ML21225A714
| ML21225A714 | |
| Person / Time | |
|---|---|
| Issue date: | 03/11/2021 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NRC-1420 | |
| Download: ML21225A714 (70) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
33rd Regulatory Information Conference Technical Session - TH27 Docket Number: (n/a)
Location: teleconference Date: Thursday, March 11, 2021 Work Order No.: NRC-1420 Pages 1-65 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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33RD REGULATORY INFORMATION CONFERENCE (RIC)
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TECHNICAL SESSION - TH27 REACTOR DECOMMISSIONING: WORKING HARD TO STAY AHEAD OF THE ISSUES!
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THURSDAY, MARCH 11, 2021
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The RIC session convened via Videoconference at 1:30 P.m. EST, Bruce Watson, Chief, Reactor Decommissioning Branch, Division of Decommissioning, Uranium Recovery, and Waste Programs, presiding.
PRESENT:
BRUCE WATSON, Chief, Reactor Decommissioning Branch, Division of Decommissioning, Uranium Recovery, and Waste Programs, NMSS/NRC CYNTHIA BARR, Senior Systems Performance Analyst, Risk and Technical Analysis Branch, Division of Decommissioning, Uranium Recovery, and Waste Programs, NMSS/NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 ZAHIRA CRUZ, Project Manager, Reactor Decommissioning Branch, Division of Decommissioning, Uranium Recovery, and Waste Programs, NMSS/NRC ANTHONY DIMITRIADIS, Chief, Decommissioning, ISFSI and Reactor HP Branch, Division of Nuclear Materials Safety, RI/NRC MARLAYNA DOELL, Project Manager, Reactor Decommissioning Branch, Division of Decommissioning, Uranium Recovery, and Waste Programs, NMSS/NRC BRUCE MONTGOMERY, Director, Decommissioning and Used Fuel, Nuclear Energy Institute TED SMITH, Project Manager, Reactor Decommissioning Branch, Division of Decommissioning, Uranium Recovery, and Waste Programs, NMSS/NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 PROCEEDINGS 1:30 p.m.
MR. WATSON: Good afternoon. Welcome to our session on reactor decommissioning. I'm Bruce Watson, I'm chief of the Reactor Decommissioning Branch. We have a full agenda, given the time we have been allocated, so let's move to the next slide, please.
Since transitioning from operations to decommissioning has been a RIC topic in the past, I thought I would like to remind everyone that the decommissioning proposed rulemaking has been with the Commission since 2018.
At last count, there were two votes in.
The staff is hopeful of getting the remaining votes in the near future so the rulemaking can move forward.
In May, the Indian Point Unit 3 plant will cease operations. The Reactor Decommissioning Program will then have 26 power reactors in decommissioning. And as everyone knows, there are seven other announced shutdowns in the next few years. The big thing to us is that we could have as many as 17 plants in active decommissioning.
For this session, I thought it would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 appropriate to look at some of the initiatives the staff has accomplished during the past year and the works in progress to keep the program moving forward.
In a few days, we will mark one year where the NRC has either been on mandatory or maximum teleworking. The staff made excellent progress in completing special projects and processing licensing requests for licensee actions, including a number of COVID-related exemptions.
I'm going to forego the lengthy bios of the speakers, since they're on the RIC website.
So, our first speaker today is Ted Smith.
He's a very experienced decommissioning project manager. He led the Reactor Decommissioning Financial Assurance Working Group, known as the RDFAWG, is what we called it, and published the report last spring.
Marlayna Doell, another accomplished RDB reactor decommissioning PM, was one of the key contributors to the NEIMA Section 108 report to Congress on Community Advisory Boards.
Zahira Cruz, another one of our reactor decommissioning project managers, led the working group of senior inspectors to risk-inform the Reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 Decommissioning Inspection Program. I consider this a major program accomplishment.
The next speaker is Region I's Tony Dimitriadis. He's the chief of the Decommissioning ISFSI and Reactor Health Physics Branch. Tony will focus on the need for licensees to conduct thorough surveillance programs for plants, not only in SAFSTOR, but also decommissioning. And so, he will talk to that.
With that in mind, though, he will be discussing the GE Vallecitos boiling water reactor that was partially dismantled and has been in cold and dark storage for 50 years. Like other licensees, GE has taken corrective actions on many of the structural issues. GE is evaluating potential structural issues with groundwater intrusion as we speak.
Our last NRC speaker is Cynthia Barr.
She is a senior systems performance analyst in our Risk and Technical Assessment Branch, who will provide an update on the regulatory tools, meaning the guidance and computer codes we use in our everyday work.
Lastly, I invited an old Calvert Cliffs NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 colleague, Bruce Montgomery. Bruce leads NEI's Decommissioning Working Group, so we communicate regularly on issues important to the NRC and the industry.
And with that, I'd like to remind you to save your questions for the panel session at the end.
And with that, I'd like to go to Ted Smith.
MR. SMITH: Good afternoon. In the interest of time, I'll be briefly discussing the Reactor Decommissioning Financial Assurance Working Group. Next slide, please. Thank you.
On September 20, 2019, the NRC formed the Reactor Decommissioning Financial Assurance Working Group as an interoffice effort, which included NRC Headquarters staff from NMSS, both REFS and DUWP, NRR, and OGC, as listed on the slide.
In addition to the independent analysis of licensees' annual decommissioning trust fund reports each year, the ability to correlate the fund expenditures with actual completed decommissioning work at the sites is integral to NRC's role of ensuring that there's reasonable assurance of adequate funds to complete decommissioning.
Therefore, all three regions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 implementing the Reactor Decommissioning Inspection Program in Inspection Manual Chapter 2561 were also represented in the working group. Next slide, please.
The Reactor Decommissioning Financial Assurance Working Group charter directed the working group to the items listed below. The most important of these was to identify potential regulatory gaps and associated policy issues in the ability of the decommissioning process to continue to provide reasonable assurance of adequate resources. Next slide, please.
The NRC's regulations require that radioactivity at a site be reduced to specified levels within 60 years of permanent plant shutdown, but do not specify the method to do this.
Historically, decommissioning has been accomplished by the licensee that had operated the plant, either on its own or by contracting with third parties.
Recently, some of the licensees that had operated the plants are instead transferring their ownership of the plants, either temporarily or permanently, to third parties to complete NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 decommissioning. These transfers require an evaluation of whether the third party is financially qualified to decommission the plant.
This new decommissioning business model typically involves accelerated decommissioning schedules and accelerated decommissioning trust fund withdrawals, which result in less time for the decommissioning trust fund to grow during decommissioning.
It typically involves ownership by limited liability companies dedicated to decommissioning. However, this corporate structure is not unusual for power plant licensees. Currently, approximately 55 percent of power plant licensees, operator or owner, are LLCs.
Although the financial assurance methods available to LLCs may be significantly different than those available to traditional rate-regulated electric utilities, they still must satisfy the NRC financial assurance regulations. Next slide, please.
Based on our review of the reactor decommissioning financial assurance regulations and of the NRC's experience implementing these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 regulations, and after two public meetings, we determined that there were no regulatory gaps or policy issues.
Specifically, with respect to expedited decommissioning, the regulations still ensure sufficient funding through annual recalculations of the decommissioning cost estimates and reporting to the NRC.
With respect to LLCs as licensees, the regulations already include changes made in 1998 and 2002 to address financial assurance in light of the potential deregulation of nuclear power plants.
We did identify several improvements that we recommended be made to three key guidance documents. They are the Financial Assessment Branch procedures, called LIC-205, certain decommissioning inspection procedures, and Regulatory Guide 1.159, titled Assuring the Availability of Funds for Decommissioning Nuclear Reactors.
The proposed improvements include incorporation of lessons learned and integration between inspection and financial assessment activities.
Two of the recommendations were based on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 public comments received during webinars.
Participants in the webinars included members of the public, state representatives, industry, and local community groups, such as Pilgrim Watch.
We also recognized a need to train the relevant NRC staff members on these changes and how to best integrate the staff reviews of decommissioning financial assurance issues.
We anticipate being able to achieve these guidance improvements and program changes without the need for additional staffing resources. In the future, should the anticipated workload necessary increase, any additional resources needed will be addressed during our budgeting process. Next slide, please.
The recommendations include, one, clarify oversight of decommissioning trust fund expenditures. Guidance should make clear that the requirement to report the annual amount on decommissioning means that the amount should be broken down by decommissioning activity.
Thus, the decommissioning funding status reports should itemize expenses similar to how such expenses are presented in licensees' site-specific NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 decommissioning cost estimates.
The desired outcome is for licensees to present this information in a manner that allows the NRC licensing and oversight staff to make informed decisions on the usage of decommissioning trust funds. NRC guidance should be revised to clearly specify the level of detail expected in these reports.
Two, periodic cost baselining. Develop guidance for future periodic cost baselining to validate or make adjustments to the cost estimating process, based on a comparison of site-specific cost estimates to actual costs ultimately incurred. This recommendation was provided by members of the public during one of the webinars.
Three, develop 30-day notification guidance. Develop guidance for the level of detail to be provided in the required 30-day notices. Also, develop internal processes so that 30-day notices promptly reach the attention of the appropriate NRC reviewers.
Four, revise inspection procedures.
Revise current financial assurance sections of inspection procedures to clarify the expectations for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 oversight of decommissioning financial assurance.
Specifically, to record in periodic inspection reports all major ongoing and completed decommissioning activities, to make inquiries as to the overall financial status of decommissioning, and to review the licensee's financial allocation control process.
Five, provide direction to refer financial review questions to the Financial Assessment Branch for evaluation and for consideration under a new decommissioning reactor financial assurance spot-check program.
Six, develop decommissioning reactor financial assurance spot-check program. Modify the Office Procedure LIC-205 and the Inspection Procedure 71801 to establish those procedures and a process for a spot-check program of the decommissioning trust fund for licensees with power reactors that are in decommissioning. This program will be similar to the existing spot-check program for operating power reactors.
Seven, develop guidance for post-shutdown decommissioning activity report update triggers. Provide guidance in Regulatory Guide 1.159 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 of what constitutes a significant increase in decommissioning costs, as described in 10 CFR 50.82(a)(7). This suggestion was also provided by members of the public during a webinar.
Eight, develop guidance on comparison between the decommissioning trust fund formula and the site-specific cost system. Provide guidance to clarify that the 10 CFR 50.75(b)(1) requirement for a site-specific cost estimate should be more, but not less, than the 10 CFR 50.75(c)(1) formula cost estimate is only applicable at the time of plant shutdown, prior to active decommissioning work.
Nine, refer irradiated fuel funding guidance related to the use of provisional trust funds to NRC's Division of Fuel Management for their consideration.
And finally, as I mentioned before, a training program for NRC staff involved in reactor decommissioning financial assurance. Our proposal is to incorporate training activities as part of the existing annual decommissioning counterparts meeting by inclusion of REFS financial analysts. Next slide, please.
The three documents that were recommended NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 for improvements and their ADAMS accession numbers are listed here, along with a list of completed and planned training activities.
So, again, just to wrap up, the Regulatory Guide 1.159, which is currently the version from 2011, Assuring the Availability of Funds for Decommissioning Nuclear Reactors, LIC-205, which was last revised in 2017, Procedures for NRC's Independent Analysis of Decommissioning Funding Assurance for Operating Nuclear Power Reactors and Power Reactors in Decommissioning, and finally, the Inspection Procedure Decommissioning Performance and Status Reviews at Permanently Shut Down Reactors.
And with that, I'll turn it back to Bruce.
MR. WATSON: Thanks, Ted. Our next speaker is Marlayna Doell. Marlayna is an experienced decommissioning project manager, as I mentioned, and she was a key member of the team that did the Community Advisory Board report to the Congress. So, Marlayna, you're up.
MS. DOELL: All right. Thank you, Bruce. Good afternoon. As was already mentioned, my name is Marlayna Doell and I was part of the NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 team responsible for addressing the requirements in Section 108 of the Nuclear Energy Innovation and Modernization Act, or NEIMA 108 for short.
Today, I want to just give a quick recap of the activities the agency undertook in response to the NEIMA 108 directives, which culminated in a report to Congress that was sent out this previous summer. Next slide, please.
So, the NEIMA 108 team was tasked with submitting to Congress the report on best practices for Community Advisory Boards, more commonly called CABs, associated with decommissioning activities at nuclear power plants.
To prepare the report, the NRC staff conducted 11 public meetings from August through October of 2019 to obtain insights from host states, communities near nuclear power plants, and existing Community Advisory Boards.
We also conducted two webinars to provide people that couldn't participate in the meetings in-person with an opportunity to participate in the process.
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16 covered by NEIMA 108 in order to provide an additional avenue to receive feedback.
The NRC staff used the public comments from these meetings, responses to the questionnaire, and direct outreach to state and local officials, as well as existing CABs, to compile a report.
Through these efforts, we received over 1,200 oral and written comments from more than 200 commenters. So, thank you to all of you who may be joining us today that also participated in one or more of these efforts. It was a very busy year and a half for all of us and we look forward to being able to do in-person meetings someday soon again.
As a result of these interactions, our team identified a number of good practices for CABs, but also noted that there are other effective means to communicate with the public regarding decommissioning activities at nuclear power plants.
The report to Congress was signed by the Chairman on July 1 and the accession number is listed here on the slide for anyone that may be interested in reading that. Next slide, please.
So, here are the best practices that were included in the report to Congress. They include, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 in no particular order, that any group or organization that's interested in forming a CAB should think about pursuing that formation early in the decommissioning process to get the most bang for their buck from the CAB meetings.
And that as part of that early formation, they should also consider putting together a charter or a guiding document of some sort that will set up the routine interactions of the CAB.
We also had identified that diversity in CAB membership is very important, so that the folks that are participating in it have a diverse set of technical and logistical interests and backgrounds.
We also talked a lot in the report about the fact that the CAB meeting frequency can be really dependent upon the site status and the site location, as well as the level of interest in the decommissioning process.
As most of you know, this varies widely across the country and site by site, depending on the ongoing activities. So, many of these meetings can be tailored to that consideration.
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18 members can be important, especially early in the process as everyone is sort of getting up to speed on what nuclear decommissioning entails and how they can outreach to either other groups or to the NRC itself to be able to receive some of this training. Next slide, please.
So, during the course of preparing the NEIMA 108 report, our team also identified several other common themes in the comments that we were receiving on the best practices for the CABs. While these were not ultimately included in the report to Congress, some of the common issues we heard are listed here on the slide.
And a couple of the themes I want to highlight are down, actually, closer to the bottom, which is that CAB meetings should be held to help the community better understand the overall decommissioning process.
This was something we heard quite often, just to help members in communities that are starting to enter decommissioning, just for them to understand what it's all about, not just the site-specific implications, but just how the process works, how the NRC gets involved, what the other opportunities are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 for public involvement, and walking through some of those important aspect early in the process.
And the second one is that CABs should consider staying in existence even through the end of the formal decommissioning process, when the Part 50 reactor license itself is terminated and all that remains on the site are the dry cask storage facilities or ISFSIs.
There are several CABs still in existence at some of the plants that decommissioned many years ago that are still operating, they only have meetings on a less frequent basis, but in order to stay involved with the ISFSIs and the eventual process for removing fuel from the site in the future. Next slide, please.
A few more of the topics that we heard often, but did not get included ultimately in the report were that the CAB meetings should, obviously, be open to members of the public.
But then, on some specific topics, it was useful for CAB members only to be able to have meetings just amongst themselves, to be able to talk through some of the technical and logistical issues before taking those specific topics out to members of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 the public.
We heard several, several times that there should be a formal funding mechanism for CABs.
There's a lot of different ways that sites and different boards across the country are pursuing their funding mechanisms, so there's some good practices out there and a lot of diversity in how that particular item is address across different CABs.
That kind of goes to the third topic here, which is that CABs should share information with each other. We've seen great examples of that, I think, across the industry and across the decommissioning fleet in general, that not only the licensees exchange information, but the different Community Advisory Boards also share information with each other, and it's led to, I think, a great deal of understanding and a lot of good insights shared across the board at these different facilities.
The last one is a very site-specific one, but certain decommissioning facilities do actually have more than one Community Advisory Board in place.
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21 at certain sites, especially if those CABs have different directives and different things that they are pursuing in mind. Next slide, please.
So, as a result of all these activities, we were able to make some conclusions about the use of the Community Advisory Boards. Again, not all of them made it into the final report.
But the big overarching one that we stressed in the report and would like to stress again here is that there are multiple ways to correctly engage the public during the decommissioning process, there's no one-size-fits-all for Community Advisory Boards, for the decommissioning process, for these sites, as everybody has specific items and concerns that they're addressing.
So, we as the NRC are very committed to trying to make the process as open and transparent as we can and we do currently offer, through the NRC regulations, several opportunities for the public to engage during the decommissioning process, including at public meetings on both the post-shutdown decommissioning activities report and the license termination plan, as well as additional interactions at certain plants on additional topics.
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22 Again, the report to Congress was signed on July 1. The ADAMS accession number is listed here if you're interested in taking a look. And I think that closes me out for today. I'm going to say thank you, again, for joining us, and turn it back over to Bruce.
MR. WATSON: Well, thank you, Marlayna.
Our next speaker is Zahira Cruz. Zahira led the working group and she had the opportunity to work with many of the senior inspectors from the regions that do the decommissioning inspections, as well as a number of subject matter experts, in revising the IMC 2561 and the nine core, or what became nine core inspection procedures.
So, with that, I'll turn it over to Zahira. Welcome, Zahira.
MS. CRUZ: Thank you, Bruce. And thank you, everyone, for attending this session. As Bruce mentioned, I'm Zahira Cruz, I'm a decommissioning project manager and I had the pleasure to lead the Inspection Manual Chapter 2561, or IMC 2561, Working Group, with members from the NRC Headquarters, Region I, III, and IV.
This group was formed just prior to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 mandatory telework and travel restrictions due to COVID-19, and we pretty much took advantage of having the inspectors working remotely and engaged them in updating all of the IMC 2561 core inspection procedures.
Previous versions of this inspection manual was dated back to March 2018, and since then, I know you are aware that the agency has undertaken lots of initiatives for becoming a modern risk-informed regulator.
An essential aspect of our mission is oversight and we took the opportunity to ensure that our inspection procedures are risk-informed and that the expectations for each inspection procedure are more clear.
This project was a team effort, with inspectors, staff, subject matter experts, and branch chiefs participating to meet the schedule and accomplish the project by the end of calendar year 2020. Next slide, please.
The purpose of IMC 2561, which is titled Decommissioning Power Reactor Inspection Program, is to provide guidance for inspection of decommissioning nuclear power reactors.
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24 This program is to be implemented on or shortly after the certification date for permanent removal of the fuel from the reactor vessel, in accordance with the regulations, and is to continue until the license termination.
The NRC inspection program consists of two types of activities, which are performed by inspectors from our regional offices.
The inspection procedures that are designated as core are performed annually as applicable at varying levels of depth and effort depending on the site activities. The ones that are listed as periodic or discretionary are performed as needed based on activities and/or issues at the site.
Anyone can access the new version of the IMC and the inspection procedures through the NRC public website, under NRC Library Document Collections. Next slide, please.
So, here is a list of the core inspection procedures that were revised. Previous version for some of these IPs dated back to the 1990s.
Some highlights include that we deleted IP 36801 and incorporated this information in IP 71801. We also deleted IP 62801 and incorporated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 this information in IP 60801.
We did a full rewrite of IP 64704, which is the fire protection program at decommissioning sites, which was previously a discretionary IP and we made it a core IP based on recent experience related to fire hazards at decommissioning sites.
Fire protection requirements previously discussed in IP 71801 were included in this new IP, in addition to including the 10 CFR 50.48(f) regulations and guidance from the recently revised Regulatory Guide 1.191, titled Fire Protection Program for Nuclear Power Plants During Decommissioning.
We revised IP 71801, in part to clarify expectations for the oversight of reactor decommissioning financial assurance program, as recommended by the Reactor Decommissioning Financial Assurance Working Group previously discussed by Ted.
We also, the radiation protection procedures, which are 83750, 84750, and 86750, were updated using the new operating reactor health physics procedures under the IP Series 71124. Next slide, please.
In addition to the specific updates I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 just discussed, other changes to the IPs include that we added language regarding focusing inspection activities commiserate to the licensee activities, based on an evaluation of the risk of these activities by answering three questions. What can go wrong?
How likely it is? And what its consequences might be?
References were updated and redundancy was deleted. For an example, we combined part of the maintenance procedure with the spent fuel pool procedure to reduce redundancy and eliminate duplication.
We incorporated recent lessons learned.
For example, the definition of the types of surveys and when it is to be conducted was expanded in IP 83801. Specifically, the definition of a verification survey was expanded to provide an opportunity for NRC inspectors to conduct a survey and collect samples as needed when appropriate.
General commentary was reduced, and focused inspection requirements were added to more directly align to the purpose of the IP, making the inspections more efficient.
Guidance was improved on specific NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 inspection activities, including collaboration with the subject matter experts when needed and the addition of a range of the number of activities for review as appropriate.
We had a very successful training session on January 21 and project managers, inspectors, and subject matter experts are following up as a team for additional support for on-the-job training for implementing these procedures.
It is our goal to continue updating this procedure as needed, based on lessons learned and decommissioning program improvements. Thank you for your attention. Now, I'll turn it over back to you, Bruce.
MR. WATSON: Well, thank you, Zahira. I just wanted to point out that we did do the training on the inspection procedures in January as Zahira said. We also have a follow-up session planned in May for additional training and to get feedback from the inspectors on the implementation of the changes to the procedures.
So, with that, I'd like to introduce Tony Dimitriadis. He's our Region I branch chief that follows our decommissioning work. And Tony and I, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 obviously, talk frequently about issues and where the program's headed. So, with that, I'll turn it over to Tony.
MR. DIMITRIADIS: Thank you, Bruce.
Good afternoon, everyone. My name is Anthony Dimitriadis, I'm the chief of the Decommissioning ISFSI and Reactor Health Physics Branch in Region I.
My portion of the presentation will cover the Reactor Decommissioning Inspection Program and I'm going to talk about some of our recent inspection results. So, next slide, please.
So, this diagram shows the major steps during the decommissioning of a nuclear plant. On the left, you see the Reactor Oversight Program. On the right, you'll see the Decommissioning Oversight Program.
As the plant operates, the NRC resident inspectors provide direct oversight. After the reactor shuts down and the fuel is offloaded to the spent fuel pool, the resident inspector stays onsite for a period of time. And that amount of time varies by site, depending on need. Typically, the amount of time is about one to three months.
Now, upon initial shutdown, a number of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 activities are undertaken by the licensee at first.
They basically offload the fuel to the spent fuel pool. They drain and de-energize systems, conduct plant reconfiguration, and implement staff changes.
And they revise programs and procedures to reflect the changes in the plant, which has changed in configuration.
So, as far as how long the NRC resident inspector remains at the site, for example, at TMI Unit 1, the site shut down in September and the senior resident inspector remained onsite until about mid-December.
Now, typically, after the resident inspector has left the site, the onsite inspection activities are commensurate with the ongoing decommissioning work.
For example, if a limited amount of work is being performed, then we perform limited inspections. But when the work ramps up, to do active decommissioning that is, the onsite inspections increase via use of regional-based decommissioning inspectors.
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30 associated with decommissioning reactors. Next slide, please.
So, during our routine SAFSTOR inspection of Peach Bottom Unit 1, NRC inspectors identified a non-cited violation of technical specifications, which basically requires the performance of semiannual inspections and a radiological survey of the accessible portions of the contaminated vessel.
So, during an inspection of the containment, the inspectors noted that certain areas were fenced off or blocked and not available for inspection. So, review of surveillance and radiological surveys revealed that these areas were not routinely entered for survey and inspection.
This had been the condition since about 1978. And Exelon staff had considered these fenced-off areas to be inaccessible and believed that the tech spec requirements were being met.
But the NRC inspectors, obviously, delved into that a little bit and found that these areas could easy access by unlocking a barrier on the refueling floor and that Exelon was not correctly interpreting the technical specifications and the underlying technical specification basis. And, of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 course, they took corrective actions. Next slide, please.
During a SAFSTOR inspection of Millstone Unit 1, you can see a little bit on the right-hand side of the site there, the NRC inspectors identified a minor violation of the maintenance rule, 10 CFR 50.65(a)(2).
So, because the Millstone Unit 1 refueling floor has concrete walls, instead of metal blowout panels that is, the reactor building roof was equipped with tornado dampers to equalize pressure and to protect the structure.
So, the reactor building structure is important to safety and were scoped into the maintenance rule for Millstone Unit 1. The tornado dampers are designed to help mitigate against extended loss of spent fuel pool cooling, and that is the dampers are supposed to be open.
So, the NRC found that these dampers, which by the way are important to safety, were not routinely operated, tested, or surveilled. The dampers were being visually inspected every five years and their functionality was assessed using engineering judgment.
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32 So, during the inspection, the inspector observed the dampers and they did appear to be functional, but they were also in very poor material condition.
So, contrary to the regulations, Dominion had not been demonstrating that the tornado dampers remained capable of performing their intended function and, of course, Dominion took corrective action to demonstrate functionality. Next slide, please.
So, the GE Hitachi Vallecitos Nuclear Center contains basically three shutdown reactors.
One of the power reactors is the VBWR, the Vallecitos Boiling Water Reactor.
So, just to give you a little background on it. This is a reactor that was operational from about 1957 to about 1963. A possession-only license was issued on September 9, 1965. Therefore, 60-year SAFSTOR period began when the possession-only license was issued and it will expire on September 9, 2025, so about four years from now, four and a half.
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33 lack of surveillance and maintenance of the structure over the years.
So, based on our inspections, this led us to question the structural integrity of the building over the extended period. The licensee is now investigating the structural integrity of the building, due to our request for additional information on the issue.
Our inspectors observed evidence of water seepage, such as mineral deposits into the basement of the building. Our inspectors identified potential structural integrity issues, such as cracks in the support columns in upper floors, some corroded rebar, ground water ingress through and into the basement, and lack of ability to remove the water because the sump had become inoperable.
So, these structural issues need to be monitored over the years. In this case, the licensee has addressed most of the problems depicted in the picture, but it is still in the process of collecting data and doing an analysis of the structural integrity of the building.
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34 reactor, leaving only the reactor vessel itself.
So, to summarize, it is important to conduct surveillance activities at decommissioning or SAFSTOR reactor sites. We think that it's important as the years move on.
So, now, I'll turn it back over to Bruce.
MR. WATSON: Well, thank you, Tony. I think the point we'd like to make is that we need to have surveillances and continue those surveillances in good detail by the licensee to ensure that the site remains safe, especially in SAFSTOR.
Just because you've locked the doors doesn't mean, so to speak, doesn't mean it can be ignored. So, with that, we hope there's some words of wisdom that get out to all the licensees in making sure those get done. Thank you, Tony.
Our next speaker is Cynthia Barr.
Cynthia is, as I said, is a senior risk analyst or performance analyst in our Risk and Technical Assessments Branch.
Cynthia has graciously taken on the task of project managing NUREG-1757 Volume 2, which is huge, but it is a major step in updating our technical approaches to decommissioning. So, with that, I'll NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 turn the session over to Cynthia.
MS. BARR: Thank you, Bruce. My presentation is on guidance updates and other decommissioning initiatives.
Many staff were involved in the updates to the guidance documents, there are too many to name here, so I'll refer you to the list of contacts at the end of the presentation. Please feel free to contact those staff for additional information on specific topics. Next slide, please.
Updates to decommissioning guidance documents are related to updates to technology, based on stakeholder comments, and also based on lessons learned from reviews of decommissioning documents.
We updated four guidance documents.
Two of the guidance updates are associated with NUREG-1757, which is our Consolidated Decommissioning Guidance. Volume 1 is more of a process or programmatic type document. Volume 2 is more of a technical guidance document, focused on radiological surveys and dose modeling.
NUREG-1507 Rev. 1 provides guidance on minimum detectable concentrations with typical radiation survey instruments.
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36 And, finally, NUREG-1575 Revision 2 is the Multi-Agency Radiation Survey and Site Investigation Manual. You guys probably know it as MARSSIM. Next slide, please.
So, significant changes to NUREG-1757 Volume 1 including updated information on 10 CFR Part 170 fees incurred during decommissioning versus annual fees associated with 10 CFR Part 171, which stop when the site enters decommissioning.
A status update on the Site Decommissioning Management Program, or SDMP, which was a decommissioning program prior to the license termination rule, is also provided.
There is new guidance on the decommissioning planning rule relating to minimization of contamination and there's also information on categorical exclusions for decommissioning, which alleviate the need for environmental reviews for certain types of activities. Next slide, please.
Major changes to NUREG-1757 Volume 2 include key updates to dose modeling guidance on topics such as model abstraction or simplification, exposure scenarios for buried radioactivity, and a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 new Appendix Q on uncertainty analysis.
Updates to guidance on radiological surveys are primarily found in Appendix G and include surveys of excavations and surveys associated with soil reuse.
There was also updates to Appendix F and N, but I wanted to specifically point out new guidance in Appendix O on composite sampling. Composite sampling could be helpful for hard-to-detect radionuclides, where the costs of sampling start to become prohibitive. Next slide, please.
So, NUREG-1757 Volume 1 has been developed and will be issued this year. NUREG-1757 Volume 2 has been issued for public comment, with the public comment period ending April 8. So, you still have time to get your comments in, I think we have about four weeks left.
We are also having a public meeting on Monday to collect comments on the draft guidance document. So, if you're interested in participating, please look at the nrc.gov web page for additional details. Next slide, please.
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38 developed to support the license termination rule in August 2000 and NUREG-1507 Rev. 1 was published in August 2020, so 20 years later, lots of stuff to update. Next slide, please.
NUREG-1507 updates include changes in technology, such as new information on data capture tools using global positioning system and geographic information system technologies. There's also updated information on survey instrumentation. The revision also contains expanded information on a priori versus a posteriori method for detection decisions.
Finally, there is a new Appendix A that provides case studies and examples of how to calculate weighted efficiencies, such through minimal detection concentration equations, and provides examples of single and multi-source calibrations.
Next slide, please.
MARSSIM is the multi-agency guidance document that was recently updated in Revision 2. It also has been 20 years since the document was updated.
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39 and associated parameters, updated guidance on consideration of elevated areas, and a new Appendix E on rank set sampling, which could also be useful for hard-to-detect radionuclides.
Revision 2 is soon to be issued for public comment and has already undergone initial peer review by EPA's Science Advisory Board. There, you can find the guidance document for download, if you so choose. But we are waiting on just one of the agency's signatures on the Federal Register Notice before announcing the public availability of the draft document. Next slide, please.
Other decommissioning initiatives include adding computational tools and code, such as Visual Sample Plan, or VSP, to implement tools that we have in our updated guidance documents. Some updates to VSP are listed on this slide and most are available in the current version of VSP, which can be downloaded for free at PNNL's website.
We also have a contract on subsurface investigations to develop methodologies to address subsurface contamination more efficiently. A draft technical letter report is currently being finalized to help frame discussion topics for a workshop we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 plan to hold this summer. So, if you're interested in participating, please let us know and we'll get you more information. Next slide, please.
So, in conclusion, several guidance initiatives are completed or well underway to share lessons learned and experience for recent reviews and based on updated technology.
Improvements to computational tools have been made to facilitate survey design and data analysis.
And new guidance is being developed for subsurface investigations.
We are looking forward to working with you on continuing to increase the usefulness of our guidance documents and thereby increase the efficiency and review of licensee submittals related to the license termination.
And with that, I'll turn it back over to Bruce.
MR. WATSON: Thank you, Cynthia, great job. I wanted to just piggyback onto one thing, that I believe we're having a public meeting on Monday on NUREG-1757 Volume 2, and it's on our meeting and notice information and it's also had a Federal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 Register Notice out on it. So, we're hoping that we get a good attendance for that.
Our next speaker is Bruce Montgomery, as I said, my old colleague from Calvert Cliffs, I've known him for, well, I don't want to say how many decades, but it's been quite a few. So, I think Bruce's credentials speak for himself.
He's the lead of the NEI Decommissioning Working Group right now and does a number of different things for NEI. And so, with that, I will turn the mic over to Bruce Montgomery.
MR. MONTGOMERY: Yeah, thank you, Bruce, I appreciate that and appreciate the opportunity to be here at the RIC to speak. And I'd like to thank all of my co-panelists for the good work you're doing to improve decommissioning.
I've named my talk Driving to a New Normal in Decommissioning, because I think there's still a lot of work to do and I think the industry agrees with the statement that we still have a lot of work to do to normalize the decommissioning processes so they're predictable, consistent, and efficient.
So, I'll talk a little bit about that as we go. But, next slide, please.
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42 I find this quote from John F. Kennedy as apropos. The question I like to ask is, is decommissioning really the end or is it just the beginning of another important change that we have to work through?
In the past, I think many of you, decommissioning is a sign that might be the end of the commercial nuclear industry that's inexorably approaching.
I think a more contemporary view of decommissioning and all of the public attention and legislative activity and market reform that's going on, it might be the public is really looking at this and may be a little confused about what decommissioning is all about and what it means to them.
What I suggest is that we have an opportunity here to show the public an attribute of our industry that's unique and distinguishes us from others. That is, when we return many of these sites to the communities, we return them in a pristine, park-like condition.
Take Connecticut Yankee for example.
It's a beautiful site, all that remains there is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 independent spent fuel storage facility and you have to look hard to find it.
And I think in many other cases, we'll be laying the foundation for future nuclear power by making the sites available for advanced nuclear.
Next slide, please.
Now, a little bit of philosophy here.
So, life is circle, even in nuclear. And as nuclear power plant completes its operational lifetime, whether it shuts down prematurely or after an extended period of operation, what are we left with?
Well, we're left with a place that has access to high voltage transmission, has access to cooling water, has access to an experienced high tech labor force, and more often than not, a community that's embraced nuclear for decades. So, why in the world would this be the end of nuclear at a place like this?
I spoke of a new normal. What does that look like in practical terms and how do we strategically get there? And I think strategies always start with a good vision, so let's go to the next slide, please, and I'll talk about what I think our vision for new normal should be. And I've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 captured what I think that might look like the next time we get together in 2025 for the NRC Regulatory Information Conference.
So, first, we will have regulations that will allow a streamlined and preprogrammed journey from operations to decommissioning.
A second, we'll have license termination that's being achieved, the site released for unrestricted use, say around two years from the time a license termination plan has been submitted to the NRC for review and approval.
For those accelerated decommissioning projects, which are now far more popular, the DECON, those projects are being completed in only seven or eight years.
These projects are always being completed within the budgets defined by the nuclear decommissioning trust funds. And there's a used fuel solution that does not involve stranding fuel at the sites for decades. And there's a plan to repurpose the site to the benefit of society.
And after that's all said and done, the public looks back on decommissioning enterprise and says, you know, this really works and there's nothing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 to be afraid of.
I think underpinning this vision is a set of three core principles or core values. And I'm borrowing these from Mr. Doug Bauder, a colleague of mine at Southern Cal Edison, who is the chief nuclear officer there and is overseeing decommissioning at SONGS.
Safety, environmental stewardship, and community engagement. These three things underpin and are enablers to the success of decommissioning.
Next slide, please.
So, by 2025, decommissioning should be fairly well-paved road, I would say. In fact, we should have a regulatory and public policy equivalent to an easy-pass lane. This is not rocket science.
We are dismantling a shutdown industrial facility.
Yes, there are differences that demand some specialized technologies and expertise to radiologically decontaminate a plant and to demonstrate that it's been done so adequately, but decommissioning is not fundamentally different than demolishing any other large complex technical facility.
We've done these ten different times in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 commercial plants and we're about to complete the process at three more, at Zion, La Crosse, and Humboldt Bay. Next slide, please.
So, instead of an easy-pass, I think we've got more of an old-fashioned tool booth and a traditional lane of travel. And that's not really me driving, that's not really Bruce Watson there collecting a few. Next slide, please.
So, not only do we have a significant toll booth that takes quite a bit of time to get through, but there are quite a few speed bumps in the process. And I'll go through those.
First, we have to dismantle a plant's license piece by piece, and there are a lot of pieces.
It involves 12 to 15 different applications to obtain relief from regulatory requirements that no longer apply. There's lots of electronic paper going back and forth, with little value to the overall end state.
And we need site remediation and license termination processes that are straightforward and streamlined. Right now, they're very complex and difficult to navigate, because they're complicated.
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47 with quite a variety of different types of facilities, not just commercial.
And we presently do have spent fuel that's being stranded and has been stranded for quite some time at decommissioned sites and sites that are decommissioning.
We have communities that have been severely economically impacted by plant shutdowns, and understandably looking for ways to mitigate those impacts in the face of lost jobs and lost tax base.
And we have states and localities that want to exercise homegrown regulatory oversight standards that are often above and beyond the standards set by NRC. Next slide, please.
But despite the challenges we face today, we see signs of positive regulatory trends coming out of the activities that you've already just heard about from the panelists today.
But I'd like to start with the fact that I'd like to recognize the NRC's prompt reviews of a myriad of required transition licensing actions that they receive routinely now. So, really good job on taking those in and processing those approvals out with a minimum of requests for additional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 information.
The NRC's adopted the risk-informed performance-based decommissioning inspection program that you just heard about, very much appreciate that.
And in view of public concerns over the emergence of these new business models involving the purchase of sites and transfers of licensees to decommissioning specialty companies, I think the NRC's taken a targeted approach to the oversight of how those funds are spent, to make sure that those spent funds are not overspent.
And response to NEIMA, thank you for taking a very measured approach to the NRC's footprint and role with regard to encouraging healthy relationships and communications between licensees and the surrounding communities.
And most importantly, we appreciate the NRC's willingness to listen to NEI and the industry as we work to improve elements of the decommissioning process. Next slide, please.
So, besides the things that I would ask NRC to do, there are quite a few things that the industry needs to do as well to get to this new normal.
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49 First, we have to recognize that the kinds of people that we need to get through decommissioning, you have to get the rights skills, and the kinds of people that can develop and conduct final site radiological surveys are not easy to find.
So, that's going to be a challenge for us, and to some extent, we compete with the operating fleet for the kinds of skills that are important for decommissioning and site remediation.
We need to continue to build a reputation for the conduct of decommissioning in a safe and environmentally responsible way, just the way we continue to operate our plants in the current fleet safely. And we appreciate the NRC's presence onsite and oversight of the work we do as we're decommissioning these plants.
And very importantly, we need to learn from each other in decommissioning, just as we do in the operating fleet.
One thing that we've noticed, and I hear this from Bruce, I see, Tony, you're nodding as well, we get into this competitive enterprise called decommissioning, where you have these special new companies work. And it's a limited market, yes, it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 growing, but it's a limited market and very competitive.
So, we just don't have platforms, and maybe not even the impetus to share lessons learned, learn from each other and make the overall experience for the public and for the industry, and for the NRC, a better one. So, that's something that we have to work on.
And we need to maintain the same good community relations that we have during the operating phase into the decommissioning phase, especially where the owners of the plant is changing. So, that turnover, I know we still have many of the same people involved, even though the company's name has changed, but it's very important that we pay very close attention to our relationships with the community.
All of these things that I talk about will improve going forward with innovation and they are today. So, next slide, please.
So, as Bruce mentioned, I lead the Decommissioning Working Group at NEI. It's a very active, engaged group. It's got 35, at any one-time, active members. I've got a mailing list of well over 100. It's international. Suppliers, licensees, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 decommissioning specialty companies, and so forth.
And we've had a very busy year in 2020, we were chartered back in 2019. For 2021, we've set some big objectives that should put us well along the road towards that vision of 2025.
First off, we're going to continue advocating for that proposed transition rule. It's up with the Commission now, that's SECY-18-055. We really do need that.
And we're going to continue to work with the NRC as you work through the advanced notice of proposed rulemaking on how to comply with the Dodd-Frank Act on nuclear decommissioning trust funds.
And, in fact, we sent in our comments on that ANPR on Monday, so we're looking forward to the next steps on that.
There's been a lot of activism, I'll call it, at the state level. I'll point to New York. As we see things unfold there, we have the Public Service Commission getting more involved.
NEI is watching these things very closely, and as requested by our member companies, we'll get involved to help educate and inform the policymakers, so that we can work through this in a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 way that's a win-win for all.
We need to clarify the regulatory framework for radioactive waste disposal. It would be good to see a Part 61 rulemaking that talks to some of the issues, it always has and needs to on high level waste, but also on very low level waste disposal, maybe greater than class C waste. That would be good to see.
A big project that we're undertaking this week, or this year, is to develop a comprehensive industry guideline and template for how to develop license termination plans, with the final survey plans within them, and how to work through them to the end. That's a big, big deal.
And, Cynthia, I'll be on your meeting on Monday, looking at your presentation on NUREG-1757, and might offer a few comments as well, because we've been working very hard to read through that and develop our constructive input to the process.
And I think, looking back to what we've already decommissioned, the plants up in the Yankees and so forth, we have -- as people move through the process, they get smarter.
Things like emergency planning, what the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 EALs should look like, what does the physical security plan look like? Folks are coming up with some good idea, so we're going to circle back and we'll get with the NRC at the appropriate time, but we'd like to try to normalize some of these emergency and physical security plans as well.
So, we're going to have a busy year in 2021.
So, go to my last slide here, I think in conclusion, I propose that we start looking at decommissioning as the inevitable journey we'll all going to have to take sooner or later, whether it's prematurely or 40, 60, 80, or even 100 years, we need to understand that what we're really looking at is the nuclear circle of life.
So, the way I look at it, we build new, we operate well, we decommission responsibly, and we repeat.
So, thank you for that. I'll turn it back to you, Bruce.
MR. WATSON: Well, thanks, Bruce, for a number of compliments. I think the staff has worked very hard and I think we're going to continue to work very hard as we go into the future.
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54 So, we're looking forward to looking with you and industry and the public, and of course, the states, over the issues concerned about decommissioning.
We have a few minutes left here, so we have a number of questions, we'll see how many we can get to before we're done here.
But I thought I would just go ahead and take the first question, which is what is the NRC's general overall decommissioning rulemaking plan, especially to eliminate the licensee's need for exemptions in areas such as emergency planning?
These exemptions are not well-understood by the public.
So, that's the question. The answer's pretty straightforward, I think, in our minds. When these plants started decommissioning, transitioning from operations to decommissioning, the NRC took a very broad look at all the requirements in the regulations to, I'll call it undo a number of issues and requirements to get the plant into decommissioning, that were really not required anymore.
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55 process. One thing about exemptions is they do not require or have the opportunity for hearing or other public comment from the public. And so, yeah, it is a little bit concerning that there is not much public engagement on that.
However, in saying all this, the rulemaking was intended to improve the efficiency, since there's really no safety considerations in the decision-making that went into the rulemaking.
Having closed a number of plants, so to speak, since 2013, when we started with Kewaunee, we've learned a lot. We know that the processes are pretty much established.
One particular one related to emergency planning is the time it takes for the fuel to cool and to make the spent fuel pool pretty much fairly benign in that you cannot have a fuel issue that would cause an offsite dose problem or dose meeting the EPA tags.
So, with that, our plan is to continue to make things, improve the efficiency of the licensing process. Because in doing that, we're also preserving resources from the decommissioning trust funds and also, the resources the NRC needs to process NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 those things.
So, with that, I'll go to, let's see here, I think it's number seven. No, it's not, it's number six. I'll go ahead and answer.
You stressed the recent lessons learned are incorporated into the IP, could you give a concrete example identified in lessons learned has been addressed in the IP?
I'm going to go ahead and start and then, turn it over to Zahira. But the one thing that I think is important is we made the fire protection procedure a core procedure, because a lot of the precursor events we were seeing out in the industry, especially at the beginning of decommissioning with fire protection.
We had a number of incidents which were not reportable, but yet, could have been worse had they not been following most of the procedures.
So, Zahira, you got anything you want to add to that?
MS. CRUZ: That was actually the --
MR. WATSON: Example you were going to give?
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57 provide.
MR. WATSON: Okay.
MS. CRUZ: But, I mean, during the presentation, I mentioned that we also improved, we revised the definition of some of the surveys to provide more possibility for the inspectors to collect samples as needed, not just at the end of the final status survey. So, that's another example.
MR. WATSON: Okay. Another question on IMC 2561 says that, I use 2561 when accompanying the NRC on inspections. Do you have any idea when the January 2021 update versions would be available in ADAMS? Have there been any updates coming soon for the IPs within 2561?
MS. CRUZ: They're available in the public website already.
MR. WATSON: Yes.
MS. CRUZ: Yeah. So, under public library NRC documents. Or anybody can reach out any of the project managers in decommissioning and we can provide the information too.
MR. WATSON: Okay. Let's see here. I believe I'm going to ask Tony to answer this one.
Physical hazards can be significant during NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 decommissioning and dismantlement, but have noticed that the NRC deleted the inspection procedure associated with those reviews.
Has the NRC decided physical hazards are not a significant part of the NRC oversight? If so, how are the other agencies, such as OSHA, filling the void?
Tony, got an answer for that one?
MR. DIMITRIADIS: Thank you. Yeah, thank you for the question, appreciate it. No, we have not deemed that these hazards are unimportant, but we do -- so, in a decommissioning process, there are two portions when it's being dismantled.
One is the contaminated parts, and there's all the buildings in the protected area that are dismantled. So, of course, there are hazards.
And similar to regular health physics, our inspectors observe the decommissioning and dismantlement activities with the thoughts of time, distance, and shielding, right? So, for radiological hazards.
For physical hazards, we implement the same kind of philosophy, if you will, and our inspectors ensure that the licensee is implementing safety measures, like PPE for the individuals, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 that people take appropriate safety measures. So, we absolutely observe the hazards and how they're treated onsite.
And, speaking of which, we maintain strong partnerships with OSHA. We have a memorandum of understanding with OSHA and we reach out to OSHA through our state liaison officers, through each of our offices. And we maintain very good communications with them, in the event that there's something that we feel that should be inspected by OSHA directly.
So, just to recap, we certainly maintain our vigilance on safety during dismantlement activities. We want to make sure that these actions are done in a safe manner.
And by the way, the licensee has a vested interested in ensuring that these things are done safely, for their own workers and, certainly, members of the public.
MR. WATSON: Okay. Tony, thanks.
Another question, which I'll probably follow up to you, Tony, with is that during the RIC and other NRC presentations, safety culture is deemed to be extremely important to ensure safety of workers and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 members of the public. However, I did not hear a discussion on that topic. How is NRC incorporating this into the inspection program?
I think, from our perspective in decommissioning, we look at safety culture with a very keen eye. We look at the licensee's performance metrics that they use for safety, but it's more holistic than that.
We look at their planning and how they incorporate safety into not only the physical work, but the radiological work, in ALARA planning, in amply maintaining all of their programs during the entire decommissioning process.
So, Tony, I don't know if you have anything else to add?
MR. DIMITRIADIS: Sure, yeah, I do, actually. So, in Manual Chapter 2561, basically, in Appendix A, it outlines nine core procedures. One of those procedures is Inspection Procedure 40801.
And we -- just to sort of lay it out for other people, other members of the audience. So, safety culture talks about how employees should really feel free to raise safety concerns, both to their management and the NRC, without fear of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 retaliation.
So, although the licensee may be implementing an employee concerns program or similar safety programs regarding identification of safety issues and fixing those issues, we want to make sure that the underlying factors that would produce a potential chilling effect or reluctance to report such issues could exist, and we want to make sure that we keep a pulse on that.
Our inspectors are specifically trained for this sort of thing and we implement Inspection Procedure 40801. And during our inspection, we expect, and our people, our inspectors, they have discussions and interviews with both members of licensee management and staff throughout the site at routine inspections.
Our people are there, typically, two or three weeks during any given a quarter, and they assess safety culture on a routine basis. So, that's something that we absolutely keep tabs on.
MR. WATSON: Okay. Tony, thank you for your comments on that. Safety culture's just part of the routine, I believe, in our day-to-day observations of the activities at all sites. And I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 was just going to add that we expect the same safety culture from operations to translate directly into the decommissioning process.
So, we have a number of questions about financial area. And before I get to Ted, I had one question for Bruce Montgomery, and it's really from me and the staff, not from the audience.
But it just seems to me, and you and I have talked about this in the past with some of the final status survey report we've received, but more recently, we seem to be getting lots of volume of information to support a licensing action request.
And it seems to me that we are getting just hundreds of pages of information that may or may not be necessary for us to make that licensing decision. Because it's really incumbent on the licensee to make those decisions.
And it seems like with providing all this information, I don't know if it's a justification of what they're trying to do in infinite detail, but also, it adds to our time for us to evaluate the information, since it's much more volume.
And I just wanted to get your perspective on it, because I want to make sure that the licensees NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 are making the decisions and we're in the regulatory mode of verifying that they're making the correct decisions and issuing an approval or denial, whatever the case may be. But, hopefully they've done an adequate job.
So, I didn't know if you had any perspective on that that you'd like to share with us?
MR. MONTGOMERY: Yeah, thank you, Bruce.
I think in a healthy licensee-regulator relationship, we would make the decision and that we had gotten to the right conclusion and point in the process, and then, you're simply validating what we already know or what we propose to you and you only get the information you need to be able to do that validation.
So, I think what you're seeing is some uncertainty on the part of the licensees on what your expectations are in the volume and the types of information to send to you.
So, I think this is a perfect example of where we can come in and provide some guidance to our membership, to say, here's what you really need to do at your site, here's the documentation that's really worth, that passes muster at the NRC, and only send what you need to send in, so that your reviews can be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 very focused and come to the conclusion in a reasonable time frame.
So, I think, if you start off badly with a poorly written license termination plan, vagueness in what the final status survey process is going to look like, then you don't have those guardrails to come in in a very focused way.
And I think we're guilty of maybe not getting a good start and well-defined plan and something that we can follow and stay within those guardrails and make life easier for everybody and get through these processes more timely.
So, that's really what our license determination guidance is all about.
MR. WATSON: Okay. Well, thank you for confirming what I believe should be the path. We are, the NRC's probably going to be -- we've been asking for more pre-submittal meetings on most activities, because we want to better understand the issues out in front so we can do a more efficient job at doing the review. So, I appreciate that.
With the last few minutes we have left, I was going to turn some of the questions over to Ted Smith. So, Ted, the next question is, can you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 outline what details can be required in the likely 30-day withdrawal notice of guidance? Maybe I should number -- no, go ahead, that's it.
MR. SMITH: Sure, it's a great question.
The expectation is that the level of detail would be similar to what we wanted to see in those annual reports, where they itemize expenses, similar to the site-specific cost estimate, so that staff can go in, inspectors, and do a comparison of what those notices are saying and what's actually been done.
So, it's very similar to the way we're trying to clarify for the overall expenditures, just want to bring that parallel level of detail into the 30-day notices.
I would point out that, in most cases, those 30-day notices really apply to operating reactors. By exception or license condition, they'll apply to decommissioning.
MR. WATSON: Okay. The next question, also for you, 50.75(c), which is the generic formula for estimating decommissioning cost, was developed more than 35 years ago and seems to consistently underestimate the actual decommissioning costs.
Should the regulation be updated to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 reflect all of the additional information that have been gathered in the last 35 years?
MR. SMITH: Yeah, so, this is another great question. An important piece to understand in the relationship between the formula and the site-specific cost estimate is that it's not our expectation that they will match dollar-to-dollar at the point of shutdown of the facility.
The purpose of the formula is to make sure that the bulk of the funds are there and ready.
And we require that site-specific formula be done in advance, so that enough money is there to actually do the decommissioning.
But I also want to point out that that formula is not frozen in time. So, the formula does start with the basic information of whether it's a PWR or BWR and the power output as the basis for determining the amount of money.
But it is adjusted, if you look in the second paragraph, under that 75(c)(1) and (c)(2), has adjustment factors. Those adjustment factors are labor, energy, and disposal costs.
The labor and energy costs are based on updates from the Bureau of Labor and Statistics that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 are based on regional data for where the reactor is located. So, that's an annual update to energy and labor costs.
The burial costs come from NUREG-1307, which is updated every two years. And so, you have, at most, two years from when we've gone back and looked at the critical factors that affect the validity of the formula.
Additionally, on top of that, on a periodic basis more on the order of eight to ten years, I don't recall the exact amount, we go back and look at the formulation of the formula itself.
Are the factors right? Are we appropriately determining the relative proportion of different types of waste, so that the formula is correct, even with those adjustment factors that are adjusted on an annual or biannual basis?
So, I see that time's up, but the bottom line is that that formula is pretty current and sufficient for purpose.
MR. WATSON: Well, it looks like we've run out of some time here. So, given that, I want to thank everybody, the panel, for participating today. There's other ways to get the questions to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 us, we'll see how we can capture those and hopefully respond some way through the RIC.
And so, I really want to thank everybody and appreciate all the people that registered and listened in on today's discussions. I hope you found it interesting and of benefit to you.
I think, again, I think we are continuing to make good progress in the decommissioning program, and we'll continue to look forward to our continued improvement, because I think there's room for continuous improvement in every aspect of the world.
So, I appreciate it and thank you very much, and have a great afternoon. Thank you.
(Whereupon, the above-entitled matter went off the record at 2:46 p.m.)
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