ML22279A993
| ML22279A993 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/30/2022 |
| From: | Sauger J ZionSolutions |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML22279A984 | List: |
| References | |
| ZS-2022-043 | |
| Download: ML22279A993 (9) | |
Text
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ZIONSOLUTIONSLLC--------
An EnergySolut/ons Company September 30, 2022 ZS-2022-043
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304
Subject:
Revised Final Status Survey Release Records, Final Reports, and Discrete Radioactive Particle Survey Report Technical Support Document
References:
- 1) Gerard van Noordennen, ZionSolutions, Letter to U.S. Nuclear Regulatory Commission, "Revised Response to Request for Additional Information Related to Partial Site Release and Recent Site Survey Activities," dated March 22, 2022 As a follow-up to the referenced letter, ZionSolutions, LLC is providing the enclosed revised Final Status Survey (FSS) reports for Survey Units (SUs) 12102, 12103, and 12201C, D, and E. These survey units had the FSS reperformed due to removal of subsurface concrete material (SUs 12201 C and 12201D) and areas requiring additional fill (SUs 12201B, 12102, and 12103) after the initial FSS was completed. Also enclosed are the revised Phase 3 and Phase 4 Final Reports and the revised technical support document (TSD)22-001, "Discrete Radioactive Particle Survey Report."
The attached FSS reports are revisions to previously submitted versions. These revisions were necessary to submit the findings of surveys that were performed in survey units that were disturbed by the exhumation or covering of subsurface material that was discovered in February and March of 2022 or survey units where clean concrete demolition debris was stored or transported through and FSS was not originally reperformed.
With this submittal, ZionSolutions has completed all documents that are required for the termination of the licenses for the Zion Nuclear Power Station, Units 1 and 2. Based on our communication with NRC regarding the requests for additional information and the recently completed audit, staff is not expecting any additional submittals at this time. As such, it is our expectation that there is no impediment to the NRC conducting its review.
Completion of the FSS process for Zion has been delayed due to the need to address the presence of discrete radioactive particles (DRPs, or "hot particles"). The site has otherwise been remediated to the point where it meets the NRC's residual radioactivity standard of 25 mrem per year for unrestricted release. ZionSolutions has worked diligently to address the DRP issues and believes its approach satisfies NRC requirements and guidance and is consistent with precedent in this area.
ZionSolutions believes that it has fully satisfied NRC's regulations in 10 CFR 50.82(a)(l 1) that specify the conditions under which the NRC shall terminate the licenses. This includes regulations in 10 CFR 50.82(a)(9)(ii)(D) addressing final radiation surveys, which provide that the License Termination Plan (LTP) must include "detailed plans for the final radiation survey." These FSS reports, along with those previously submitted, demonstrate compliance with 10 CFR 20.1501(a),
which require a licensee to perform surveys that may be necessary to comply with the radiological criteria for license termination found in Part 20, Subpart E.
101 Shiloh Boulevard, Zion
- IL 60099 (224) 789-4016
- Fax: (224) 789-4008
- www.zionsolutionscompany.com ZionSolutions, LLC ZS-2022-0043 Page 2 of 3
In conducting these surveys, ZionSolutions has followed NRC guidance for site surveys for decommissioning of reactors provided in NUREG-1757, Rev. 1, Vol. 2, Consolidated Decommissioning Guidance: Characterization, Survey, and Determination of Radiological Criteria (2006). We have used the methodology described in NUREG-1575, Rev. 1,.Multi-Agency Radiation Site Survey and Investigation Manual (MARS SIM) (August 2000).
A complication that ZionSolutions has faced in this process is addressing the presence of DRPs.
NUREG-1757 and MARSSIM provide only general guidance on addressing DRPs. For example, for purposes of selecting survey units for detailed review, section 4.5.1.2.3 ofNUREG-1757 indicates that factors to consider include "use of MARSSIM survey methods and statistical tests when hot particles are present." MARS SIM does not consider DRPs explicitly, but recommends use of a process to identify elevated areas of radioactivity.
Consistent with MARS SIM, ZionSolutions has used a process, including scanning, to detect DRPs not previously detected and rem.ediated. This process is described in detail in the enclosed document, "Discrete Radioactive Particle Survey Repo1t." ZionSolutions' process is similar to methods that have been found acceptable by the NRC for addressing DRPs at other decommissioning projects.
As ZionSolutions has noted in its response to the NRC RAis, the precedent for dealing with DRPs as part of the decommissioning and license termination process include:
- She/well Services, Inc. - For decommissioning of the Shel well site near Columbus, Ohio, the Com.mission itself "approved the staff's proposed use of a probabilistic approach in determining whether the Shelwell site may be released for unrestricted use." 1 Shelwell detem1ined the "expectation dose" from DRPs based on the probability of finding a DRP in a given area and the potential number of particles per year that could be ingested or inhaled.
ZionSolutions used a similar approach for calculating expectation doses and the associated risk to a future occupant of the site.
- Yankee Rowe - DRP issues for Yankee Rowe required use of rigorous surveys and an assessment regarding the effective dose equivalent (EDE) of Co-60 and Cs-137 hot particles.
In approving the FSS reports for Yankee Rowe, the NRC Staff concluded that the EDE was an appropriate dose calculation for DRPs. 2
- Maine Yankee - DRP issues were addressed at Maine Yankee in part through use of a supplemental characterization process. As reflected in Revision 1 to the Maine Yankee LTP, if hot particles that would exceed remediation thresholds on-site were discovered, hot particle remediation would be undertaken following onsite methods and protocols.
- Connecticut Yankee -The NRC's Atomic Safety and Licensing Board addressed the issue of the adequacy of surveys for DRPs in connection with the LTP for Connecticut Yankee (CY). 3 In that case, the Licensing Board analyzed CY's method for detecting DRPs and their impact during decollllllissioning activities. CY's FSS plan was developed using the guidance of MARS SIM, and CY proposed to use its surface soil survey methodology per MARS SIM to detect any DRPs not previously detected and rem.ediated. The Board found that CY had
1 Staff Requirements Memorandum on SECY-98-117, She/well Services, Inc., Risk Assessment (May 27, 1998).
2 See NRC Letter, "Yankee Nuclear Power Stations -Approval of Final Status Survey Reports," dated January 25, 2007 (ADAMS Accession No. ML070220076).
3 Connecticut Yankee Atomic Power Co., LBP-03-18, 58 N.R.C. 262 (2003)
ZionSolutions, LLC ZS-2022-0043 Page 3 of 3
shown that its LTP met the requirements of 10 C.F.R. § 50.82(a)(9) with regard to the presence of DRPs at the site, and that it met the requirements of Subpart E to Part 20.
We believe these precedents are important and relevant because they indicate that if a licensee has an PSS plan based on MARSSIM, with a process for assessing dose and remediating DRPs, there is reasonable assurance that the licensee's plan will address DRPs sufficiently to protect public health and safety. 4 We encourage the NRC to rely on previous cases that were similar in nature to that of Zion.
There are no regulatory commitments made in this submittal. If you should have any questions regarding this submittal, please contact Gerry van Noordennen at (860) 462-9707.
Respectfully,
(, Digitally signed by John J' John Sauger Sa U g er /~ Date,: 2022.10.03 /,. 11 :55:06 -04'00' John Sauger v President and CNO, Reactor D&D Division
Attachment:
Preflight Report
Enclosure CD containing PSS Release Records SU 12102, 12103, 12201C, D, and E; Phase 3 and Phase 4 Final Reports; and TSD 22-001 Revision 2.
cc: Kimberly Conway, U.S. NRC Project Manager Regional Administrator, U.S. NRC, Region III Zion Nuclear Power Station, Units 1 and 2, License Transfer Service List (w/o Enclosure)
4 A draft revision of the MARS SIM guidance was published for public comment in 2020, with a new provision on remediation of "discrete radioactive particles." The publication of new draft guidance shows that this is an evolving area for the industry and the NRC where requirements are not yet settled, and so it would not be appropriate for NRC to impose new regulatory positions on ZionSolutions or other decommissioning licensees at this time.
Zion Nuclear Power Station, Units 1 and 2, License Transfer Service List
cc:
Ken Robuck Steven A. Reynolds President and CEO Manager, Nuclear Facility Inspection Energy Solutions Division of Nuclear Safety 299 South Main Street, Suite 1700 Illinois Emergency Management Agency Salt Lake City, UT 84111 245 W. Roosevelt Road, Units 55 & 56 West Chicago, Illinois 60185 John Sauger President and Chief Nuclear Officer Kelly F. Grahn ReactorD&D Senior Health Physicist Energy Solutions Illinois Emergency Management Agency 121 W. Trade Street, Suite 2700 Division of Nuclear Safety Charlotte, NC 28202 245 W Roosevelt Road, Building 8, Suite 55 West Chicago, IL 60185 Todd Eiler Vice President Dan Eder, MPH, IPEM, LEHP D&D Engineering/Projects Interim Manager Energy Solutions Lake County Emergency Management Agency 121 W. Trade Street, Suite 2700 1303 N. Milwaukee Avenue Charlotte, NC 28202 Libertyville, IL 60048-13 08
Russ Workman General Counsel Energy Solutions 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 ZionSolutions
ZS-2022-043 Attachment
Zion Nuclear Power Station, Units 1 and 2
Preflight Report ZionSolutions, LLC ZS-2022-043 Attachment - Preflight Report Page 1 of 1
This document serves as the preflight report for the Enclosure to ZionSolutions letter ZS-2022-043. The file did not pass pre-flight criteria or do not meet NRC criteria; however, the text is word searchable and legible.
File Name Preflight Reason Status
01 Phase 3 FSSR REV! Error/ Failed Document contains logos, graphics, color maps, digital photos, and signatures < 300 ppi, clear and legible
02 Phase 4 FSSR REV2 Error/ Failed Document contains logos, graphics, color maps, digital photos, and signatures< 300 ppi, clear and legible
03 Release Record 12102 REVl Error/ Failed Document contains logos, graphics, color maps, digital photos, - - and signatures < 300 ppi, clear and legible
04 Release Record_12103_REV1 Error/ Failed Document contains logos, graphics, color maps, digital photos, signatures, and scanned pages< 300 ppi, clear and legible
05 Release Record 12201C REV2 Error/ Failed Document contains logos, graphics, color maps, digital photos, - - signatures, and scanned pages < 300 ppi, clear and legible
06 Release Record_ 12201D _ REV2 Error/ Failed Document contains logos, graphics, color maps, digital photos, signatures, and scanned pages< 300 ppi, clear and legible
07 Release Record_l2201E_REV2 Error/ Failed Document contains logos, graphics, color maps, digital photos, signatures, and scanned pages< 300 ppi, clear and legible
08 TSD 22-001 Discrete Radioactive Particle Survey Error/ Failed Document contains logos, graphics, color maps, digital photos, Report REV 2 signatures, and scanned pages< 300 ppi, clear and legible Zions olutions
ZS-2022-043 Enclosure
CD containing FSS Release Records -12102, 12103, 12201C, D and E; Phase 3 and Phase 4 FSS Final Reports; and TSD 22-001 Revision 2