ML23324A433

10/16-17/2023 Summary of Routine NRC Site Visit at the Oyster Creek Nuclear Generating Station to Discuss License Termination Plans and Other Technical Topics

ML23324A433
Person / Time
Site:	Oyster Creek
Issue date:	01/23/2024
From:	Marlayna Vaaler Doell Reactor Decommissioning Branch
To:	Holtec Decommissioning International
References
Download: ML23324A433 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 20, 2023 MEMORANDUM TO: Holtec Decommissioning International, LLC (HDI)

THRU: Oyster Creek Nuclear Generating Station FROM: Marlayna V. Doell, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material, Safety and Safety Guards

SUMMARY

OF OCTOBER 16-17, 2023, ROUTINE NRC SITE VISIT AT THE OYSTER CREEK NUCLEAR GENERATING STATION TO DISCUSS LICENSE TERMINATION PLANS AND OTHER TECHNICAL TOPICS On October 16-17, 2023, U.S. Nuclear Regulatory Commission (NRC) staff from NRC Headquarters visited the Oyster Creek Nuclear Generating Station (OCNGS) in Forked River, New Jersey. The purpose of the site visit was for the NRC technical team assigned to review the OCNGS License Termination Plan (LTP) to:

1. Tour the site to gain a better understanding of the site layout and the relationships between facility structures, natural and engineered land features, and the surrounding waterways.

2. Obtain an understanding of the licensees status regarding site characterization progress and future plans as they relate to informing the development of the LTP.

3. Inquire about the planned schedule and potential complexities for LTP development and discuss any unique or site-specific aspects that may impact the OCNGS LTP information.

NRC Staff:

Marlayna Doell, Project Manager Kathryn Robertson-DeMers, Health Physicist Randall Fedors, Senior Hydrogeologist Cynthia Barr, Senior Performance Analyst CONTACT: Marlayna V. Doell, NMSS/DUWP 301-415-3178

HDI HDI and Contractors:

Jeff Dostal, OCNGS Site VP Steven Johnston, HDI Regulatory Assurance Manager Tom Williamson, HDI Fleet LTP Project Manager Chris Messier, BHI, VP of Radiological Engineering Marty Erickson, BHI Health Physics Ed O'Brien, HDI Environmental Health and Safety Kevin Wolf, HDI Manager of Radiation Protection and Chemistry Jean Fleming, HDI Vice President, Licensing, Regulatory Affairs & PSA Bill Noval, HDI Director, Regulatory Affairs Benjamin Reynolds, HDI Kevin Leonard, HDI Jack McCarthy, HDI Forthcoming Action:

HDI is planning to submit the OCNGS LTP in the first half of 2024 under the provisions of 10 CFR 50.82(a)(9). In accordance with the NRC regulations and associated guidance, the LTP will include: (1) a site characterization; (2) identification of remaining dismantlement activities; (3) plans for site remediation; (4) detailed plans for the final radiation survey; (5) a description of the end use of the site, if restricted; (6) an updated site-specific estimate of remaining decommissioning costs; (7) a supplement to the environmental report describing any new information or significant environmental change associated with the licensee's proposed termination activities; and (8) identification of parts, if any, of the facility or site that were released for use before approval of the license termination plan.

The NRC staffs review of the OCNGS LTP will ensure that the remaining decommissioning activities planned at the site are adequate to ensure the site will meet the radiological criteria for unrestricted use in 10 CFR 20.1402, Radiological criteria for unrestricted use. Upon receipt of the LTP, the NRC staff will make the license termination plan available for public comment and schedule a meeting in the vicinity of OCNGS to discuss the LTP and upcoming activities. If the OCNGS LTP demonstrates that the remainder of the decommissioning activities will be performed in accordance with the NRCs regulations, will not be inimical to the common defense and security or to the health and safety of the public, and will not have a significant effect on the quality of the environment, and after notice to interested persons, the NRC will approve the plan, by license amendment, subject to such conditions and limitations as the Commission deems appropriate and necessary to authorize implementation of the license termination plan.

Previous Pre-Application Activities:

From September 2022 - March 2024, the NRC staff engaged (or will engage) with the licensee on various aspects of HDIs plans and methods for preparing the site for license termination, including the discussion of several site-specific aspects that will inform the LTP development and documentation. Some of the topics covered during these interactions included the structure of the plan to conduct the final status survey, how site characterization information is being used to inform remediation plans, how the inputs to different dose scenarios are being evaluated and justified, and general discussions of the remaining financial assurance and environmental impacts of the dismantlement and decontamination activities that support license termination.

HDI These pre-application interactions included several teleconferences between members of the NRC and licensee staff to prepare for this site visit to OCNGS, as well as a previous site visit in September 2022, both of which assessed the ongoing decommissioning progress and the early activities supporting development of the LTP (see Agencywide Documents Access and Management System (ADAMS) Accession No. ML22290A057). Subjects covered during these preliminary teleconferences include the OCNGS Historical Site Assessment, hydrogeologic model, site characterization report, plans for site remediation, remaining dismantlement activities, the various dose scenarios being evaluated by the licensee, and several financial and environmental considerations for development of the LTP. The NRC staff also conducted a preliminary review of several White Papers and other documentation to provide feedback to the licensee on technical topics related to the overarching LTP content and structure, as well as HDIs proposed methods and approach for demonstrating compliance with the radiological criteria for unrestricted site release.

Items Reviewed by the NRC or Discussed with HDI:

Before the site visit the NRC technical team reviewed the OCNGS docket for technical reference material and documents of interest related to development of the LTP, including draft and pre-decisional materials provided by the licensee in support of the upcoming interactions on development of the LTP. These draft documents will be finalized and made publicly available as part of the LTP submittal (e.g., site characterization report and historical site assessment). The NRC provided a list of items that the NRC staff would like to see or discuss during the site visit; HDI obtained the information and made it available for the staff to review or discuss, as needed.

Additional topics covered during the OCNGS site visit include:

• The areas planned for continuing radiological characterization survey and sampling, as well as the associated analysis strategy to help establish derived concentration guideline levels (DCGLs) and establish the appropriate radionuclides of concern (ROCs) for the site.

• Any areas of significant known radiological burials, leaks, or spills at the site (e.g., more significant releases or remedial activities that occurred during operation).

• DCGL parameter selection criteria and assumptions, including deselection of ROCs that are characterized as insignificant contributors to dose and methods for determining radionuclide distribution, variability, and ratios.

• Dose scenarios and pathways assumed for the modeling efforts related to final site status.

• Site/model boundaries and air/groundwater monitoring locations.

• Plans for leaving buried piping and embedded piping or metal penetrations in place. The licensee stated that no buried piping will remain after remediation efforts are complete but that it will develop a DCGL for buried piping in case it is needed to reflect actual site status.

• Discussion of the plans for grouting of subgrade structures, including penetrations and buried piping as applicable.

• Plans for release or reuse of site materials, including rubblized concrete and backfill material from the dredging of the OCNGS intake and outfall canals.

• Methods for characterization of remaining subgrade structures, including extensive concrete characterization to support potential reuse of material as onsite fill or in offsite applications.

HDI

• Plans for packaging and shipping of wastes from decommissioning activities, including intent to recycle or free release as much of the facility materials as practical.

• Status of the activities related to licensing a transportation cask to move the consolidated low-level waste cassettes to a radiological disposal facility (i.e., Waste Control Specialists).

• Methods for ensuring that demolition activities do not create discrete radioactive particles.

• Methods for monitoring and controlling the release of effluents from the site.

• Schedule for LTP development and submittal, if available.

The agenda for the two-day NRC site visit is provided in the attachment. On the first day, a site safety briefing was conducted, and introductions were made. HDI and contractor staff provided an overview of the decommissioning and license termination project, including state and local interest in the dismantlement of OCNGS, the proposed end state for unrestricted release, and high-level conceptual plans for the remaining structure of the LTP.

On the morning of the first day, HDI provided an overview of ongoing decontamination and decommissioning activities, plans for building demolition and expected final configuration of remaining substructures, methods for waste and materials management, and radiological site characterization activities, including ongoing Phase 2 characterization activities and future continuous characterization activities. The day one discussions also focused on development of the list of ROCs, surveys of hard to detect radionuclides, the efficacy of development of surrogate ratios, support for de-listing of radionuclides as insignificant contributors, DCGL development, and determination of the need for establishment of background or reference radiation areas. In the afternoon, the participants discussed the plans for constructing the final status survey, establishing suitable minimum detectable concentrations, and selecting appropriate dose pathways and exposure scenarios.

On the second day additional presentations and discussions took place between HDI and NRC staff on groundwater monitoring, site history and hydrology, future plans for recycling, release, or reuse of concrete and other solid materials to facilitate decommissioning activities, maintaining doses as low as is reasonably achievable (ALARA), and dose modeling methodology. HDI and NRC staff further discussed support for the determination of reasonably foreseeable future land use scenarios to demonstrate compliance, including elimination of exposure pathways (e.g., groundwater pathway due to classification exception area restrictions), as well as analyses related less likely but plausible exposure scenarios.

HDI conducted a site tour of OCNGS, including walkdowns of various elevation levels in the turbine and reactor building, the old radioactive waste building, the intake and discharge canal, areas of likely subsurface contamination for future continuing characterization efforts (e.g.,

condensate storage tank area and areas associated with a known leak outside of the old radioactive waste building), waste storage and staging areas, the area of a previous 10 CFR 20.2002 onsite disposal, and other areas of the site. This tour helped provide the NRC staff with a better understanding of the expected final configuration of the site following decontamination and demolition activities to support license termination to unrestricted release standards.

During the 2-day visit, the NRCs recently issued interim staff guidance (ISG) on subsurface surveys and dose modeling was discussed, including alternative methods for survey and sampling of hard to access locations, small excavations, substructures, and backfill materials. A discussion on methods to support risk-significant parameters, such as distribution coefficients, is also included in the ISG, as well as method to assess the risk from existing groundwater

HDI contamination, if present. For additional details, see the ISG at the following link:

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML23177A008.

Action items were also discussed to end the second day, and include the potential for HDI to request formal NRC review of the following items before formal submittal of the OCNGS LTP:

• Potential white paper on reuse of materials during decommissioning, including concrete.

• ROC technical basis document for alignment to support the deselection of insignificant contributors to dose before LTP development.

• Development of a DCGL technical basis document (e.g., soils, buildings, and subsurface).

Additional interactions between HDI and NRC staff are planned between now and the proposed submittal of the OCNGS LTP in 2024 to address the action items and ongoing discussion topics related to the licensees plan to decontaminate the site for unrestricted release. Future interactions may include additional teleconferences or site visits in advance of a formal LTP pre-submittal public meeting and will be coordinated and documented as needed. The LTP pre-submittal public meeting will summarize the results of these pre-submittal interactions, explain the feedback given by the NRC staff to HDI, and provide the public with an opportunity to provide comments and ask questions about the formal LTP review process.

Please contact me with any inquiries at 301-415-3178 or via e-mail at marlayna.doell@nrc.gov.

Sincerely, Signed by Doell, Marlayna on 12/20/23 Marlayna V. Doell, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-219 Renewed License No. DPR-16

Enclosure:

1. Agenda

NRC Visit Agenda Oyster Creek Nuclear Generating Station License Termination Plan Sunday, October 15th

• NRC Travel Day Monday, October 16th

• Site Overview Presentation - J. Dostal 0830 to 0930

• Discussion 0930 to 1130 o Overview of Site Characterization o Radionuclides of Concern o Hard To Detects, Insignificant Dose Contribution, and Surrogate Ratios o DCGL Development, Including the Subsurface o Background Radiation and Reference Area Determination o Concrete Characterization Efforts

• Lunch 1130 to 1300

• Discussion 1300 to 1630 o Overview of Final Status Survey Plans o ALARA Discussion o Dose Pathway Selection Parameters o Dose Modeling Assumptions Tuesday, October 17th

• Discussion 0830 to 1030 o LTP Chapter Draft Walkthrough and Remaining Schedule o Review of Applicable NRC Guidance

• Site Tour - T. Williamson 1030 to 1300

• Ad Hoc Discussions 1300 to 1400

• Adjournment 1400 Wednesday, October 18th

• As Necessary/NRC Travel Enclosure

Memo ML23324A433 NMSS/DUWP OFFICE NMSS/DUWP/RDB NMSS/DUWP/RDB NMSS/DUWP/RDB

/RTAB NAME MDoell MD RFedors RF CBarr CB SAnderson SA DATE Nov 26, 2023 Nov 28, 2023 Nov 29, 2023 Dec 20, 2023 OFFICE NMSS/DUWP/RDB NAME MDoell MD DATE Dec 20, 2023