ML23310A072

Audit Plan - Crystal River Unit 3 Nuclear Generating Plant LTP

ML23310A072
Person / Time
Site:	Crystal River
Issue date:	11/07/2023
From:	Jack Parrott Reactor Decommissioning Branch
To:	ADP CR3
Shared Package
ML23310A063	List: ML23310A071 ML23310A072
References
EPID L-2022-LLA-0194
Download: ML23310A072 (5)

Text

REGULATORY AUDIT PLAN

TO SUPPORT REVIEW OF LICENSE AMENDEMENT REQUEST TO ADD LICENSE CONDITION 2.C.21 THAT APPROVES THE LICENSE TERMINIATION PLAN (LTP) AND ADDS A LICENSE CONDITION THAT ESTABLISHES THE CRITERIA FOR DETERMINING WHEN CHANGES TO THE LTP REQUIRE PRIOR NRC APPROVAL

ACCELERATED DECOMMISSIONING PARTNERS (ADP)

Crystal River Unit 3 Nuclear Generating Plant

DOCKET NO. 50-302

I. BACKGROUND

By letter dated December 12, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22355A441), as supplemented by letter dated June 9, 2023 (ADAMS Accession No. ML23163A063), Accelerated Decommissioning Partners Crystal River Unit 3, LLC (ADP CR3) (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) to approve a request to add a condition to include License Termination Plan (LTP) requirements to the NRC license, No. DPR-72, for Crystal River Unit 3 Nuclear Generating Plant (CR3)

The proposed amendment would approve the LTP and add License Condition 2.C.21 that establishes the criteria for determining when changes to the LTP require NRC approval. The LTP will be implemented by the licensee to complete decommissioning activities at the CR3 site. Once decommissioning is complete, a separate request will be made to the NRC by the licensee to terminate the CR3 license.

II. REGULATORY AUDIT BASES

The basis for the audit is to determine if the licensees License Amendment Request (LAR) related to their LTP meets all the applicable regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) and addresses the applicable guidance provide in Regulatory Guide 1.179, Revision 2, Standard Format and Content of License Termination Plans For Nuclear Power Reactors, and NUREG-1700, Revision 2, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans (ADAMS Accession Nos: ML19128A067 and ML18116A124, respectively).

The audit will be performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ADAMS Accession No. ML19226A274). An audit was determined to be the most efficient approach toward a timely resolution of issues associated with the LAR review.

III. PURPOSE AND SCOPE

The purpose of the Audit is to gain a greater understanding, verify information, and/or identify information that will require docketing to support the basis for the NRCs staffs decision on the LAR.

The audit will consist of three parts:

Part 1 - In-Office Technical Review and Onsite Audit Prep During the In-Office Technical Review and Onsite Audit Prep, technical staff will review the LTP documentation provided on the online portal, and narrow down areas for focused discussion during the onsite audit. The NRC staff will have the opportunity to have discipline-specific discussions with the licensee to discuss the approaches used for evaluation and development of its LTP. In addition, the NRC staff may identify specific technical areas where they would benefit from a presentation or discussion to provide additional context to support their review. At the conclusion of the In-Office Technical Review and Onsite Audit Prep, the NRC staff will identify any areas requiring inclusion in the On-Site Audit, Part #2 of the LTP Audit.

Part 2 - Onsite Audit During the onsite audit the licensee should be prepared to support additional focused discussions and provide additional documents, calculations, and other material, as applicable, supporting the analysis and justifications in the LTP, to better facilitate understanding of the site and physical conditions to support license termination. In addition, to making documents available for review and discussion, the licensee should be prepared to support the NRC staff with a comprehensive tour of the facility.

Part 3 - In-Office Breakout Session Following the Onsite Audit, the In-Office Breakout Sessions provide the opportunity for the technical staff to ask questions and have detailed technical discussions to identify and obtain information to complete the safety review. In-Office Breakout Session topics and participants will be grouped by discipline, to the greatest and most efficient extent possible.

The scope of the three-part regulatory audit includes a discussion on the licensees LAR related to their LTP, with focus areas discussed below in Section IV, Information and Other Material Necessary for the regulatory Audit. During this audit the NRC staff intends to review the supporting methodology and supporting documents used in the development of the LTP.

IV. INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT

The NRC audit team will require access to the licensees personnel with detailed knowledge of the LAR, supporting methodology, and supporting documents used in the development of the LAR.

Focus Topics:

Site Characterization (SC)

Staff will have the opportunity to gain clarity on the planned and continued site characterization of the facility related to the following: The use of post-remediation verses pre-remediation data for classification of survey units and the approach to downgrading survey units. How apparently limited surveys for interior building structures, building basement structures remaining onsite, above ground concrete/asphalt used as backfill material, embedded piping, and subsurface soils for impacted areas are leveraged within the LTP. Understanding how site characterization data will be used to verify radionuclides of concern, radionuclide fractions, and insignificant contributors in various media. Licensees approach for determining how random and systematic measurements for land and surface areas are appropriate for demonstrating statistical significance and calculating statistical parameters to support final status survey (FSS) design given the limited number of samples and analyses in some survey units.

As Low As Reasonably Achievable (ALARA) Evaluation

Clarification is needed for the use of 2014 values rather than current values for the averted dose (VAD) and value of statistical life (VSL) in accordance with the guidance in NUREG-1530. In addition to other inputs to the general ALARA evaluation such as the discount rate, survey unit area, waste volume, and the choice of radionuclides assumed.

Final Radiological Survey Plan

The FSS is used to demonstrate compliance with regulations by providing data to show that all radiological parameters satisfy the established guideline values and conditions. Clarity is needed on the FSS approach and the Derived Concentration Guideline Level (DCGL) development and application for remaining structures, systems and components, surface and subsurface soils, and backfill materials. An understanding of inputs used to determine instrument sensitivities is needed, therefore, NRC staff is seeking to review demonstration of laboratory methods and instruments as well as advanced technologies that ensure adequate sensitivities are achieved to detect residual radioactivity at or below the DCGL. NRC staff also need further explanation on radionuclides of concern, insignificant contributors, hard-to-detect radionuclides, and survey investigation levels. Clarity is needed on the licensees approach of how surveys are used to evaluate the success of remediation and FSS readiness. Finally, further explanation is needed on double sampling and its impact on statistical assumptions.

Dose modeling and approach for compliance with radiological criteria for license termination

The NRC staff would like clarification of the general approach to demonstrating compliance with the radiological criteria for license termination. For example, in LTP Enclosure 10, Section 4.0, it was not clear to the NRC staff how the surface soil DCGLw accounted for potential doses from other contaminated media a resident farmer could be exposed to (e.g., subsurface soil, buried piping, buried structures, and site soil and concrete used as backfill) (see, e.g., NUREG-1757 Vol. 2 Rev. 2 Sections 2.7 and J.1.1). For the resident occupancy scenario, the staff would like clarification of the applicability (or conservatism) of the building occupancy scenario to basement substructures. The NRC staff also would like to understand the licensees consideration of alternative exposure scenarios (see, e.g., NUREG-1757 vol. 2, Appendix I Sections I.3.3, I.3.4, I.7.2; Appendix J Section J.1, Appendix M, and Appendix Q Section Q.5.2.4).

The second topic related to compliance demonstration is the implementation of the dose models. The NRC staff is interested in reviewing the RESRAD-ONSITE and RESRAD-BUILD reports for DCGL calculations and sensitivity analyses for each radionuclide of concern.

Reviewing the model inputs would help clarify questions the NRC staff has about parameter values used in the dose modeling. The NRC staff also would like to understand the bases for certain key parameters, such as the modeled depth of soil contamination and radionuclide sorption coefficients. In addition, NRC staff also would like to understand the process used to determine which physical parameters to represent with stochastic distributions and which distributions to correlate in sensitivity analyses.

Hydrology and Groundwater

Staff will review the data quality objectives for groundwater for the FSS plan including the inputs for groundwater contamination and approach for dose calculation, or clarification for not including groundwater residual radioactivity in the FSS. Review of the hydrological inputs for the soil DCGL are needed for applicability to both power-block and non-power block areas, the consequence of mixing of default RESRAD parameter values and sites-specific values, and understanding parameter values that affect wellbore dilution. Clarification is needed on the different vertical datums used for all the components supporting the conceptual site model, including geology, groundwater levels, and engineered components across the site.

Documents to be provided via online portal

1. RESRAD-ONSITE and RESRAD-BUILD reports

2. Technical Basis Document(s) or procedures related to pipe survey and data assessment methodology.

3. Pre & Post remediation surveys of EOCZ-04

4. Technical Support Document File No. 134300, cited in RESRAD input parameter tables

5. BHI Energy Engineering Calculation ENG-CR3-002, RESRAD-Build Input Parameter Sensitivity Analysis - Crystal River 3

6. A summary of site characterization data collected since the issuance of the LTP, including surface and subsurface soils, structures, buried and embedded piping, and backfill material.

7. Site characterization data used to select/deselect radionuclides of concern

8. Hard-to-detect radionuclide analysis results used to determine radionuclide mixtures for by media

9. Site characterization gamma scan survey summary, including maps of scanned areas for open land areas.

10.Procedures describing the survey of concrete and soil backfill material 11.Vendor laboratory analysis types, techniques, methods, and MDC by media

V. AUDIT TEAM

The following are members of the NRC audit team:

• Jack Parrott, Project Manager, (Jack.Parrott@nrc.go

• Tim Barvitskie, Backup Project

• Kathryn Robertson-DeMers, Health ysicist, (Kathryn.Robertson-D

• e, Sr. Risk Analyst, (Chriige@nrc.gov)

• Louis Caponi, Risk Analyst, (Louis.Caponi@nrc.gov)

• Randall Fedors, Hydrologist, (Randall.Fedors@nrc.gov)

• Shaun Anderson, Branch Chief, (Shaun.Anderson@nrc.gov)

VI. SPECIAL REQUESTS

The NRC staff would like access to the documents listed above in Section IV through an online portal that allows the NRC staff to access documents remotely via the internet at least 2 weeks prior to the start of the audit and through completion of the audit. NRC staff access to the online portal should be terminated upon issuance of the audit summary discussed in Section VIII of this audit plan.

The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff have access to the online portal:

• The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.

• The online portal will be sufficiently secure to prevent the NRC staff from printing, saving, downloading, or collecting any information on the online portal.

Username and password information should be provided directly to the NRC staff. The NRC project manager will provide to the licensee the names and contact information of the NRC staff who will be participating in the audit. All other communications should be coordinated with the NRC project manager.

VII. LOGISTICS

The LTP audit will be conducted in a hybrid format and will take place from approximately November 13, 2023, to January 19, 2024. The onsite audit will take place at the Crystal River site in Crystal River, FL and via Microsoft Teams or other similar platforms.

The audit period may be reduced or extended, dependent on the NRC staff and Crystal Rivers progress in addressing the Audit Questions. Additional audit activities may be planned as necessary to support the NRC staffs understanding of information needed to complete the review of the license amendment, and, if conducted, the additional audit activities will be documented in the audit report discussed in section VIII of this audit plan.

VIII. DELIVERABLES

An audit report will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee.