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Nei/Nrc License Termination Process Improvements Public Meeting Slides - October 30, 2020
	ML20304A122
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Issue date:	10/30/2020
From:	Marlayna Vaaler Doell; Reactor Decommissioning Branch
To:	;
	Doell M 301-415-3178
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	Download: ML20304A122 (24)
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NRC/NEI Public Meeting on Enhancements to the License Termination Process October 30, 2020 1

Risk-Informing the Decommissioning Program Patricia Holahan, Director Division of Decommissioning, Uranium Recovery, and Waste Programs October 30, 2020

10 CFR 20.1402

A site will be considered acceptable for unrestricted use if the residual radioactivity that is distinguishable from background radiation results in a TEDE to an average member of the critical group that does not exceed 25 mrem (0.25 mSv) per year, including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA).

Decide Measure Translate

Modeling, Parameters, Derive Concentrations Survey and Sample Statistical Tests Release Criterion -

dose or risk level MARSSIM 3

NUREG-1757, Vol. 2

MARSSIM, Revision 2

First update since 2000

Updates that increase flexibility

- Scan only surveys

- Rank set sampling

- Scenario B (assumes release criteria are met)

- Consideration of elevated areas 4

NUREG-1757, Volume 2, Revision 2

First update since 2006

Updates that increase flexibility

- Composite sampling

- Scenario B (assumes release criteria are met)

- Consideration of elevated areas

- Subsurface surveys 5

Opportunities II.

Objectives III.

LTP Guidance IV.

Final Status Survey (FSS) Guidance V.

Licensee-NRC Communication VI.

Enhance Role of Independent Oversight VII. Next Steps Enhancing the License Termination Process Agenda:

Speaker Bruce Montgomery Gerry Van Noordennen Gerry Van Noordennen Sarah Roberts Ron Cardarelli, Willie Harris Bill Barley Bill Barley Bruce Montgomery

Mission: to enable the success of decommissioning projects by providing timely input and guidance on decommissioning-related policy, state/local community engagement, regulatory, legislative and legal issues, enabling NEI to most effectively respond to high-impact, highly-visible, and potentially contentious issues.

Members: CEOs from four major nuclear utilities, and four major decommissioning companies NEIs Role in Decommissioning

©2020 Nuclear Energy Institute 4 NEI Decommissioning Working Group Mission: a forum for consideration of matters related to the advance planning and execution of decommissioning activities from cessation of operations through license termination.

Eight areas of focus:

NEIs Role in Decommissioning (continued)

Policy Used Fuel Best Practices Low Level Waste Regulatory Framework International Licensing Activities Public Outreach

©2020 Nuclear Energy Institute 5 NEI Decommissioning Working Group Mission: a forum for consideration of matters related to the advance planning and execution of decommissioning activities from cessation of operations through license termination.

Eight areas of focus:

NEIs Role in Decommissioning (continued)

Policy Used Fuel Best Practices Low Level Waste Regulatory Framework International Licensing Activities Public Outreach

©2020 Nuclear Energy Institute 6 License termination plan content, consistency and quality Volume and types of FSS data to support reviews Role of independent surveys and quality assurance programs Communication between licensees, NRC HQ and Regions Risk informing the process: Maintain a focus on safety significance and environmental stewardship I. Opportunities:

Implementation of MARSSIM, Rev. 2, and Application of guidance in existing regulatory guides and NUREGs.

Focus and align Final Status Surveys (FSS) and reports on the objectives stated in the license termination plan.

Improve industry coordination with NMSS reviewers, regional inspectors, and independent oversight.

II.

Objectives:

MARSSIM (NUREG-1575) is a guidance document that allows for flexibility in the Final Status Survey Plan (FSSP).

Section 4 of NUREG-1757, Vol. 2 (Ref. 6) describes the evaluation criteria for the FSSP.

Include NRC Technical Reviewers for review and implementation of the LTP (in particular the FSSP).

III. LTP Guidance

Apply Risk Informed Decision Making to define extent of technical evaluation required when resulting additional dose when resulting dose is small (e.g., < 1 mrem) and final compliance dose not approach defined criteria (e.g., 25 mrem).

Include this guidance in the crosswalk for both licenses and NRC reviewers.

Consider adding the additional dose without extensive studies/paperwork.

III. LTP Guidance (continued)

Allow use of Screening Values for Structures and Surface Soils included in Appendix H of NUREG-1757:

Subsurface soil, buried pipe, buried concrete, etc. screening values currently not available.

Do not include groundwater dose contribution.

Applicability to large sites?

Consider approval of DCGLs in advance of full LTP approval (to remove potential for at risk work).

III. LTP Guidance (continued)

Chapter 8 of the LTP requires a Supplement to the ER: NRC regulation 10 CFR 50.82(a)(9)(ii)(G) requires that the licensee submit a supplement to the ER, pursuant to 10 CFR 51.53, describing any new information or significant environmental associated with the proposed termination activities Subject to review by state and local stakeholders.

Consider early submittal to expedite LTP approval process.

III. LTP Guidance (continued)

FSS Report format not well defined.

Number of submittals and RAIs is increasing.

A very high volume of data is being exchanged.

Duplicate sets of information are being submitted.

IV.

Final Status Survey (FSS) Report

A standard format and content (level of detail) for Final Status Survey (FSS)

Reports, and A communications protocol to engage NRC Technical Reviewers early in the FSS process to achieve:

Alignment around LTP requirements; In-process reviews of quality assurance and procedural requirements (hard-to-detect nuclides, insignificant contributors, instrumentation, investigation criteria, continuing characterization, subsurface contamination, DCGLs, etc.); and Early identification of technical issues and expediency in the FSS report review process.

IV. FSS Report (continued)

©2020 Nuclear Energy Institute 14 Engagement between licensees and NRC should be early and often LTP development early in decommissioning; Discussion of outside MARSSIM issues during development and implementation.

Include region in routine communication with headquarters Support to independent regional/ORISE oversight during more critical FSS survey performance.

V. Licensee-NRC Communications

FSS process reviews to support later HQ FSS report reviews, and Augment an inspection with HQ reviewer.

ORISE (Oak Ridge Institute for Science and Education):

Time an early FSS survey implementation visit to allow for improvement suggestions, and Better align licensee survey methods with ORISE to prevent later surprises during ORISE confirmatory survey visits.

V.

Licensee-NRC Communications (continued)

Employ Regional Inspections in process.

Credit ORISE confirmatory measurements and split sampling.

Perform confirmatory detailed review of first FSS report.

FSS reports should comprise results of process outputs vs.

a compendium of inputs. Any deviations from process should be highlighted in 1st report.

VI.Enhance Role of Independent Oversight

Identify industry vs. NRC actions.

Agree on deliverables and timeframes.

VII.

Next Steps

Questions

ML20304A122

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