ML23103A192
| ML23103A192 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/19/2023 |
| From: | Jack Parrott Reactor Decommissioning Branch |
| To: | ADP CR3 |
| Parrott J | |
| Shared Package | |
| ML23103A189 | List: |
| References | |
| eConcurrence 20230413-80012, EPID L-2022-LLA-0194 | |
| Download: ML23103A192 (3) | |
Text
Information Needed for NRC Staff to Continue Acceptance Review of the LTP Item No. Regulation (s) NUREG -1700 Rev 2 NUREG 1757 Vol. 2, Rev 2 Information Provided Information Needed 1 50.82(a)(9)(ii)(A) Section 2.2.1 "Acceptance Section 4.2.3.1.3 A site map of survey areas and survey units with borders that Discussion of survey methods and results, including tables/maps of (ii) The license Criteria" 3rd & 5th bullets. were not well defined and unclear identification of the sample the sampling results/locations. This is needed for both the impacted termination plan locations within given survey areas and survey units. and non-impacted areas identified in the LTP. Identification of the must include Section A.2 Site background levels and how the background levels were established (A) A site Characterization that are used during characterization surveys and will be characterization subsequently used for final status surveys in support of license Subsection on termination.
Characterization Surveys: 2nd & 3rd Reminder: The CR Characterization Plan needs to follow NUREG bullets. 1575 and 1757 Guidance otherwise the licensee must provide technical justification to demonstrate the technical adequacy of the proposed alternative approach. If the licensee plans to use characterization surveys and sampling for release from the license, the characterization surveys and sampling must meet the same rigors as final status surveys (FSS) if the licensee plans to use that data in FSS reports for license termination.
2 50.82(a)(9)(ii)(A) Section A.2 Site Section 4.2.3.1.3 LTP Section 2.4 (pdf pages 44-47) provided limited survey Survey results for the buildings and structures in survey areas:
(ii) The license Characterization results for four of the thirteen impacted survey areas. The CRRB, DISS, and INTS termination plan survey information provided did not have sufficient detail to must include Subsection on ascertain overall distribution of sample locations e.g. (surface, Survey results for the soils in survey areas: NORB, SORB, EORB, (A) A site Characterization depth, etc.) and radionuclide concentrations at those locations. WOCZ, SOCZ, DISC, INTC, EOCZ, R16Y, and CASA.
characterization Surveys: 1st, 2nd & 3rd bullets. Survey results of areas that are described as unimpacted to form the basis of that unimpacted determination. Site Land Areas that the licensee believes to be non-impacted by site operations must be approved by the NRC and provide sufficient surveys and sampling data to support the licensees assessment and subsequent early partial site release or as part of the LTP and meet LTP/FSS requirements for NRC approval. In addition, the licensee must provide the isolation and controls to be implemented to ensure the radiological status is not changed by decommissioning activities.
3 50.82(a)(9)(ii)(A) Section 2.2.1 "Acceptance Appendix F "Ground and LTP Section 2.6.2 (pdf page 49) Well monitoring data for a single Groundwater characterization sufficiently detailed and summarized in (ii) The license Criteria" 3rd bullet. Surface Water sampling event in 2020 that did not provide radiological sample the LTP to allow the NRC staff to determine the extent and range termination plan Characterization" results. (including any temporal variability) of any radiological contamination must include Section A.2 Site of ground water.
(A) A site Characterization characterization Subsection on Surface Water and Ground Water:
1st bullet.
4 50.82(a)(9)(ii)(A) Section 4.2.3.1.3, 7th & 8th LTP Section 2.8 (pdf page 50) Future commitment to perform Identification of areas of the site that will require further (ii) The license bullets further characterization of potentially impacted areas as necessary characterization, plans for future characterization, and how the results termination plan without out identification of those areas, why they were not will be evaluated relative to the LTP.
must include characterized, and plans for evaluating impacts from those areas (A) A site on the current evaluation in the LTP.
characterization Enclosure
Item No. Regulation (s) NUREG -1700 Rev 2 NUREG 1757 Vol. 2, Rev Information Provided Information Needed 2
5 50.82(a)(9)(ii)(A) Section 4.2.3.1.3, 9th bullet LTP Section 5.6.2.1 (pdf page 132). A commitment to provide a Site characterization should be updated to address isotopic mixtures (ii) The license white paper for NRC approval if surrogate ratios are to be used. in general areas as described or Section 5 of the LTP should state if termination plan each radionuclide (including HTD) will be measured independently must include LTP Section 5.2.1.3 (pdf page 93) Due to variability of for all FSSs.
(A) A site radionuclide concentrations does not expect to employ surrogate characterization ratios.
Various locations in LTP Chapter describe equations for applying surrogate ratios if needed.
Example of a Potential Issue:
Enclosure 7 (pdf page 591) - Discusses surface DCGL calculated based on gamma-spec analysis of swipe samples of the reactor building which showed Cs-137 and Co-60. It is not clear if HDT radionuclides were analyzed and accounted for in the determination of scan DCGLs.
6 50.82(a)(9)(ii)(A) Section A.4 Final LTP Table 2.2 and Section 2.4 provides qualitative discussion of A description and map or drawing of affected areas of the site, area, (ii) The license Radiation Survey Plan classification of general survey areas. or buildings classified by residual radioactivity levels (Class 1, Class termination plan 2, or Class 3) and divided into survey units with an explanation of must include Subsection on Final Status the basis for division into survey units.
(D) Detailed Survey Design: 2nd bullet.
plans for the final radiation survey 7 50.82(a)(9)(ii)(A) Section A.4 Final LTP Section 5 contains discussion of scanning methods and A description of scanning instruments, methods, calibration, (ii) The license Radiation Survey Plan instrumentation for FSS. operational checks, coverage, and sensitivity for each media and termination plan radionuclide.
must include Subsection on Final (D) Detailed plans Status Survey Design: 5th For in situ sample measurements made by field instruments, a for the final & 6th bullets. description of the instruments, calibration, operational checks, radiation survey sensitivity, and sampling methods with a demonstration that the instruments and methods have adequate sensitivity.
8 50.82(a)(9)(ii)(A) Section A.4 Final Section 5.3.4, Background Reference Area, mentions the use of Identify the specific background reference areas and materials used in (ii) The license Radiation Survey Plan a background reference area measurements for use with the support of statistical tests and give a justification for their selection.
termination plan WRS or background subtraction used with the Sign Test. It must include Subsection on Final provides a generalized discussion of characteristic of a suitable (D) Detailed plans Status Survey Design: 3rd for the final background reference area.
bullet.
radiation survey 2
Item No. Regulation (s) NUREG -1700 Rev 2 NUREG 1757 Vol. 2, Rev Information Provided Information Needed 2
9 50.82(a)(9)(ii)(A) Section A.5 Enclosure 5 (pdf page 405) Table 6-1 represents a list of Summary of how Site Characterization data was used to develop (ii) The license Compliance With radionuclides potentially present at CR3 based on applying the input for pathway analysis and dose or risk assessment models for termination plan Radiological Criteria for described screening criteria to the combined list of potential determining site-specific DCGLs.
must include License Termination radionuclides from regulatory guidance contained in NUREG/CR-(D) Detailed (Dose Modeling) 3474 and NUREG/CR-4289 and historical 10 CFR Part 61 Provide plans for further characterization of the survey areas and/or plans for the final analyses. units. The plans should identify survey areas or units that havent radiation survey Subsection Unrestricted been characterized and discuss how data gaps will be addressed.
Release Using Screening The radionuclides in Enclosure 5 were then used in and 10CFR20 Criteria: 1st bullet. RESRAD Onsite (Enclosure 8) RESRAD Build (Enclosure 9) to Site characterization data pertinent to conceptual site model Subpart E determine DCGLs. development when using site-specific parameters.
Section A.5 Compliance With Enclosure 7 (pdf page 591) - Discusses surface DCGL calculated Radiological Criteria for based on g-spec analysis of swipe samples of the reactor License Termination building which showed Cs-137 and Co-60. It is not clear if HDT (Dose Modeling) radionuclides were analyzed and accounted for in the determination of scan DCGLs Subsection on Unrestricted Release Criteria Using Site-Specific Information: 3rd and 5th bullets.
10 50.82(a)(9)(ii)(C), Section A.3 Identification Section 3.3, Future Decommissioning Activities provides a high Summarize remaining site dismantlement activities and remediation (ii) The license of Remaining Site level list of remaining major decommissioning activities with tasks planned for each room, area, and/or system, including a termination plan Dismantlement projected completion dates. projected order of completion that will remain at FSS.
must include - (C) Activities and Plans for site Remediation Plans.
remediation.
Subsection on Identification of Remaining Site Dismantlement Activities and Remediation Plans, 4th bullet.
11 50.82(a)(9)(ii)(A), A.2 Site Characterization Section 4.2.2. Enclosure 4, HSA, Section 6.3.3, Building and Structure and Provide a list or description of each room or area containing (ii) The license (Operating History) Characterization Surveys Section 6.3.4, Exterior Area, contains information on incidents contaminated structures, systems, or equipment within contaminated termination plan and subsequent clean-ups, and potentially contaminated media. structures, including a summary or map of locations of contamination must include - (A) Subsection on The enclosure itself does not identify specific areas of in each room or area. Specify the mode of contamination as whether A site Radiological contamination or whether the contamination is on the surface the contamination is on the surface or penetrating into the material.
characterization. Contamination Structures, only or integrated into the matrix.
Systems, and Equipment, The information provided should be sufficiently detailed to meet the 3rd, 4th, and 5th bullets. applicable Characterization survey objectives listed in NUREG 1757 Volume 2 Rev 2 page 4-8 and 4-9.
3