ML20345A303
| ML20345A303 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/17/2020 |
| From: | John Hickman Reactor Decommissioning Branch |
| To: | Sauger J ZionSolutions |
| Hickman J | |
| References | |
| Download: ML20345A303 (9) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 17, 2020 Mr. John Sauger General Manager Zion Restoration Project ZionSolutions LLC 101 Shiloh Blvd.
Zion, IL 60099-2797
SUBJECT:
ZION NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO FINAL STATUS SURVEY REPORTS
Dear Mr. Sauger:
By letters dated September 30, 2019, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML19295G627), November 25, 2019 (ML19338B863),
December 30, 2019 (ML20009E643), April 30, 2020 (ML20147A092), and May 1, 2020 (ML20133J975), ZionSolutions, LLC submitted Final Status Survey Reports (FSSRs) Phase 2a, 2b, 3, and 4, for Zion Nuclear Power Station, Units 1 and 2 to the U.S. Nuclear Regulatory Commission (NRC). By letter dated November 4, 2020 (ML20303A207), the NRC staff provided Requests for Additional Information (RAIs) regarding those FSSRs. On November 11, 2020 (MLpending), you responded to those RAIs.
The NRC staff has reviewed your RAI response and based on review performed to date, concluded that it is insufficient to enable the NRC staff to complete its review. The licensee did not adequately address the staffs questions, and in some instances needs corrections.
The enclosure provides examples of the areas that need to be enhanced or modified. These examples are not all inclusive and we expect that ZionSolutions will review all of their responses for sufficiency. The NRC staff acknowledges that the RAI package requested substantial information on numerous survey release records and related technical items that may require considerable time to answer. This was discussed in telephone conversations with your staff on December 9, 2020, and December 14, 2020, and they committed to work with our staff prior to submitting the revised responses in an effort to submit high quality RAIs. Absent the additional information requested, the NRC cannot make a determination that the site meets the unrestricted release criteria.
You agreed to provide a response addressing our issues by January 11, 2021. Based on that response date, and assuming a sufficient response, we anticipate a 4 to 6 week delay in the completion of our review of your FSSRs and the approval of your partial site release request.
In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
J Sauger 2
Should you have any questions regarding this action please contact me at 301-415-3017 or John.Hickman@nrc.gov.
Sincerely, John B. Hickman, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos. 50-295 and 50-304 License Nos. DPR-39 and DPR-49
Enclosure:
Acceptance Review of ZionSolutions RAI Response ZS-2020-0058 cc: w/enclosure Zion Service List
J Sauger 3
SUBJECT:
ZION NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO FINAL STATUS SURVEY REPORTS DATE:
DISTRIBUTION:
RDB r/f JHickman BWatson THuffert LParks KPinkston MDoell REdwards, RIII WLin, RIII CWolf, OCA JWeil, OCA OPA Document Accession No ML20345A303 *Via email OFFICE NMSS NMSS NMSS NAME JHickman BWatson*
JHickman DATE 12/10/2020 10/16/2020 10/17/2020 OFFICIAL RECORD COP
Acceptance Review of ZionSolutions RAI Response ZS-2020-0058 Example RAIs not adequately addressed (to date):
RAI-1 (Final Status Survey Reports and Release Record Revisions)
HQ staff identified numerous release records that provided information that is inconsistent with the final radiological conditions of the site (i.e., additional remediation, investigations that found contamination, or potential for recontamination). Please provide a basis to justify that additional surveys following FSS, or surveys performed following hot particle removal on FSS areas, are acceptable to reflect the final state and/or ensured the integrity of the original FSS of those areas.
A clearer, more detailed timeline is needed of when contamination and particles were remediated in relation to completion of FSS records (see RAI 11).
Example of potentially inaccurate information:
Licensee statement: All Release Records provided to the NRC to demonstrate compliance with the unrestricted release criteria reflect the final conditions of the site. Any remediation or potential recontamination of the survey units (including with concrete debris from the demolition of structures on site) occurred prior to the execution of FSS documented in the applicable Release Records.
HQ reviewers note:
Information provided to RIII shows concrete debris placed on SU 12203 and 12113 after the time of FSS.
Licensee response to RAI-10 states particles were identified and remediated in survey units after the time of final FSS (e.g., a discrete particle was found in SU12204A during confirmatory survey after FSS).
Licensee response to RAI-10 describes investigations that were performed as a result of elevated areas identified by ORISE after the FSS was completed.
RAI-3 (100% Coverage of Accessible Area vs Actual Surface Area)
Clarification is needed on survey coverage for SUs 10220H and 10220I. RAI response states it was 100%
actual coverage. This disagrees with the release records, which state some areas were not accessible.
For example, the release record for SU 10220I states, A discrete area in the wetland was not accessible for surface soil scanning due to the presence of standing water. This area is documented on the field logs.
RAI-4 (Post-Remediation Scans and Survey Data Not Provided for Power Block Land Survey Units)
Results of surveys conducted after July 2019 is needed (before clean backfill emplaced).
Licensee providing Readiness Review Surveys from April and May 2019 is not entirely sufficient, given that ORISE found additional particles during the July 2019 confirmatory.
To assess the potential of remaining discrete particles, describe what controls were in place to avoid recontamination, including controls before and after July 2019 confirmatory survey.
During the Readiness Review for 12202D and 12202F in April and May 2019, licensee recovered particles in SU 12202D, and volumetric contamination in SU 12202F. Later in July 2019, ORISE discovered particles in these SUs. So, Readiness Review did not result in recovery of all particles, new particles were introduced into SUs before confirmatory survey due to a breakdown in controls, or
the licensee survey method was unable to detect some discrete particles in these SUs using their scan method.
RAI-7 (Subsurface Soil Excavations: RASS Versus FSS)
Dose calculation does not account for dose contribution of sub-grade excavation FSS SUs.
Licensee could account for dose by either listing SUs 12106K, 12105K, and 12107K as separate Land Survey Units in the table in the Partial Site Release Request from which the maximum Land Survey Unit dose is decided, or by providing an alternative way to incorporate dose from these SUs. A detailed calculation of the dose that is assumed for the survey units should be included in the response.
RAI-8 (Subsurface Remediation in Land Survey Units Where Piping Was Removed)
Licensee should provide the post-remediation surveys where buried piping was removed.
The response states that, ZSRP was required to solicit permission from the NRC prior to backfilling any excavation. Permission was typically solicited through e-mail correspondence from ZSRP to the NRC with an attached letter detailing the location of the excavation, the purpose, the results of scanning, and soil sample analysis from the RA. Until regulatory permission was received, excavations were not backfilled and remained open. Staff note that the example of the correspondence provided in the response is an internal memo from the Zion Rad Engineer to the Zion Licensing Manager as opposed to an example of NRC correspondence permitting backfill. Regardless, any permission to backfill from NRC during decommissioning is at-risk and is not commensurate with release of the survey unit. The licensee still needs to provide a technical basis in the release record that the survey unit meets the release criteria, including excavated or remediated areas that have been backfilled. Staff are requesting the post-remediation surveys where buried piping was removed to be submitted formally to demonstrate that the site meets the release criteria.
LTP Section 5.7.1.7, Reuse of Excavated Soils, states that a soil sample will be collected at any scan location with residual radioactivity in excess of 50% of the soil OpDCGL, and that any soil confirmed with concentrations exceeding 50% of the soil OpDCGL will be disposed as waste. Page 45 of Attachment 2 states that the subsurface soil OpDCGLs were used as action levels for scans and sampling. Page 47 of states the alarm set point was 90% of the subsurface OpDCGL for scans. Page 48 of states that no sample locations exceeded 0.50 of the MDC were identified. Please clarify these statements in terms of the LTP commitment to not reuse soil that is above 50% of the soil OpDCGL from excavations and describe how the scans were used to identify soils above 50% of the soil OpDCGL for sampling and possible disposition as low-level waste.
RAI-9 (Recontamination of Survey Units with Concrete Debris after FSS Completed)
Provide list of all SUs in which concrete debris was stored or transported after the FSS.
Provide revised release records or addenda that reflect the final status of SUs (after the removal of the concrete debris or transport through the SU), for any SU in which concrete debris was stored or transported after FSS completion. Specifically, address SUs 12113 and 12203, as well as any other SUs.
Explain how actions taken by the licensee to reperform or not reperform FSS comply with Section 5.12 of the LTP.
RAI-10 (Corrective Actions that were Done in Response to ORISE Confirmatory Surveys)
Provide revised release records or addenda that reflect the final status of SUs (see RAI-1 also).
Similar to RAI-4, describe why the discrete particle in SU12204A, which was found during the confirmatory survey, was missed during the FSS (completed in February 2019), or if the particle entered this SU after the FSS was completed (before confirmatory survey in December 2019/January 2020).
Given that contaminated concrete debris was found in SU 10209C during the confirmatory survey, which required further investigation and removal, please describe how the actions taken by the licensee comply with Section 5.12 of the LTP. The RAI response states that no additional action was deemed necessary as scanning of the shallow hole left from the ORISE judgmental sample did not indicate the presence of radioactive material exceeding background. However, the soil comprising ORISE judgmental sample 5217S0075 resulted in an SOF of 2.03 when compared to the OpDCGLs. Therefore, please provide the scan results from the investigation and describe how the licensee concluded that no additional judgmental samples were necessary.
Please provide relevant revision of the procedure ZS-LT-300-001-003, Isolation and Control for Final Status Survey for the NRC staff to validate the statements made in the FSS records.
RAI 10c states, However, due to the highly transportable nature of particles, they can be introduced onto a surface following the completion of a scan survey where no elevated scan measurements were previously identified. Given this information, provide additional assurance that areas that had been scanned were not recontaminated with discrete particles.
RAI-11 (Scanning Adequacy for Finding Discrete Particles of Residual Radioactivity)
Provide a timeline that summarizes the release, discovery, and remediation of discrete particles across the site, including corrective actions taken to try to reduce the spread of discrete particles, and decisions to reclassify certain survey units or certain areas of the site.
Provide in table format a list of SUs that received the special type of survey for detecting discrete particles, the survey dates, and whether they were conducted before or after FSS. Also provide supporting information (e.g., field notes, survey results). See attached table as an example.
Please provide the relevant revision of the procedure that describes the surveys for discrete particles (i.e.,
0.25 m/s, serpentine fashion, 1000 cpm background), for the NRC staff to validate the statements made in the FSS records and the RAI response.
It is not evident from release records whether the survey procedure for discrete particles (i.e., 0.25 m/s, serpentine fashion, 1000 cpm background) was applied in SUs where particles were suspected.
Therefore, provide survey data for SUs for Phase 1-4 that had specialized scan surveys conducted to locate discrete particles. Include a discussion of the assumed background level for the scan MDC calculation as compared to the actual measured background. Also include a discussion of the technical basis for the assumed background value used in the scan MDC calculation. Provide a discussion of whether the technicians were using headphones/earphones when scanning with several technicians walking side-by-side.
Provide a rationale for why certain SUs did not use the specialized scan procedure for discrete particles, if discrete particles are highly transportable and were found throughout the site, as stated in the RAI-11 response (see below).
Address corrective actions to prevent the spread of the discrete particles or actions taken to identify discrete particles that had recontaminated a survey unit after FSS was completed.
Provide the information requested in the path forward of RAI-11c. Specifically, provide information on the reason that the scan might have missed the Co-60 speck/particle found in sample L1-12112A-FQGS-014-
SS. Describe whether the scan method used would be expected to locate a speck/particle of this size.
Provide any additional information on the source of the Co-60 speck/particle. The release record provides the result of the analysis of the sample using the on-site gamma spec lab as 0.117 pCi/g for Co-60 whereas the Eberline results was 1.01 pCi/g. Please explain the discrepancy in results.
The RAI Response 11b discusses three incidents that caused the particle contamination: (1) 2012 wind entrainment of particles exiting Containment through barn doors; (2) 2014 liner incident; and (3) 2015 steam generator segment incident. Please indicate the impacted survey units from each of these incidents.
Please indicate whether concrete debris was determined to be a source of discrete particle contamination and the rationale for that determination.
Provide Condition Reports related to the first incident in 2012 with the Containment barn doors.
Provide Condition Report (CR-2014-001074) and the Apparent Cause Evaluation (ACE) related to the 2014 liner event, as well as any other condition reports related to the 2014 liner event.
Provide ZionSolutions procedure EN-ZN-407, Response to Inadvertent Release of Licensed Material to Groundwater Surface Water or Soil, which was implemented for the release of radioactive material to the soil in the South Yard near the vault array in 2014. The RAI response states that there were multiple slivers/chips and, subsequently, particles in the range of 50,000 dpm to 7 million dpm identified on the ground in the travel path of the liner between the rad vault and the shipping cask. Please include any additional information the licensee has on the physical size (AMAD), chemical composition, and radioactivity of the particles recovered in 2014. Also, please provide information about the survey instruments, and their scan MDCs, used during this recovery effort.
Provide Condition Report (2015-000324) related to the 2015 incident with the steam generator segments, and any other condition reports related to the 2015 steam generator segment events.
The RAI response indicates that, after the 2015 incident with the steam generator segments, from June 3-9, 2015 the licensee recovered 75 discrete particles across the site. Please provide information about the particle distribution size (AMAD), chemical composition, and radioactivity, of recovered particles. Also, please provide information about the survey instruments and their scan MDC, as used during particle recovery surveys.
The RAI response states, In the time following the described incidents, particles were found throughout the site. Condition Reports pertaining to the discovery of discrete radioactive particles were routinely issued from 2015 through the end of major project work in 2020. ZionSolutions took several steps to ensure that discrete radioactive particles were identified, captured, and removed to the extent practicable.
As a response to the frequent identification of particles, a decision was made in July of 2016 to reclassify all Class 2 and Class 3 survey units located within the security-controlled area as Class 1 FSS units. In addition, a large percentage of the accessible soil surfaces in most of the Class 1 open land survey units were scanned multiple times prior to performing FSS.
Please provide a list of all survey units that are in the security-controlled area. Please state which survey units were reclassified to Class 1 as a result of particle discovery. Please state whether any survey units in the security-controlled area were not reclassified Class 1 and the basis for not reclassifying them.
Please provide a rationale for using the security-controlled area as a boundary for reclassification purposes. Also, please provide a rationale for where the licensee decided to survey for particles (including whether a decision was made to survey for discrete particles outside of the security-controlled area).
Please provide the following information on the discovery of discrete particles throughout the site: (1) a list
of SUs that were found to include discrete particles from June 2015 through the end of major project work in 2020; (2) whether discrete particles were found outside the security-controlled area; and (3) a description of controls that were implemented to prevent particles from moving beyond the security-controlled area.
The RAI response states that Condition Reports pertaining to the discovery of discrete radioactive particles were routinely issued from 2015 through the end of major project work in 2020. Please provide these condition reports and any associated corrective actions. The staff are requesting this information to inform conclusions in the SER.
Discuss the physical size (AMAD), chemical composition, and range in radioactivity of particles identified in the soil, including the location, and predicted source (including any particles that may have been discovered in Phase 1 Survey Units 10205, 10219A, 10219B, 10220C, 10222, 10223, 10224, 10301).
Discuss the physical size, chemical composition, and range in radioactivity of particles identified in the occupational exposures, including the location, and predicted source (including any particles that may have been discovered in Phase 1 Survey Units 10205, 10219A, 10219B, 10220C, 10222, 10223, 10224, 10301).
Provide an estimate of the dose from a hypothetical intake (both inhalation and ingestion) of a typical discrete particle for the site, taking into account the range of sizes, chemical compositions, and radioactivity of the discrete particles discovered in soils at the site.
RAI-12 (Commitment for Continuing Characterization in LTP Section 5.3.4.4 (RAI 3a Response)
State whether the fill that had been temporarily placed in the excavation of the keyways was disposed of as waste when it was removed.
RAI-13 (Quality Control Investigations of FSS Data)
Provide relevant revision of procedure ZS-LT-300-001-004, Final Status Survey Data Assessment for the NRC staff to validate the statements made in the FSS records.
For the survey unity 01100, the statement that resolution was poor (<4) for both Cs-137 and K-40 appears to be incorrect. It appears that both IP 84750 and the +/- 20% criteria are being used as comparisons for the ISOCS measurements even though the response states that the IP84750 was the criterion for all ISOCS replicate measurements. For example, for sample, B1-01100AF-SFM-146-GD/B1-01100AF-QFM-146-GD, the response states the ISOCS shots are within 20%. The licensee should clarify if the comparison to the +/-20% is done only for the RAI response as an additional comparison.
For another sample in this survey unit (standard measurement B1-01100AF-SFM-150-GD), the statement that resolution was poor (<4) for both Cs-137 and K-40 appears to be incorrect. Also, the statement that The standard concentration for Cs-137 is 42% of the replicate appears to be incorrect. Attachment 4 of the release record (Rev 1) states the Cs-137 concentrations were 3.46E4 for the standard and 2.00E4 for the comparison.
Please review the response for clarity and accuracy.
RAI-14 (QC Failures Inadequately Explained by Low Concentrations of Co-60 in Soil Samples):
Provide procedure ZS-RP-106-002-005 Identification Control of Discrete Radioactive Particles for the NRC staff to validate statements made in the FSS records and RAI response.
Recommended Table for Licensee Completion Survey Unit Number: SU_12113 SU_XXXX Was a discrete particle found (either during decommissioning prior to FSS or after FSS)?
Was clean soil placed on survey unit before FSS?
Was this survey unit reclassified (if reclassified more than once, provide details)?
Date the survey unit was reclassified (if reclassified more than once, provide details)
Date of FSS Date of Confirmatory (if performed)
Was concrete debris stored on or transported through the SU after FSS?
Was contamination or particle identified during the Confirmatory Survey?
Was additional contamination or particle identified after FSS?
Was it remediated?
Was FSS redone?
Date of second/final FSS?
Was the special survey technique used (1000 cpm background),
serpentine fashion, scan speed 0.25 m/s, etc.)?
Was the field data provided for the special survey technique that was performed to detect particles?
Did any removal of contaminated soil or potential recontamination of the survey unit (including with concrete debris from the demolition of structures on site or windblown discrete particles) occur after the execution of FSS documented in the applicable Release Records?
Did the routine surveillance of any of the survey units after FSS result in investigations?