ML20132A091
| ML20132A091 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center, Vallecitos |
| Issue date: | 06/03/2020 |
| From: | Jack Parrott Reactor Decommissioning Branch |
| To: | Feyrer M GE-Hitachi Nuclear Energy Americas |
| J PARROTT | |
| References | |
| Download: ML20132A091 (4) | |
Text
June 3, 2020 Matt J. Feyrer, Site Manager Vallecitos Nuclear Center GE Hitachi Nuclear Energy 6705 Vallecitos Road Sunol, CA 94586
SUBJECT:
VALLECITOS NUCLEAR CENTER ANNUAL SHUTDOWN REACTOR REPORTS FOR THE YEAR 2019 - REQUEST FOR ADDITIONAL INFORMATION
Dear Mr. Feyrer:
By letter dated March 25, 2020 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML20086K769), GE Hitachi Nuclear Energy (GEH) submitted the annual reports for the deactivated reactors (Vallecitos Boiling Water Reactor (VBWR), ESADA-Vallecitos Experimental Superheat Reactor (EVESR), and the General Electric Test Reactor (GETR) located at the GEH Vallecitos Nuclear Center (VNC) near Sunol, California.
Upon review of these reports, the U.S. Nuclear Regulatory Commission (NRC) staff has a request for additional information to better understand the radiological status of these facilities as relates to GEHs planning for the eventual termination of their licenses.
RAI-1, Strontium-90 in groundwater Included in each report are the analytical results from recently installed groundwater monitoring wells at the shutdown reactors (wells W-9S and W-9D for VBWR and EVESR and well W-8 for GETR) and the previously existing well B-2 at GETR. The results provided include gross alpha, gross beta, and tritium. The NRC decommissioning guidance document NUREG-1757, Vol. 1, Rev. 2, Decommissioning Process for Materials Licensees, provides guidance on planning and implementing license termination under the NRCs License Termination Rule (LTR), in the Code of Federal Regulations (CFR), Title 10, Part 20, Subpart E. Appendix H of NUREG-1757, Vol.1, contains the Memorandum of Understanding (MOU) Between the U.S. Environmental Protection Agency (EPA) and the NRC on consultation and finality on decommissioning and decontamination at all NRC-licensed sites including reactor sites. In the MOU, NRC has agreed to consult with EPA on the appropriate approach in responding to the circumstances at sites with groundwater contamination, at the time of license termination, that is in excess of EPAs maximum contaminate levels (MCLs). The EPAs MCLs for radionuclides are in 40 CFR § 141.66 - Maximum contaminant levels for radionuclides. That regulation contains an MCL for beta particle and photon radioactivity. The MCL for beta particle and photon radioactivity is based on a dose standard of 4 mrem/year. However, the regulation contains specific MCLs for tritium (20,000 pCi/l) and strontium-90 (8 pCi/l).
NRC Reg Guide 4.25, Assessment of Abnormal Radionuclide Discharges in Ground Water to The Unrestricted Area at Nuclear Power Plant Sites, which provides guidance for licensees to
M. Feyrer meet the requirements of Title 10 CFR, Sections 20.1406(c) and 20.1501, endorses American National Standards Institute/American Nuclear Society (ANSI/ANS) 2.17-2010, Evaluation of Subsurface Radionuclide Transport at Commercial Nuclear Power Plants, (reaffirmed in 2016).
ANSI/ANS 2.17 presents a ranked list of radionuclides at nuclear power plants which might be appropriate performance indicators for evaluating the effects of subsurface radionuclide transport. Strontium-90 is ranked as the no. 1 radionuclide on that list.
At the end of the decommissioning process for the shutdown reactors at the VNC, NRC will consult with EPA on the concentration level of radionuclides in groundwater. Therefore, NRC is requesting that GEH, in its reporting on the radiological status of the decommissioning reactors at the VNC, include groundwater analytical results that cover strontium-90 for comparison to the EPA radionuclide MCL. Please also submit the complete tabulation of the reported analytical results from well B-2 from its first sampling year through 2019.
RAI-2, Other groundwater parameters Please also report any other groundwater parameters that are measured in the wells referenced above such as total dissolved solids, pH, oxidation, and sulfate/nitrate concentration. These parameters can be an indication of groundwater impact from site operations even without radionuclides present.
RAI-3, Other groundwater sampling points Observations made by NRC personnel during site visits and inspections indicate that there is a sump on the north side of the EVESR building and a well on the southwest corner of the EVESR condenser building (building 352) that collect groundwater. Please evaluate if these wells can be used as sampling points for groundwater monitoring of the EVESR licensed area going forward.
RAI-4, Background wells NUREG-1757, Consolidated Decommissioning Guidance, Vol. 2, Characterization, Survey, and Determination of Radiological Criteria, Rev. 1, provides guidance on planning and implementing license termination under the NRCs LTR. Appendix F, Ground and Surface Water Characterization, Section F.2, Ground Water Characterization, and Section F.3, Indicators for Potential Ground Water Contamination, gives general guidance for characterizing the groundwater where groundwater contamination is a potential concern. One aspect of an appropriate groundwater survey, to determine the presence of contamination is establishment of the background groundwater quality. Are there background wells at the VNC suitable for providing the background water quality in the areas of the shutdown reactors? If not, please describe how this information can be provided.
RAI-5, soil sample results Each of the annual reports contain a site map entitled VBWR & EVESR Site Map or GETR Site Map. Each of these maps display soil sample locations. However, there are no soil sample results in the reports. Please provide the soil sample results for the locations identified on the maps.
M. Feyrer The information requested and associated time frame in this letter were discussed with Scott Murray of your staff on June 3, 2020. Please respond within 30 days of the date of this letter.
If you have any questions, please call me at (301) 415-6634 or e-mail at Jack.Parrott@nrc.gov.
Sincerely, Jack D. Parrott, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs, Office of Nuclear Material Safety and Safeguards Docket Nos. 50-18, 50-70, and 50-183 cc:
GE Hitachi shutdown reactor service list
ML20132A091 *via email OFFICE DUWP DUWP DUWP NAME J.Parrott B.Watson* J.Parrott DATE 05/21/2020 05/21/2020 06/03/2020