ML22347A104
| ML22347A104 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/2022 |
| From: | Tanya Hood Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | Shaun Anderson Division of Decommissioning, Uranium Recovery and Waste Programs |
| References | |
| EPID L-2022-LRM-0095, NEI 22-01 | |
| Download: ML22347A104 (6) | |
Text
MEMORANDUM TO:
Shaun M. Anderson, Branch Chief Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards FROM:
Tanya E. Hood, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF NOVEMBER 16, 2022, PUBLIC MEETING TO DISCUSS THE NUCLEAR ENERGY INSTITUTES PRE-SUBMITTAL OF NEI 22-01, LICENSE TERMINATION PROCESS (EPID - L-2022-LRM-0095)
On November 16, 2022, a hybrid public meeting was held at the U.S. Nuclear Regulatory Commission (NRC) with Nuclear Energy Institute (NEI) to discuss NEI 22-01, License Termination Process. NEI 22-01 provides industry guidance on preparing license termination plans and final site survey reports based on existing NRC guidance. NEI 22-01 is informed by case studies from previous industry experience and provides advice on interactions with other Federal and State organizations during decommissioning. In this pre-submittal meeting, NEI presented information on the contents of the planned submittal and requested preliminary feedback on the scope of the document from NRC staff.
The meeting notice and agenda, posted November 2, 2022, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML22319A011 and are posted on the NRCs public Web page at http://www.nrc.gov/reading-rm/adams.html. The presentation material provided by the licensee are available in ADAMS (ML22318A303).
Persons who do not have access to ADAMS or who encounter problems in accessing the meeting materials located in ADAMS should contact the NRC Public Document Room reference staff by telephone at 1-800-397-4209 or by email to PDR.Resource@nrc.gov.
CONTACT: Tanya Hood, NMSS/DUWP 301-415-1387 December 13, 2022 Signed by Hood, Tanya on 12/13/22 During the meeting, NEI presented a high-level overview of the information contained in the NEI 22-01 guidance document. There are nine chapters and eight appendices that discuss site characterization, remediation and final status survey plans and reports, compliance with radiological criteria for license termination, and supplement to the environmental report among other topics.
The NRC staff asked several clarifying questions which expanded the discussion on the communication among licensees and the regulator. The NRC appreciated NEIs efforts to develop guidance specific to reactor licensees noting that NRCs decommissioning guidance is broad to cover both materials and reactor licensees. The NRC noted that NEI plans to develop a crosswalk between the license termination process and NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, and NUREG-1757, Volume 2, Rev. 2. The NRC would welcome any additional comments from NEI on areas where its guidance document could be improved.
The NRC staff reiterated that guidance, such as, the NEI submittal is one approach to meeting the NRC requirements and noted that NRC has expended significant resources to develop technical guidance that the NRC staff accepts as one way to comply with the regulations for a wide range of licensee types. NRC guidance has made the process more efficient, such as MARSSIM, NUREG 1575, Multi-Agency Radiation Survey and Site Investigation Manual. Any new technical approaches to comply with the regulatory requirements may require a comprehensive technical justification for the NRC staff to evaluate and approve.
The NRC staff stated that it would be important to discuss in Section 2.1, Objectives of Site Characterization, how characterization surveys support final site survey planning and decision-making with final status surveys being the focus of NRC staff review. For example, sufficient data should be collected during characterization to support the use of an in-situ object counting system for final status survey. Characterization data is also used to support survey unit classification, final status survey plans, and statistical parameters.
The NRC staff stated that it would be useful to include a general as low as reasonably achievable discussion related to good housekeeping and general work practices in NEI 22-01.
For example, removing small, elevated areas or discrete radioactive particles as you encounter them and dispositioning the material as you go as opposed to trying to address them during the final status surveys.
The NRC staff also discussed the benefits of a section on quality control to verify key assumptions in the final status surveys (e.g., verification of radionuclides of concern and surrogate ratios). Additionally, data quality objections for surface water and groundwater monitoring should be discussed (e.g., to assess dose contributions from surface and groundwater residual radioactivity or to evaluate concentrations against Environmental Protection Agency memorandum of understanding thresholds). NRC also indicated that NEI 22-01 would benefit from a discussion on decommissioning of above and below grade structures that will remain in place and the types of exposure scenarios that will be considered for buried residual radioactivity. A description of planned decommissioning activities and the types of controls that will be in place to mitigate releases residual radioactivity to the environment will be important.
Based on insights gained from the discussion of the NEI 22-01 contents with NRC staff, NEI indicated that it would consider the following as part of the final submittal to the NRC:
1.
A high-level overview of the document that is readily available for the public.
2.
A roadmap discussing various elements of the site characterization.
3.
Some discussion on quality control samples to verify that the assumptions made during site characterization follow through into final status surveys.
4.
A pointer to fuel materials to easily identify where it is addressed.
5.
Possible addition discussing variable ambient background challenges.
NEI plans to submit this document for NRC review in mid-December 2022 under a fee waiver request. No regulatory decisions were made during the meeting.
Approximately 25 representatives from industry, state government, and NRC participated in the meeting. A list of the meeting attendees is enclosed. Members of the public were invited to attend. No public meeting feedback forms were received. Please direct any inquiries to me at (301) 415-1387 or Tanya.Hood@nrc.gov.
Enclosure:
List of Attendees
ML22347A104 OFFICE NMSS/DUWP/RDB/PM NMSS/DUWP/RTAB/SRA NMSS/DUWP/RTAB/BC NAME THood CBarr CMcKenney DATE 12/08/2022 12/08/2022 12/13/2022 OFFICE NMSS/DUWP/RDB/BC NMSS/DUWP/RDB/PM NAME SAnderson THood DATE 12/13/2022 12/13/2022
Enclosure LIST OF ATTENDEES NOVEMBER 16, 2022, PRE-SUBMITTAL MEETING WITH NUCLEAR ENERGY INSTITUTE RE: NEI 22-01, LICENSE TERMINATION PROCESS Name Organization Boby Abu-Eid U.S. Nuclear Regulatory Commission (NRC)
Shaun Anderson NRC Cynthia Barr NRC Gregory Chapman NRC Kim Conway NRC Christian Dennes NRC Suzanne Dennis NRC Anthony Dimitriadis NRC Marlayna Doell NRC Randall Fedors NRC Tanya Hood NRC Jane Marshall NRC Christepher McKenney NRC Jack Parrott NRC Paul Rades NRC Neil Sheehan NRC Bruce Watson NRC Bruce Montgomery Nuclear Energy Institute (NEI)
John Conly Certrec Sarah Roberts Energy Solutions Gerard P. Van Noordennen Energy Solutions John Clements Public Eric Darois Public John Jernigan Public Jeff Kitsembel Public
ML22347A104 OFFICE NRR/DORL/LPL2-2*
NMSS/DUWP
/RTAB*
NMSS/DUWP/RTAB* NMSS/DUWP/RDB*
NAME THood CBarr CMcKenney SAnderson DATE Dec 13, 2022 Dec 13, 2022 Dec 13, 2022 Dec 13, 2022 OFFICE NRR/DORL/LPL2-2 NAME THood DATE Dec 13, 2022