed CERP states, in part:

Detection of accidents is dependent on personnel observation, by fire a radiation monitoring instrumentation.

The proposed CERP should state the specific location where pe of alarms and radiation monitoring instrumentation for the det ensure accurate and timely emergency classification.

This information is necessary to determine complianc 72.32(a)(4).

Response to RAI EP-3:

The fire, smoke and radiation alarms and

the central alarm panel located within t Administration Building. The CAS is ma the detector is located and at the central outside the Security and Administration B Incident Commander (IC) immediately. The for obtaining initial inform ass on to emergency classificatio F will be monitored from in the Security and h in the building where es obs g an alarm from is/her supervisor and the serv1 alarm is also responsible ecurity to facilitate accurate and timely eflect where the fire, smoke and radiation Impact:

Page 77 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-4:

Clarify the statements in Section 3.1, "Classifications of Accidents," of the proposed CERP, which refer to classification of accidents at the proposed CISF for both an Alert an Site Area Emergency declarations.

The provisions of 10 CFR 72.32(a)(3), "Classification of accidents," only re classification for accidents at an independent spent fuel storage installa

CFR 72.32(b)(3) requires a classification for accidents at a monitored as either an "alert" or "site area emergency."

Section 3.1, of the proposed CERP states, in part:

Emergencies are classified as an Alert or Site Area Eme This information is necessary to determine complian Response to RAI EP-4:

ISP has revised Section 3.1, including Ta classifications of accidents are specific SP&D facilities or WCS CISF). Per 10 C proposed WCS CISF includes only an Al apply to accidents that fall under TCEQ re Specialists SP&D Facilities.

Impact:

ERP to clarify which ste Control Specialists of accidents at the ergen assification would only

pacting the Waste Control B have been revised as described in the response.

Page 78 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-5:

Clarify the statements in Table A, "Emergency Classification," of the proposed CERP, which refer to a response to an Alert classification at the proposed CISF.

The provisions of 10 CFR 72.32(a)(8) states, in part:

The licensee shall also commit to notify the NRC operations center imm notifications of the appropriate offsite response organizations and not the licensee declares an emergency.

Table A of the proposed CERP for response to a Site Area E part:

... Notify state and local agencies.

Notify the NRC Operations Center immediately after o than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after declaring a Site Area Emergency.

However, there is no statement regardin the NRC Operations Center for an Ale Response to RAI EP-5:

ISP has replaced Table SP&D Emergency Cl

) in the draft CERP with Tables A (WCS Emergency Classifications).

ify appropriate offsite response ed state and local agencies. Per 1 O CFR C Operations Center immediately after off-ter than 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after an Alert is declared.

e of Texas, as an agreement state, in accordance with NUREG-

ng at the WCS SP&D facilities.

able B) has been revised as described in the response.

Page 79 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-6:

Clarify the individual (designated emergency response organization (ERO) position) on site at all times (24-hour per day, 7 days per week) with the authority and responsibility t accurately and timely perform emergency classification, and notify offsite agencies and the Section 4.4, "Incident Commander (IC)," of the proposed CERP states, in The IC or alternate is on the facility premises or on call 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a da le to respond rs). In the IC to an emergency by reaching the facility within less than one houri

work, absence or unavailability of the primary IC, an alternate IC is de

n ed as the p under a delegation of authority memorandum.

Section 4.4.1, "Delegation and Assignment," of the prop These personnel may not always be present at the ti occurs. One of the /Cs ted Emergency listed in Attachment F, Emergency Information List of Response, is always on-call. If the on-call IC is not at the those individuals present at the facility through communica he I she is available to Section 5.1.3, "Initial Response and No WCS Security Officers are trained to ass during these times. Upon detecting a perc and notification ersonnel on duty will immediately inform the IC.

The CERP in mander (IC) or alternate as the primary ccurately and timely perform emergency NRC. These individuals are on the facility IC are not onsite and cannot be reached in 15 minutes, a e on-site has the responsibility to perform emergency and no offsite agencies and the NRC. In most cases this will be re always onsite) specifically trained and qualified in classifying uired notifications. Security personnel will either be patrolling the site

~dministration Building where fire, smoke and radiation alarms and CS CISF will be monitored from a central alarm panel (see response to nated security person will be trained and have the authority to make ations provide notification to the NRC within one hour.

Page 80 of 116

RAls and Responses

Enclosure X to E-XXXX The CERP has been revised in Section 4.4. 1 and 5. 1.3 to designate an individual who can assume the authority and responsibility to perform emergency classifications, and notify offsite agencies and the NRC in the event that the IC or alternate I Cs are not onsite and cannot be reached in 10 minutes. The revised CERP includes requirements that the individual performing this role be; 1) verified as being onsite when there is no IC present; 2) understand his role in making an emergency classification and notifying the NRC within one hour; 3) ceived the proper training.

Impact:

CERP Sections 4.4.1 and 5.1.3 have been revised as described in Page 81 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-7:

Clarify the NRC's responsibilities for detecting, measuring and supervising cleanup for a release of Agreement State licensed radioactive materials at the proposed CISF.

Section 4.11, "Coordination with Participating Government Agencies," of the states, in part:

The OSHS [Department of State Health Services], TCEQ [Texas Co Quality] and NRC have responsibilities for detecting, measuring, a radioactive materials that are released into the environment.

This information is necessary to determine compliance with Response to RAI EP-7:

The NRC's roles and responsibilities for incident resp NUREG-0728, NRC Incident Response Plan, Revision 4, are described in

. The plan states in part:

"For incidents involving facilities Agreement

State, NRG i

Nuclear/Radiological Incident specified Federal-level response the agency's authorities and respo Federal agencies related to the activities related t incident; (3) operations;

storage, by the NRG or an cy under the performs the consistent with ordinating actions of nse; oordinating Federal of the radiological aspects of the 1ties related to Federal response technical data (collection, analysis, ring Federal protective action nd effective manner and providing al governments for implementation; ation to the public; (7) coordinating rmation to Congress; (8) informing the White House on all ent; and (9) ensuring coordination of demobilization of ignated cooperating agencies (e.g., DOE, EPA, USDA) ort to the NRC."

's roles nd responsibilities for incident response and recovery (which entially the same whether the accidental release of radioactive aste Control Specialists SP&D facilities or at the WCS CISF. NRC's anup of radioactive materials released by either an Agreement State e, would be coordinating Federal activities related to response and gical aspects of the incident.

The primary onsibility for dealing with an incident (and cleanup) originating at the Waste Control Specialists SP&D facilities remains with the licensee - Waste Control Specialists.

Page 82 of 116

RAls and Responses Enclosure X to E-XXXX Under its response plan, NRC would provide advisory support and assist in diagnosing the situation, help isolate critical problems, and determine what courses of action and additional precautionary measures are necessary and appropriate. NRC would advise the licensee and, as applicable, State/local/tribal authorities and other Federal agencies.

Section 4.11 has been revised to clarify NRC roles and responsibilities in assist" incident response and recovery activities by adding the following text:

"In responding to a Site Emergency or Alert and subseque cleanup of radioactive material releases), NRC would provi and assistance in diagnosing the situation, help isolate determine what courses of action and additional prec tio ary measu necessary and appropriate, in accordance with the N ident Response (NUREG-0728, Revision 4)."

Impact:

CERP Section 4.11 has been revised as described in Page 83 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-8:

Clarify what State (Texas and/or New Mexico) and local response organizations that are notified at the declaration of an Alert classification. Additionally, what is the timing of these notifications?

Section 4.10, "Activation of the ERP [Emergency Response Plan]," of the pro states, in part:

Activation for any reason is reported to the TCEQ Region 7...

If an emergency is declared notify the OSHS emergency nu contacting off-site response agencies...

This information is necessary to determine compliance Response to RAI EP-8:

rganizations to be contacted when an Alert is declared is down procedure EP-1.1 - Consolidated Emergency t is also referenced in Tables A and B in Section 3.1 and in Section

, Standard Format and Content Guide for Emergency Plans for Fuel s Facilities, Revision 1, April 2011 Impact:

CERP Section 3.1, 4.10 and Table A and Table B have been revised as described in the response.

Page 84 of 116

RAls and Responses Enclosure X to E-XXXX Page 85 of 116

RAls and Responses Enclosure X to E-XXXX Page 86 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-9:

Clarify how the source term is determined for a release from the proposed CISF.

Section 5.2, "Accident Assessment," of the proposed CERP states, in part:

The WCS inventory program can provide a real time radiological source term tracking program can provide immediate real time information on the radio stored in the specific areas impacted by the incident/accident.

This information is necessary to determine compliance with 10 CF Response to RAI EP-9:

As stated in Section 11.1 of the SAR:

"In general, all of the canisters to be stored leak tight under all normal, off-normal, and a confinement of the SNF or GTCC waste is main only exceptions to this are the FO-, FC-, FF-Dry canisters) that were leak teste a leakage rate confinement evaluation for thes

s presented i ak tigti nisters. Table A.11-6 Cm-244 Kr-85 Pu-240 Eu-154 Pu-239 The following Table based 1fy what the accident source r the FO-, FC-, FF-Dry Storage Accident (Ci/sec) 4.055E-13 Volatile 4.055E-13 Volatile 2.614E-13 Volatile 2.614E-13 Fine 9.253E-13 Fine 1.341E-13 Fine 9.737E-14 Fine 3.416E-14 Gas 1.576E-08 Fine 1.837E-14 Fine 1.598E-14 Fine 1.120E-14 Page 87 of 116

RAls and Responses Enclosure X to E-XXXX Accident Nuclide Type (Ci/sec)

Ni-63 Fine 1.042E-14 Sm-151 Fine 1.010E-14 H-3 Gas 2.193E-09 Np-239 Fine 1.020E-15 Am-243 Fine Am-242m Fine Am-242 Fine Cm-242 Fine Cm-243 Fine 1-129 Gas Co-60 Crud Note:

le canister.

Source:

CS Consolidated Interim Impact:

Page 88 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-10:

Clarify if there are agreements in place or a memorandum of understanding with the New Mexico State Police.

Section 5.3.1, "Mitigation of Fires," of the proposed CERP states, in part:

In the event of a catastrophic fire, the Andrews and Lea County Sheriff's Department of Public Safety and/or the New Mexico State Police are traffic along Highway 176 and evacuating any of the general public may be affected by windblown or gaseous wastes.

This information is necessary to determine compliance with Response to RAI EP-10:

he Texas Department e De nt, the Andrews County t for the Waste Control Specialists SP&D Police Department, the Andrews Police rtments are responsible for coordinating ement, traffic control and evacuation Specialists site) within their respective e

assistance from the New Mexico State quest assistance from Texas Department of arts to coordina e traffic control and evacuation services.

lication is approved, the Agreements with the Eunice Police epartment and Andrew County Sheriff's Department will be and implemented after a 60-day comment period.

a catastrophic fire, the Andrews Police Department and the y Sheriffs Department in Texas and the Eunice Police New Mexico are responsible for directing traffic along Highway ing the evacuation of any of the general public surrounding the facility be affected by windblown or gaseous wastes. These parties may request assistance from the Texas Department of Public Safety and/or the New Mexico State Police as needed."

Page 89 of 116

RAls and Responses Enclosure X to E-XXXX Impact:

CERP Section 5.3.1 has been revised as described in the response.

Page 90 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-11:

Clarify if there are agreements in place or a memorandum of understanding with the State of New Mexico for notification of the transportation of a contaminated person for trea ment at a medical facility in New Mexico.

Section 5.3.5, "Mitigation of Injuries," of the proposed CERP states, in part*

The primary treatment facility for radiological contaminated individual Medical Center in Carlsbad, New Mexico....

This information is necessary to determine compliance with 1 Response to RAI EP-11:

There are currently no agreements or memorandum Mexico for notification of the transportation of a conta facility in New Mexico.

ISP has revised Section 5.3.5 of the CER of Homeland Security and Emergency are being routed to the Carlsbad Medica Center in a timely manner of incoming pa medical center added time to call in any er and to make arrangements for isolating an Impact:

Page 91 of 116 he New Mexico Department ted person or persons Carlsbad Medical

. This will enable the

RAls and Responses.

Enclosure X to E-XXXX RAI EP-12:

Clarify what recommended protective actions will be provided to off-site response organizations for the design-basis accidents at the CISF related to the ISFSI.

Section 5.4.5, "Off-site Protective Actions," of the proposed CERP states, in After declaration of a Site Emergency, the IC has the authority to recom actions. The IC or designee will make off-site notifications to local aut This information is necessary to determine compliance with 10 C Response to RAI EP-12:

ISP has revised CERP Section 5.4.5 to clarify that pro response organizations for the design-basis acciden revised CERP Section 3.1 to clarify that site area eme Specialists SP&D facilities (see Table A in the revised C classification that applies to the WCS CISF is an Alert (see ot needed for off-n addition, ISP has ly to Waste Control ly emergency reated Table B).

s that protective action sis results in NUREG-and Other Material

s. NUREG-1140 Section 3.6.4 of Interim Staff Guidance recommendations for dry cask storage s 1140, A Regulatory Analysis on Emergen Licensees, and the limits in EPA's Manual calculates the effective dose equivalent for ecte ent for dry cask and dry vault storage of spent fuel 003 rem a ers for Stability Class F and 1 m/s wind 05 to 0.04 rem within 100 meters. These for taking protective action after an speed and that the chil doses are below the accident. TherefO[

not necessary f

References:

and recommended protective actions are I storage in dry casks.

sis on Emergency Preparedness for Fuel Cycle and Other n Guides and Protective Actions for Nuclear accidents, U.S.

Agency, 1992 and 5.4.5 have been revised and new Table B has been added as Page 92 of 116

RAls and Responses -

Enclosure X to E-XXXX RAI EP-13:

Revise the threshold limits in Section 5.5, "Exposure Control," and Table 8, "Protective Action Guidance," of the proposed CERP to ensure consistency with the latest version of the U.S.

Environmental Protection Agency (EPA) Protective Action Guide (PAG) Manual arly phase PAGs.

Section 5.5, "Exposure Control," of the proposed CERP states, in part:

The PAG threshold of concern for WSC is based on the EPA limits Committed Effective Dose Equivalent (CEDE), five Rem thyroid, boundary.

Reference - "Manual of Protective Action Guides and Office of Radiation Programs, USEPA, 1992 ensure consist Protective Acti Table C were cha

, "PAGs for the Early uides and Protective Actions

, "Summary Table for f the PAG Manual:

s (EPA-400/R-17/001,

.5 and designated the table as Table C to Environmental Protection Agency's (EPA) e PAGs. Specifically, the doses in REM in AGs. The recommended actions listed in PAG but are worded slightly different to more closely match the

on Gui and Protective Actions for Nuclear Accidents, U.S.

Agency, 1992 Table C have been revised as described in the response.

Page 93 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-14:

Provide a basis for the size of the emergency planning zone (EPZ) with respect to the CISF, and clarify the definitions for chief elected officials in Section 5.9, "Emergency Pia ning Zone,"

of the proposed CERP.

Section 5.9 of the proposed CERP states, in part:

Based on the potential consequences of postulated emergencies, the has been defined as 6km [kilometer] (3. 7 mile) radius circle center<

Section 5.9 further states:

The size of the EPZ is sufficiently large that:

Detailed planning within the EPZ provides both reasonably credible accidents and a substantial b responding to all ion of response efforts ocal agencies and other in the event that this proves necessary by WCS, Sta organizations responsible for off-site emergency respon Projected maximum doses resultin meteorological conditions, within the outside the EPZ.

Z will provide the public acility and, based on inputs from the site otective actions, such as sheltering or agreements or a memorandum of e proposed size of the EPZ includes s an NRG-licensed fuel facility. The NRC ation on the definition of "Chief elected officials," as referenced in termine compliance with 10 CFR 72.32(a)(1) and 10 CFR Zone at the Waste Control Specialists site was established based on ents that could occur at the Waste Control Specialists SP&D Facilities.

mplement emergency response actions resulting from those

. The WCS CISF could be impacted because it is located within the Waste ts SP&D Facilities EPZ. ISP has revised CERP Section 5.9 to clarify this.

Page 94 of 116

RAls and Responses Enclosure X to E-XXXX The WCS CISF does not require the establishment of a separate EPZ because the Commission determined in NUREG-1140 that offsite emergency preparedness and recommended protective actions are not necessary for design-basis accidents for spent fuel storage in dry casks or dry vaults (See response to RAI EP-12). Thus, the EPZ established for the Waste Control Specialists SP&D Facilities is not used to plan and implement emergency respons actions resulting from incidents/accidents originating at the WCS CISF.

Section 4.11 of the CERP discusses the Texas Chief Elected Officials. Ne will go to New Mexico Department of Homeland Security and Emergenc

References:

NUREG-1140, A Regulatory Analysis on Emergency Prepare Material Licensees, August 1991.

Impact:

CERP Section 5.9 has been revised as described in ttl Page 95 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-15:

Provide a description, by position or title, of the person responsible for developing, maintaining and updating the CERP.

Section 7.0, "Maintaining Emergency Preparedness Capability," of the propo include the identification of the personnel responsible for developing, main the plan, as required in 10 CFR 72.32(a)(7).

This information is necessary to determine compliance with 10 CF Response to RAI EP-15:

ISP has revised CERP Section 7.1 to designate the prim individual responsible for developing, maintaining and Commander also serves as the Vice PresidenUSite Impact:

CERP Section 7.1 has been revised as d Page 96 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-16:

Clarify that the change process for the proposed CERP under the QA [Quality Assurance]

Program will be evaluated in accordance with 10 CFR 72.44(f), and that maintenance and updating of the CERP will be consistent with the requirements of 10 CFR 72.32

).

Section 7.1, "Written Emergency Plan Procedures," of the proposed CERP Changes to ERP-100, Emergency Response Plan, and EP-1.1, Cons Response, are composed in accordance with QA-5.1, Standard Op Work Instructions.

This information is necessary to determine compliance with requirements of 10 CFR 72.32(a)(14).

Response to RAI EP-16:

A decrease in effectivenes methods identified in t change, which resul planning function.

emergency pla changes have ponse Plan will comply with nges to the CERP that may r the changes decrease the the following guidance ocess for Making and the criteria used ease in the capabilities, resources or ctions or measures to compensate for the

's capability for performing an emergency nges on the effectiveness of the ined, not just the effect that individual the effectiveness of the approved CERP, then ISP will make eport (in accordance with 10 CFR 72.4) describing the changes to a change is made. If the changes would decrease the P, then ISP would not implement those changes until it has

nally, ISP will comply with 10 CFR 72.32(a)(14) to the change o portions of the CERP that address NRC requirements. ISP ge control process from 10 CFR 72.44(f) and 10 CFR 72.32(a)(14) ft CERP.

as been revised as described in the response.

Page 97 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-17:

Clarify how the training of the staff at the Lea Regional Medical Center and Carlsbad Medical Center by the Waste Isolation Pilot Plant (WIPP) is verified and documented.

Section 7.2.3, "Off-Site Response Teams," of the proposed CERP states, in Currently, the staff at the Lea Regional Medical Center in Hobbs, New Medical Center in Carlsbad, New Mexico train with WIPP.

This information is necessary to determine compliance with 10 C Response to RAI EP-17:

All emergency organizations, including the Lea Regio Center, are offered participation opportunities to drill ISP will request written verification and documentation Medical Center and Carlsbad Medical Center have partic obtained. The CERP Section 7.2.3 has been updated to re Impact:

CERP Section 7.2.3 has been revised as Page 98 of 116 nd Carlsbad Me e facility. Annually that Lea Regional WIPP and any training se commitments.

RAls and Responses Enclosure X to E-XXXX RAI EP-18:

Clarify or revise the frequency and scope of the emergency planning drills and exercises, as provided in Section 7.3 of the CERP.

Section 7.3, "Drills and Exercises," of the proposed CERP states, in part:

Emergency drills and exercises are conducted systematically....

[...]

Consistent with the requirements in 10 CFR 72.32 (a) and (b),

communications checks with off-site response organization mented quarter, nclude the check an of all necessary telephone numbers."

This information is not consistent with 10 CFR 72.32

[p]rovisions for conducting semiannual communications organizations and biennial onsite exercises to test respons hich states, in part:

Radiological/Health Physics, Medical, an ire drills shall be Section 7.3 of the proposed CERP does physics, medical, and fire drills to be con exercise. Additionally, communication che as identified in Section 7.3.

This information is nee iennial onsite exercises ted emergencies Radiological/H Ith Physics, Medical, and Fire drills shall be conducted annually 10 CFR Part 72.32(a) (12) (i) and (II),

ssed in the updated WCS CERP.

Location Addressed in CERP The 61h paragraph of Section 7.3 is updated to add a reference to 10 CFR 72.32(a) to indicate that the quarterly communications checks with off-site response organizations currently in the plan are those used to fulfil the semiannual requirement in the regulation.

The 5 th paragraph of Section 7.3 requires that the CERP be fully exercised twice per year. This would include testing responses to simulated emergencies.

The 5 th paragraph of Section 7.3 is updated to require Radiological/Health Physics, Medical and Fire drills be conducted annually at the CISF.

Page 99 of 116

RAls and Responses 10 CFR 72.32(a)(12)(i)

Semiannual communications checks with offsite response organizations must include the check and update of all necessary telephone numbers.

The licensee shall invite offsite response organizations to participate in the biennial exercise.

10 CFR 72.32(a)(12)(ii)

Participation of offsite response organizations in biennial exercises, although recommended, is not required.

Exercises must use scenarios not known to most exercise participants.

The licensee shall critique each exercise usin individuals not having direct implementation responsibility for conducting the exercise.

Critiques of exercises mu appropriateness of the procedures, facilitie personnel, and ov.

response.

Enclosure X to E-XXXX Location Addressed in CERP The 5th paragraph of Section 7.3 requires updates to all necessary telephone numbers as part of the quarterly communications checks with off-site response organizations.

The 5 th paragraph of Section 7 response organizations will in exercises that are requ*

year.

n 7.3 states that each ritiqued using individuals implantation responsibility 5 th paragraph of Section 7.3 states that itiques of the exercises will evaluate the ropriateness of the CERP, emergency edures, facilities, equipment, training of nnel, and overall effectiveness of the incident The 51h paragraph of Section 7.3 requires that any deficiencies found by the critiques be entered into the corrective action program for resolution.

Page 100 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-19:

Justify why the most recent version of the NRC endorsed methodology for the development of emergency action levels (EALs) was not used in the development of the EALs for he WCS CERP specific to the CISF.

The guidance used by the industry for the development of EALs is the Nuc (NEI) document, NEI 99-01 "Development of Emergency Action Levels f Reactors," Revision 6, dated November 2012 (ADAMS Accession No Specifically, Section 1.3, "Independent Spent Fuel Storage lnstallat" guidance on the development of EALs for an ISFSI.

This information is necessary to determine compliance wit Response to RAI EP-19:

A new Appendix D of the CERP "WCS CISF Facility using NEI 99-01 "Development of Emergency Action Lev Revision 6, dated November 2012 to develop EALs applica section now references use of the NEI g *

References:

NEI 99-01 "Development of Emergency A dated November 2012 (ADAMS Accession Impact:

Page 101 of 116

RAls and Responses Enclosure X to E-XXXX RAI EP-20:

Justify the Alert criteria and the dose thresholds used for the radiological plume incident in Appendix C, "Facility Emergency Action levels," of the proposed CERP.

Appendix C contains the following Alert criteria for a radiological plume incide

>100 mrem CEDE but <500 mrem CEDE from an accidental release of r..

the general public.

or------

>1 rem CEDE in a Facility from an accidental release of ra Additionally, Appendix C contains the following Site Ar plume incident:

>500 mrem CEDE but <1 rem CEDE from an accidental general public.

or------

>1 rem CEDE, calculated at a facility bou e of radioactive material to Facility workers.

These criterion are not co NUREG-1140, "A Reg Radioactive Material Additionally, the Emergency cla thresholds for dry cask storage of spent fuel in y Preparedness for Fuel Cycle and Other 8, (ADAMS Accession No. ML062020791).

f the typical thresholds for a Site Area or the use of these radiation levels as 1ngly.

inconsistent with NRC-endorsed EAL rmine compliance with 1 O CFR 72.32(a)(3).

in Appendix C of the earlier draft CERP was developed for the Waste Facilities and is not applicable to the WCS CISF. As explained in the

, the CERP has been revised using NEI 99-01 "Development of evels for Non Passive Reactors," Revision 6, dated November 2012 to develop EA ecific to the WCS CISF. Appendix D, WCS CISF Facility Emergency Action Levels, has been added to the CERP to address those EALs. This revision assures that the CODE dose threshold is consistent with both NEI 99-01 "Development of Emergency Action Levels for Non Passive Reactors," Revision 6, and NUREG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees," dated January 1988.

Page 102 of 116

RAls and Responses Enclosure X to E-XXXX Appendix C of the CERP has been revised to clarify that it applies only to the Waste Control Specialists SP&D Facilities and not the WCS CISF. Additionally, a new Appendix D, WCS CISF Facility Emergency Action Levels, has been added to the CERP.

References:

NUREG-1140, "A Regulatory Analysis on Emergency Preparedness for Fuel Radioactive Material Licensees," dated January 1988 NEI 99-01 "Development of Emergency Action Levels for Non Passiv dated November 2012 Impact:

CERP Appendix C has been revised and a new Appendi the response.

Page 103 of 116

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