ML23353A244

Comment (2) of Bruce Montgomery on Interim Staff Guidance on Subsurface Investigations, Radiological Survey and Dose Modeling of the Subsurface to Support License Termination

ML23353A244
Person / Time
Site:	Nuclear Energy Institute
Issue date:	12/13/2023
From:	Montgomery B Nuclear Energy Institute
To:	Office of Administration
References
NRC-2023-0145, 88FR72112 00002
Download: ML23353A244 (1)

Text

12/19/23, 12:48 PM blob:https://www.fdms.gov/b2360af7-5279-48cc-b733-d4bc9d539e7b SUNSI Review Complete As of: 12/19/23, 12:47 PM Template=ADM-013 E-RIDS=ADM-03 Received: December 18, 2023 PUBLIC SUBMISSIONADD: Cynthia Barr, Status: Pending_Post Sarah Achten, Mary Tracking No. lqb-e8qe-r4qc Neely Comments Due: December 18, 2023 Comment (2) Submission Type: API Publication Date:10/19/2023 Docket: NRC-2023-0145 Citation: 88 FR 72112 Interim Staff Guidance on Subsurface Investigations, Radiological Survey and Dose Modeling of the Subsurface to Support License Termination

Comment On: NRC-2023-0145-0001 Draft Interim Staff Guidance: Radiological Survey and Dose Modeling of the Subsurface to Support License Termination

Document: NRC-2023-0145-DRAFT-0003 Comment on FR Doc # 2023-23114

Submitter Information

Email: jtwheat@energysolutions.com Organization: EnergySolutions

General Comment

See attached file(s)

Attachments

ES-2023-005 EnergySolutions Comments on NRC-2023-0145

blob:https://www.fdms.gov/b2360af7-5279-48cc-b733-d4bc9d539e7b 1/1 Bruce Montgomery Phone: 202.406.00 54 Director, Decommissioning and Email: bsm @nei.org Used Fuel

December 13, 2023

Ms. Cy nthia S. Barr Project Manager and Senior Risk Analyst U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

NEI Comments on Draft DUWP-ISG -02, Radiological Survey a nd Dose Modeling of the Subsurface to Support License Termination

Project Number: 689

Dear Ms. Barr:

On behalf of the nuclear industry, NEI0F1 is pleased to offer comments on NRCs draft interim staff guidance on subsurface radiological investigations, DUWP ISG-02, dated October 2023. We believe that this docum ent wil be helpful in the design and conduct of subsurface radiological surveys performed in support of license termina tion. Our comments are provided in the attachment to this letter.

If you have any questions, please do not hesitate to contact me at bsm@nei.org.

Sincerely,

Bruce Montgomery Director, Decommissioning and Used Fuel

Attachment

CC: Jane Marshall, NMSS, DUWP Marc Ferdas, NMSS, DUWP

1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs member s include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

NEI Comments on Draft DUWP-ISG-02, RADIOLOGICAL SURVEY AND DOSE MODELING OF THE SUBSURFACE TO SUPPORT LICENSE TERMINATION

1. Section/page Comment 1 2.2, page 2-6 The draft ISG includes the statement:

For this guidance, all open excavations and process -related substructures are presumed to be impacted

NEI suggests that additional clari"cation is warranted here. F or open land areas and other structures impacted from plant related airborne releases, only the surface would be considered an impacted Class 3 area.

Subgrade surfaces should be considered non-impacted unless shown to be impacted in the HSA. Further, even Class 2 and Class 3 excavations with no history of spills could likewise be considered either non-impacted or a lower classi"cation than the surface.

2 2.6.1, page The draft ISG includes the statement:

2-34 Off-site borrow sources are likely categorized as non-impacted, so would not fall under any class-speci"c guideline. The licensee is, therefore, required to determine if a MARSSIM/

MARSAME-like approach is appropriate or some other process is necessary to establish off-site borrow MAC. These MAC are necessary to verify the borrow site has not been unacceptably impacted by site operations or by operations from other unaffiliated sites that could also deposit radiological materials (e.g., naturally occurring radioactive materials from a coal-"red plant).

NEI is strongly opposed to this provision. NEI believes that i n the case of borrow sources from sites with no past radiological work history, all dose from NORM or Cs-137 should be considered background radiation and not subject to NRC or licensee control. This would impose an unjusti"ed burden, and licensees should not be required to sample and account for background radiological material from these borrow sources.

3 3.3, pages 3-Although the Subsection 3.3 discussion relating to risk signi"cant 14 through 3-subsuMce pMrMmeters notes thMlMborMtor expemeMl suppo to 26 dOve sOte-speci"c distribution coefficient values is not always necessary, the guidance on sensitivity of K d to geochemical parameters, soil type and groundwater chemistry appears to default to the need for extensive site-speci"c analytical data in order to defend selection of input parameters. The use of subjective quali"ers such as sparse or of low quality i n r eference to determination of acceptable reference data is not helpful. The description of physical parameters at individual sites that have the potential to affect nuclide -speci"c distribution coefficients appears to be almost in"nitely variable and even includes the consideration of seasonal variations. If it is the intent of the NRC to default to site speci"c analyses in order to remove all uncertainty from the selection of Kd
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NEI Comments on Draft DUWP-ISG-02, RADIOLOGICAL SURVEY AND DOSE MODELING OF THE SUBSURFACE TO SUPPORT LICENSE TERMINATION

that it is not practical for licensees to defend Kd values (and possibly other risk-signi"cant parameters) without site -speci"c analytical data.

4 Section 4 The draft ISG contains guidance on the various methods that can be used to calculate the dose from contamination in groundwater and the groundwater monitoring approaches that can be used to include the dose impact of groundwater contamination in showing compliance w ith the site release criteria. NEI agrees with the multiple references in the document that a graded approach can be used to determine what portions of the ISG guidance are applicable for a particular site.

5 4.2, page 4-2 There are several statements in the draft ISG that the maximum radionuclide concentration in a groundwater contamination plume should be used in calculating the dose from groundwater contamination.

NEI believes this would be an overly conser vative approach at so me sites as the postulated future drinking water well on the site w ould d ra w groundwater from a large capture zone area and that this capture zone may include multiple monitoring wells for a site that has an extensive monitoring well network which ha s gathered a great deal of radionuclide concentration and hydrogeologic data. An approach to average the radionuclide concentrations for the wells within this capture zone radius of each individual survey unit has been approved by the NRC in the past and should be added to the ISG as an acceptable approach for compliance groundwater monitoring. In line with the graded approach discussed in Comment 4 above, the approach of using the maximum concentration site-wide should be retained as it may be appropriate for a site with little or no groundwater contamination and/or a limited monitoring well network.

6 4.2.1, page The draft ISG contains the statement Considering seasonal or other 4-5 short-term variations in results, maximum residual radioactivity over a multi-year period should be used as input for dose calculation for existing contamination of groundwater contamination.

It is likely that natural attenuation will reduce the concentrations of radionuclides in groundwater, even in cases where remediation has been required. The ISG should state that if the licensee has seasonal monitoring well data that shows that radionuclid e concentrations have been trending downward over multiple years, the licensee should be able to use concentrations that are measured closer to the time of site release in calculating the dose due to groundwater rather than maximum values that occur earlier in the decommissioning.