ML22154A013
| ML22154A013 | |
| Person / Time | |
|---|---|
| Issue date: | 06/06/2022 |
| From: | Bruce Watson Reactor Decommissioning Branch |
| To: | |
| Watson B | |
| Shared Package | |
| ML22154A011 | List: |
| References | |
| Download: ML22154A013 (7) | |
Text
License Termination Strategies Decommissioning Strategy Forum Las Vegas, Nevada June 6, 2022 Bruce A. Watson, CHP Division of Decommissioning, Uranium Recovery and Waste Programs
Successful License Terminations Licensees have strong Operational Health Physics and Quality Assurance Programs that transfer into the Final Status Survey Program
- Manage data as it is collected and ensure consistency
- Have strong Corrective Action Programs
- FSS employs a Quality Assurance Survey Program to verify field performance Have strong licensing programs
- Communicate often with NRC before submittals
- Ensure submittals are accurate and of high quality Effectively use the 10 CFR 50.75(g) files, even in decommissioning, to ensure compliance at the end of the project Effectively use lessons learned, manage consultants, and contractors Communicate with the local community and elected officials
Lessons Learned
- The License Termination Plan or Decommissioning Plan replaces the Safety Analysis Report and is incorporated into the license by amendment. Compliance is required.
- The licensee management is responsible for licensee performance and compliance. Challenges that impact the NRCs reviews include:
- Quality of the submittals
- Overly complicated dose modeling
- Over classification of survey units
- Not delisting of radionuclides
- Complex survey procedures
- Excessive information in Final Status Survey Reports
- Licensees cannot delegate compliance to a contractor.
3
Moving Forward
- NRC and Federal Partners with input from industry have provided extensive decommissioning guidance and tools as the roadmap to success, continuous improvement is welcomed.
- New approaches, deviations need technical justification, and the 2.206 petitions process is there for specific rule changes.
- NRC has initiated research to develop guidance on Discrete Radioactive Particles to ensure Commission policy and regulatory framework is followed.
- NRC has initiated work to develop sub-surface guidance and recently held a 2nd public workshop.
- NRC is your regulatorcommunicate often and do not assume your schedule will be ours.
4
Projected License Terminations
Moving LTP Schedules
Thank you and look forward to your comments and questions!
N. S. Savannah - License termination by 2031