ML19088A098
| ML19088A098 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 03/28/2019 |
| From: | Westinghouse |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML19088A095 | List: |
| References | |
| CAC L33317, LTR-RAC-19-22 | |
| Download: ML19088A098 (4) | |
Text
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 1 of 4 Our ref: LTR-RAC-19-22 March 28, 2019 1
January 2019 RAI #2 Response for Environmental Report, Environmental Protection Program, and Decommissioning Planning REQUEST FOR ADDITIONAL INFORMATION REG BASIS WESTINGHOUSE RESPONSE RAI 2 Provide an updated License Renewal Application (LRA) Chapter 10
- Environmental Protection and any other corresponding changes to the LRA Chapter 11 - Decommissioning. Updates should include:
Any proposed changes to the environmental protection program and/or decommissioning programs; 10 CFR 70.22(a)
Westinghouse is providing a revised LRA, with updated information responsive to this RAI. The changes described establish programmatic controls to ensure repeatable outcomes, including how Westinghouse will address impacts from past operations using the EPA CERCLA process and how Westinghouse will operate the CFFF to minimize the potential for future impacts. These changes include the following:
Program Changes o Section 10.1 has been revised to more accurately describe the CFFF Environmental Protection Program and to add the March 2019 Environmental Report (ER) revision.
o Section 10.1.1 has been revised related to the reporting requirements for gaseous effluents.
o Editorial changes were made in Section 10.1.4.
o Section 10.1.5 was added to include the use of a Conceptual Site Model (CSM) and Operable Units (OUs) as part of the environmental protection program. The characteristics of each OU, combined with the CSM, will inform the sampling and monitoring program.
o Section 10.1.6 was revised to clarify what is contained in the annual ALARA report. Section 10.1.6 was also revised related to groundwater monitoring reports and the Westinghouse and South Carolina Department of Health and Environmental Control (SCDHEC) Consent Agreement.
o Section 10.1.7 has been revised related to reporting for off-site dose.
Section 10.1.7.2 has been added stating that a CAP shall be entered for
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 2 of 4 Our ref: LTR-RAC-19-22 March 28, 2019 2
Any proposed changes to environmental monitoring that account for (1) potential release mechanisms, including underground piping; (2) migration pathways; and (3) all potential receptors - onsite and offsite; new exceedances of federal or state regulatory limits for surface water or well water.
o Table 10.1 has been revised to require analysis of environmental samples for uranium and Tc-99 versus alpha and beta indicator parameters. This analysis provides a better characterization of potential radionuclide impacts that could originate from the CFFF.
o Table 10.2 has been revised to add monitoring wells and analyses for groundwater.
o Table 10.3 has been revised to require analysis of environmental samples for uranium and Tc-99 versus alpha and beta indicator parameters.
o Chapter 11.0 has been revised to cite the contamination control and waste minimization methods implemented at the site to minimize contamination and reduce exposures to effluents. Discussion of the sites remediation process has also been added.
o Authorization 12.1.1 has been revised to state that Westinghouse may make changes to the License Application without prior NRC approval provided the change does not affect Section 10.1.7.2.
Environmental Monitoring o Section 10.1.2 has been revised with editorial changes and to reflect that samples are analyzed for isotopic uranium and Tc-99 content.
o Section 10.1.5 was added to include the use of a CSM and defined OUs for the site. Maintaining a current CSM, in conjunction with defined OUs, addresses (1) potential release mechanisms, including underground piping; (2) migration pathways; and (3) all potential receptors - onsite and offsite.
In addition, the established groundwater monitoring program will ensure timely detection of inadvertent releases to the environment.
o Tables 10.1, 10.2, and 10.3 have been revised to reflect the new monitoring requirements.
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 3 of 4 Our ref: LTR-RAC-19-22 March 28, 2019 3
Any proposed changes to the environmental sampling program (e.g., environmental media, frequency, locations, constituents, number of samples etc.);
Any changes to the quality assurance, quality control, and laboratory analyses procedures; and Westinghouses decision-making process for determining if residual radioactivity is significant, and if so, what Westinghouses approach is for determining if further investigation or remediation is necessary, per Regulatory Guide 4.22.
The regulations in 10 CFR 20.1406(c) and 20.1501(a) require licensees to minimize contamination of the environment, including the subsurface and to characterize subsurface contamination, respectively. The Environmental Sampling Program o Changes to the sampling program are detailed in the Chapter 10 description above, to include:
Change from gross alpha/beta to uranium and Tc-99 sample types.
Sampling and analysis of 40 monitoring wells.
o Tables 10.1, 10.2, and 10.3 have been revised to reflect the new sampling requirements.
Quality Assurance Changes o Section 10.1.4 has been revised to describe new analytical methods utilized.
o Decommissioning recordkeeping requirements were clarified in Section 11.1 and 11.1.1.
Decision Making o Section 10.1.5 was added to include the use of a CSM and defined OUs for the site. Maintaining a current CSM in conjunction with the OUs addresses (1) potential release mechanisms, including underground piping; (2) migration pathways; and (3) all potential receptors - onsite and offsite.
o Section 11.1.1 has been revised to include discussion of the sites remediation process. CFFF has developed a site specific remediation process to establish programmatic controls and a repeatable process for how CFFF will respond to environmental issues on a going forward basis.
The purpose of the remediation process is to prevent migration of licensed material and/or contamination off-site and to minimize the impacts to future decommissioning. In the event of a release, whether recent or newly detected, this remediation process will be followed to determine the appropriate steps.
The process outlines the key components in decision making for either remediating the release or documenting the decision not to remediate. In each
WESTINGHOUSE NON-PROPRIETARY CLASS 3 Page 4 of 4 Our ref: LTR-RAC-19-22 March 28, 2019 4
regulations in 10 CFR Part 70.22(a) require an applicant to demonstrate that proposed facilities, equipment, and procedures are adequate to protect the public health and minimize danger to life or property.
instance, the process involves updating and analyzing the data in the CSM, including the migration pathways and potentially affected receptors. This process also guides the evaluation and documentation of the decommissioning impacts resulting from the remediation actions or the absence thereof.
The process assures CFFF actions are protective of human health and the environment, meet regulatory requirements and prevent off-site migration of contamination.
The basis for the remediation process includes guidance from NRC Regulatory Guide 4.22, Decommissioning Planning During Operations, December 2012 and Nuclear Energy Institute (NEI), Industry Groundwater Protection Initiative Final Guidance Document (NEI 07-07), Revision 1, March 2019.