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