ML24032A037
| ML24032A037 | |
| Person / Time | |
|---|---|
| Issue date: | 02/01/2024 |
| From: | Bruce Watson Division of Decommissioning, Uranium Recovery and Waste Programs |
| To: | |
| Shared Package | |
| ML24032A030 | List: |
| References | |
| Download: ML24032A037 (11) | |
Text
License Termination The Five (5) Cs NEI - EPRI Decommissioning Conference February 1, 2024 Oceanside, California Bruce A. Watson, CHP Office of Nuclear Material Safety and Safeguards Division of Decommissioning, Uranium Recovery and Waste Programs
Consensus
- Multi-Agency Site Survey and Site Investigation Manual (NUREG 1575-MARSSIM) is
- The consensus technical approach to decommissioning surveys
- A reiterative process using a graded approach and statistics to replace NUREG 5849
- RESRAD is the internationally bench-marked code for decommissioning
- NRC does not have clearance standards and has a no detect policy for release of materials
- NRC allows for alternative disposal methods of bulk materials, use MARSAME
Consensus
- NRC will accept alternative approaches to NRC guidance with technical justification
- Recommendation: Follow the NRCs guidance, if not, add 2 years to your decommissioning schedule for the NRC to evaluate your technical justification for using alternative approaches
- Recommendation: Ensure complete submittals to the NRC
- Based on NEIMA Metrics set by Congress, if your submittals are not complete, the bar for accepting the submittal for detailed technical review is higher than in the past
Characterization
- Characterization Plan is the planning tool to estimate the amount of radwaste and costs:
- Defines the areas to be remediated and the extent of the area needing remediation
- If structures/foundations will remain, must include under-building sampling to ensure soils meet release criteria
- Recommendation: Consider Continuing Characterization as a confirmation of the radiological bases in the LTP and perform additional characterization conforming to the original DQOs for inaccessible areas
Characterization
- MARSSIM (NUREG 1575) is a reiterative process
- The Historical Site Assessment and the 10CFR75(g)
Files identify areas for the Scoping Survey for investigation and bases for areas for the Characterization Plan to address
- Characterization sampling and surveys follow the Data Quality Objective (DQ0) Process
- Characterization surveys can serve as the Final Status Surveys (FSS), if they meet the LTP FSS Plan Criteria and Isolation is maintained
- The Site Characterization Report is technical basis for the License Termination Plan, Dose Modeling and Final Status Survey Plan
Communications
- Recommendation: Pre-submittal LTP meetings should be scheduled with the NRC staff to review your technical approaches
- Plan for a technical staff site visit to review your LTP and review any plant specific issues
- If the LTP is accepted for detailed technical review, the NRC will hold a public meeting near the site to hear public comments
Cooperation NRC staff and inspectors will have periodic project review meetings with the licensee to discuss:
- Upcoming decommissioning activities
- Upcoming licensing submittals
- Recent corrective action reports
- Other issues important to safely decommissioning of the plant
- Plant specific issues (IP gas pipeline)
- Upcoming issues at Community Groups (CABs, DOBs and CEPs)
Cooperation
- Recommendation: Share lessons learned and operating experience between sites both within the company and others.
- Learn from the past and decrease repeat events
- Hold periodic meetings with similar positions, i.e.
Radiation Protection Managers
- Benchmark, including physically visiting other sites
- Continue with periodic decommissioning conferences and forums to share information
Coordination
- Upcoming site inspections
- NRC staff and other VIP site visits
- Upcoming large component radioactive waste shipments
- Coordination of confirmatory surveys with the staff, inspectors and NRCs contractor
- Recommendation: Provide schedules early and update often
- Other issues, State regulator issues, foreign visitors,.
Compliance
- Revisions to the Post Shutdown Decommissioning Activities Report
- NEI 22-01 is a good start.to strive for consistency, but plants differ with operational history, NSS vendors and vintages, and time in safe storage.
- The LTP is a license amendment, therefore compliance is required, but they can be changed
Summary of the 5 Cs Recommendations
- Follow the NRC guidance, the 1st 10 plants to be terminated were successful
- Comprehensive characterization will result in better planning and implementation
- Open communications between the licensee and regulator
- Use the operating experience and lessons learned
- LTPs can be amended and should take little time when there is agreement
- The 6th C is a strong Corrective Actions Program