ML23118A237

NRC Watson Learned Meeting Slides May 2, 2023

ML23118A237
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Issue date:	05/02/2023
From:	Tanya Hood, Bruce Watson Reactor Decommissioning Branch
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Download: ML23118A237 (16)

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NRC Perspectives on Decommissioning Lessons Learned Decommissioning Lessons Learned Public Meeting Workshop May 2, 2023 Bruce A. Watson, CHP Division of Decommissioning, Uranium Recovery and Waste Programs

History Some History

• Lessons Learned from the first 3 power reactors were used to inform the 1997 Decommissioning Regulations, License Termination Rule.

• Utility/operating companies managed the first generation of decommissioning projects and were willing to share lessons learned.

• During the late 1990s and into the 2000s, industry and NRC cooperated to publish decommissioning lessons learned.

• EPRI supported numerous technical documents, including a preparing for decommissioning document with 52 attachments.

• NRC published lessons learned on the NRC website based on operating experience at both complex material and reactor sites.

• NRC incorporated technical lessons learned items into NUREG 1757 Volume 2 and other guidance documents.

• NRC and federal partners initiated the Inter-Agency Working Group to revise Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM NUREG 1575).

What Has Changed

• In 2010, the first power reactor license transfer to decommissioning company was submitted to a non-utility entity/decommissioning company. Since 2010, the NRC has approved the transfer of 11 licenses to companies, while financially and technically qualified to be a licensee, had limited experience as an NRC licensee.

• While completing the decommissioning to license termination fulfills the nuclear promise to release the land for unrestricted use and future economic development, the competitive nature of the decommissioning companies has not generally benefited the industry in sharing lessons learned.

• In 2019, at the NRCs Annual Regulatory Information Conference, NRC dedicated the Decommissioning Session to Lessons Learned to encourage the industry to share lessons learned. NRC has continued to encourage and support lessons learned at number of industry forums, workshops and conferences.

Successful Decommissioning Project Observations Senior Corporate and Project Management:

• Safety Culture

• Compliance Culture

• Ensures Quality

• Effectively uses lessons learned

• Manages consultants, and contractors

• Communicates with the local community, State, regulators and elected officials

Successful Decommissioning Project Observations As in operating plants, decommissioning projects are expected to maintain the same high level of safety and security.

• Licensees have strong Decommissioning Operational Health Physics, Quality Assurance, Fire Protection and Industrial Safety Programs that are continued into the Final Status Survey Program and until the license is terminated.

• Understand that operational decommissioning activities (dismantling/waste/transportation and adverse events) may affect the overall decommissioning effort and takes corrective actions to mitigate the issues.

Successful Decommissioning Projects Observations

• Licensees have strong licensing programs

- Communicates early and often with NRC before planned submittals

- Holds pre-submittal meetings with NRC

- Participates in routine project communication meetings with the NRC Project Manager and Inspectors.

- Ensures submittals are accurate and of high quality

- Along with the Quality Organization, effectively uses the Corrective Action Program.

Successful Decommissioning Project Observations

• Licensees have strong licensing programs:

- Along with the Quality Organization, monitors work activities to ensure compliance with the License Termination Plan and those activities which may adversely affect the license termination being achieved.

- Ensures the 10 CFR 50.75(g) files are maintained during decommissioning to ensure compliance until license termination.

- Ensures that if License Termination Plan needs to be revised, ensures that NRC is informed of the proposed changes and schedule for submittal.

License Termination Lessons Learned

• The License Termination Plan (LTP) or Decommissioning Plan (DP) ( the Plan) replaces the Safety Analysis Report and is incorporated into the license by amendment. Compliance is required.

• Employs the Data Quality Objectives process to evaluate survey and sampling information.

• New or differing radiological information discovered during decommissioning activities is to be evaluated by the licensee and requests for LTP amendment are to be submitted for NRC approval.

License Termination Lessons Learned NRC, DOE, EPA, and DOD (with industry input) have collaborated to develop decommissioning guidance, such as MARSSIM, MARSAME and MARLAP (NUREG-1575) to establish acceptable, standardized, and efficient methods for surveys, procedures, and protocols. These processes are significantly more effective and efficient than previous survey and sampling protocols (NUREG-5849).

License Termination Lessons Learned NRC has collaborated with other government agencies and National Laboratories to support tools such as RESRAD, D&D Code, Visual Sample Plan and other complex computer codes to provide standardized methods for licensees and NRC to evaluate complex decommissioning technical issues, including dose modeling, development of DCGLs, and sample analysis.

License Termination Lessons Learned

• NRC will consider alternative technical approaches to the NRC guidance, but licensees must provide sufficient technical justification for their proposed alternative methods.

• Licensees proposing new technical approaches, the alternative approach technical justification must be provided that may include calculations, computer simulations and testing to ensure the new approach will adequately meet regulatory safety and compliance requirements.

• The alternative approach should be communicated to the NRC staff through pre-submittal meetings and the licensees schedule should allow the NRC adequate evaluation time to perform an independent evaluation.

License Termination Lessons Learned Licensees have complicated the LTPs which results in more time for the staff to review and Requests for Additional Information (RAIs):

• Overly complicated dose modeling

• Over classification of survey units

• Not delisting of radionuclides

• Complex survey procedures and nomenclatures

• Delegate regulatory decisions to the licensee.

• Incomplete Characterization Data to establish LTP DCGLs and FSSRs

License Termination Lessons Learned Licensees have complicated the Final Status Survey Records review process by:

• Poor quality or contradictory information in Final Status Survey Reports

• Excessive information in Final Status Survey Reports, such as Vendor Lab reports

• Failure to investigate sample result anomalies from vendor labs

Recommendations

• If the licensee has an issue, and the NRC staff provides industry operating experience on how other licensees have solved the issue, please consider it.

• Perform Final Status Surveys when it is time and not too early when physical work may affect the survey unit and results.

• Licensees should perform Final Status Surveys when they have reasonably high assurance the survey unit will pass. This includes sample analysis evaluation and compliance with the LTP requirements. Failing a Confirmatory survey is not good.

• Isolation and Control - Licensees should ensure controls are adequate to prevent intrusions into the areas having been Final Status Survey to ensure the area does not become recontaminated such that the areas need to be resurveyed.

Conclusions Communications - early and often

• Holds Pre-submittal meetings

• At Routine Project Meetings with NRC:

- Review of planned activities meetings

- Review of CARs of interest to the inspectors and project team

• Uses industry experience and ensures new technology provides effective results

• Effective licensing, quality and safety programs will lead to success