ML24220A200
| ML24220A200 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center |
| Issue date: | 08/07/2024 |
| From: | Reid B NorthStar Vallecitos |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| References | |
| NSV 24-007 | |
| Download: ML24220A200 (1) | |
Text
NorthStar Vallecitos, LLC 6705 Vallecitos Rd.
Sunol, Ca 94586 ww w.northstar.com
Billy E. Reid Vice President, NorthStar Vallecitos
NSV 24-007
August 7, 2024
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
SUBJECT:
Update to License Termination Plan for Vallecitos Boiling Water Reactor -
Environmental Report Vallecitos Nuclear Center Docket No. 50-18 License No. DPR-1
REFERENCES:
- 1. Letter, USNRC to GEHA Regulatory Affairs., Order Approving Transfer of the Vallecitos Nuclear Center Licenses and Conforming License Amendment (EPID L-2023-LLO-0002), dated April 25, 2024 (ML24039A 019).
- 2. Letter, GEH to USNRC, License Termination Plan for the Vallecitos Boiling Water Reactor License DPR-1, dated September 7, 2023 (ML23250A267)
- 3. Letter, GEH to USNRC, License Termination Plan for the Vallecitos Boiling Water Reactor license DPR-1 (Public), dated September 15, 2023 (ML23261A591)
- 4. Email, GEH to USNRC, GEH Vallecitos Nuclear Center, E-mail: Response to acceptance Review of the VBWR License Termination Plan, dated October 31, 2023 (ML23304A300)
- 5. Letter, GEH to USNRC, GEH/NorthStar Response to NRC Request for Additional Information Regarding License Termination Plan VBWR, dated March 25, 20 24 (ML24085A 792)
Dear Sir or Madam:
NorthStar Vallecitos LLC, (the decommissioning contractor and applicant for direct license transfer for the Vallecitos Nuclear Center, Reference 1), on behalf of GEH, hereby submits an update to the Vallecitos Boiling Water Reactor L icense Termination Plan.
On September 7, 2023 (Reference 2), as supplemented by letters dated September 15, 2023 (Reference 3), e-mail dated October 31, 2023 (Reference 4), and March 25, 2024 (Reference 5),
General Electric (GE) Hitachi Nuclear Energy (GEH, the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC) a License Termination Plan (LTP) for the Vallecitos Boiling Water Reactor (VBWR).
NSV 24-007 / Page 2 of 2
The VBWR LTP, S ection 8 included a reference to a VBWR Environmental Report submitted as an enclosure to Reference 3. Based upon the completion of the removal of the VBWR reactor vessel, as document in Reference 4, an update to the Environmental Report was warranted. In addition, it has been identified that the Environmental Report contained actions which will eventually be performed as part of the license termination of the entire site, but that the actions listed are not necessary as part of the license termination of the VBWR license. Accordingly, the Attachment identifies the corrections to various portions of the Environmental Report.
As a final item, the response provided in Reference 5 to Environmental RAI 1 is enhanced by this submittal.
This letter contains no new regulatory commitments.
Should you have any questions concerning this letter, or require additional information, please contact Mr. Thomas B. Silko at (802) 451-5354, Ext 2506.
I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
Sincerely,
8/7/24 SignatureSignature Executed On (Date)
Billy E. Reid, Vice President, NorthStar Vallecitos
Attachment:
Update to VBWR LTP - Environmental Report.
cc: Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555
Regional Administrator, Region 4 U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, Texas 76011-4511 NSV 24-007 Docket No. 50- 18
Attachment
Vallecitos Boiling Water Reactor
Update to VBWR LTP - Environmental Report (6 pages excluding this cover sheet)
NSV 24-007 / Attachment / Page 1 of 6
Update to VBWR LTP - Environmental Report
Introduction On September 7, 2023 (Reference 2), as supplemented by letters dated September 15, 2023 (Reference 3), e-mail dated October 31, 2023 (Reference 4), and March 25, 2024 (Reference 5),
General Electric (GE) Hitachi Nuclear Energy (GEH, the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC) a License Termination Plan (LTP) for the Vallecitos Boiling Water Reactor (VBWR).
The VBWR LTP, Section 8 included a reference to a VBWR Environmental Report submitted as an enclosure to Reference 3. Based upon the completion of the removal of the VBWR reactor vessel, as document in Reference 4, an update to the Environmental Report was warranted. In addition, it has been identified that the Environmental Report contained actions which will eventually be performed as part of the license termination of the entire site, but that the actions listed were not necessary as part of the license termination of the VBWR license. Accordingly, this Attachment identifies the corrections to various portions of the Environmental Report.
Environmental Report (ER) Section 1.1 and 1.3 Introduction, states, It is the intent of GEH (the current licensee) to decommission the Vallecitos Boiling Water Reactor (VBWR) at the VNC and terminate its Nuclear Regulatory Commission (NRC) license Developmental Power Reactor (DPR) - 1. Later in that same section, the ER states that For the VBWR license termination, the residual radioactive materials will remain under the Empire State Atomic Development Associates Incorporate Vallecitos Experimental Superheat Reactor license until it is terminated. In Section 1.3, Purpose, the ER states The purpose of this ER is to present a current evaluation of the actual or potential environmental impacts resulting from the preparation, removal, and disposal of the VBWR vessel. The vessel removal is the remaining component that is inseparable from the DPR-1 license.
Update to ER Section 1.3:
As documented in Reference 4, the VBWR reactor vessel has been safely removed and disposed. As such, there is no remaining demolition work planned to be performed in support of the VBWR license termination.
ER Section 3 Introduction The introduction of Section 3 states The proposed work consists of dismantling all systems and components inside the containment structure and removal of the boiling water reactor vessel..
Update to ER Section 3:
The work that supports the termination of the VBWR License was the removal of the reactor vessel and this work has already successfully been performed. There is no additional dismantling of systems and components to be performed inside the containment structure under the proposed VBWR LTP.
ER Section 3.1 Preparation for removal of boiling water reactor vessel Section 3.1 states Piping and structural steel will be rigged, sectioned, and lowered. Demolition will be via cutting torches, bandsaws, or reciprocating saws depending upon the pipe diameter and NSV 24-007 / Attachment / Page 2 of 6
material. Cut lines and rigging points will be determined in the field by the rigger(s). Lead paint will be removed from cut lines where practical. Concrete bioshield segmentation via core bores and diamond wire cutting will be employed to access and cut the VBWR Vessel bottom support to allow vessel removal.
Update to ER Section 3.1:
The demolition of p iping and structural steel, the removal of lead paint and concrete segmentation necessary to remove the reactor vessel has already successfully been completed. There is no additional dismantling of systems and components, lead paint to be removed or concrete segmentation to be performed under the proposed VBWR LTP.
ER Section 3.3.1 Radioactive Waste Management Section 3.3.1 states The primary objective is to remove the reactor vessel, which contains the majority of the remaining radioactive material; and remediate the bio shield, as necessary for meeting ALARA. Based on current known radiological conditions of the external ventilation system, spent fuel pool and the external sump, no additional remediation is thought needed from an ALARA standpoint. Soil remediation is not anticipated as there is no soil associated with the VBWR license.
Update to ER Section 3.3.1:
Any remediation of the bio shield, external ventilation system, spent fuel pool or internal/external sump necessary to remove the reactor vessel has already successfully been completed. There is no additional remediation necessary under the proposed VBWR LTP.
There is no soil remediation necessary under the proposed VBWR LTP.
ER Section 3.3.2 Non-Radioactive Waste Management: Lead and Asbestos:
Section 3.3.2 discusses the possible need to remediate lead in the form of bricks or lead coatings as well as the possible need to perform a sbestos abatement in support of removal of the VBWR reactor vessel.
Update to ER Section 3.3.2:
Any such remediation or abatement necessary to support the removal of the reactor vessel has already successfully been performed. No additional lead or asbestos work is required in support of the VBWR LTP.
ER Section 3.4 Demobilization Section 3.4 states Demobilization will include remediation of the sump, decontaminating and removing, if feasible, all project equipment and materials brought on site, disposal of project-generated waste such as concrete from expansion joint areas, reactor pit, etc., and returning the work area to a clean, safe condition.
Update to ER Section 3.4:
Demobilization from the removal of the VBWR reactor vessel has been finalized. As such, there is no further remediation or decontamination of plant material remaining as part of the license termination of the VBWR.
NSV 24-007 / Attachment / Page 3 of 6
ER Section 4. 2.1 Section 4.2.1 discusses water usage during c onstruction and documents that the majority or the impacts for dismantling of the VWBR will be on paved and previously disturbed areas of the facility.
Update to ER Section 4.2.1:
First, clarification is that the termination of the VBWR l icense does not involve any construction, only demolition - there will a discussion on this topic near the end of this attachment.The second clarification to this section is that the water usage will be significantly less than when the facility was operational. Lastly the dismantlement (removal) of the VBWR reactor vessel was entirely on paved or previously disturbed areas of the facility
ER Section 4.4.6 Section 4.4.6 states: Asbestos containing materials have been abated in the VBWR containment and all generated material has been disposed of. Should asbestos be identified during the procedure to prepare for the vessel removal, it will be removed and packaged for disposal prior to any decommissioning activities in areas where these materials exist. Removal and disposal of asbestos will be accomplished by a licensed asbestos abatement contractor. Additional asbestos materials discovered during decontamination activities will be abated by the asbestos contractor as needed.
Update to ER Section 4.4.6:
All asbestos containing material associated with the removal of the reactor vessel has been abated. There is no additional demolition of the VBWR associated with the proposed LTP and as such, there is no additional asbestos to be removed as part of the VBWR LTP process.
ER Section 5. Summary of Environmental Effects Section 5 of the Environmental Report summarized the significance level for each of the respective resource areas. Based upon the removal of the VBWR reactor vessel being satisfactory completed and with no additional demolition to be conducted as part of the VBWR LTP process, a revision to Section is provided.
Update to ER Section 5 (5.1 through 5.16):
5.1 LAND USE SMALL: The activities to remove and dispose of the boiling water reactor vessel did not alter the land use of the existing site nor did it alter land outside of VNC. As no additional demolition activities are required as part of the VBWR LTP process, there will no impact to existing roads, highways and rail or the existing approved LLRW disposal site.
Mitigation: None required.
5.2 WATER USE SMALL: Water use during removal of the VBWR reactor vessel was significantly less than that utilized during station operations and was for a short duration. Supply was from the stations NSV 24-007 / Attachment / Page 4 of 6
existing source. As no additional demolition activities are required as part of the VBWR LTP process, there will be no possible impact to future water usage.
Mitigation: None required.
5.3 WATER QUALITY SMALL: Activities to remove the VBWR reactor vessel utilized paved or graveled areas and did not require ground disturbing activities which could impact water quality. As no additional demolition activities are required as part of the VBWR LTP process, there will no impact to water quality. In addition, the facilitys existing system and plans will continue to avoid inadvertent discharge in the event of a rainstorm.
Mitigation: None required.
5.4 AIR QUALITY SMALL: Activities to facilitate the removal of the VBWR reactor vessel (cutting, grinding) have been completed and were conducted primarily inside an existing building. Equipment utilized to remove the vessel utilized paved and graveled areas and as such did not generat e fugitive dust.
The mix of vehicles for work and transportation is significantly less than during plant construction. As no additional demolition activities are required as part of the VBWR LTP process, there will be no future impact to air quality.
Mitigation: None required.
5.5 AQUATIC ECOLOGY SMALL: The removal of the VBWR reactor vessel was completed with no impacts to aquatic habitats. As no additional demolition activities are required as part of the VBWR LTP process there is no potential to impact aquatic habitats via stormwater runoff from existing structures.
Mitigation: None required.
5.6 TERRESTRIAL ECOLOGY SMALL: There were no direct or indirect impacts on native plants from the removal of the VBWR reactor vessel as all work and equipment was confined to previously disturbed areas. As no additional demolition activities are required as part of the VBWR LTP process there is no potential to disturb nesting birds or the existing terrestrial ecology.
Mitigation: None required.
5.7 THREATENED AND ENDANGERED SPECIES SMALL: The risk of impacting threatened or endangered species as a result of terminating the VBWR license is none since there are no future demolition activities required.
Mitigation: None required.
5.8 RADIOLOGICAL SMALL: VNC utilized an established process to evaluate and perform non-routine activities (e.g., removal of VBWR reactor vessel) and all activities were performed under the VNC
NSV 24-007 / Attachment / Page 5 of 6
Radiation Protection Program. All nuclear fuel has been removed prior to decommissioning.
Mitigation: None required.
5.9 OCCUPATIONAL SMALL: Training and strict adherence to VNCs Health and Safety Program continues to protect workers from physical, chemical, ergonomic, and biological hazards.
Mitigation: None required.
5.10 SOCIOECONOMICS SMALL: The removal of the VBWR reactor vessel utilized a small workforce up to 30 for 3 to 4 weeks and as such it did not increase demand for community services or impact VNCs tax liability. As no additional demolition activities are required as part of the VBWR LTP process there is no potential impact on socioeconomics.
Mitigation: None required.
5.11 ENVIRONMENTAL JUSTICE SMALL: Locations of identified low-income populations are not near the VNC operational area; the closest low-income block group is located 3.9 miles north of VNC. As no additional demolition activities are required as part of the VBWR LTP process, there will be no future impact to environmental justice.
Mitigation: None required.
5.12 CULTURAL AND HISTORIC RESOURCES SMALL: The completed work did not require ground disturbance. As no additional demolition activities are required as part of the VBWR LTP process there is no potential to affect cultural or historic resources.
Mitigation: None required.
5.13 AESTHETICS SMALL: The work area is distant from sensitive receptors. The boiling water reactor vessel was inside an existing building and not visible; its removal did not have any aesthetic impacts.
As no additional demolition activities are required as part of the VBWR LTP process there is no potential for aesthetic impacts.
Mitigation: None required.
5.14 NOISE SMALL: As no additional demolition activities are required as part of the VBWR LTP process there is no potential to generate noise.
Mitigation: None required.
NSV 24-007 / Attachment / Page 6 of 6
5.15 TRANSPORTATION SMALL: As there are no demolition activities required as part of the VBWR LTP process there is no potential to impact the overall volume of traffic or compromise the safety of the public.
Mitigation: None required.
5.16 IRRETRIEVABLE RESOURCES SMALL: As no additional demolition activities are required as part of the VBWR LTP process there is no potential to consume irreversible resources, such as fuel, oil or lubricants.
Mitigation: None required.
Discussion of Construction activities Within various locations of the Environmental Report such as 4.2, 4.3, 4.4, 4.5, 4.6, 4.7, 4.14, 4.15, the term construction was inappropriately utilized in lieu of the proper term demolition. There is no construction required to terminate the VBWR license and this term was used in error.
Summary of corrections / updates to Environmental Report When the subject environmental report was submitted as part of the VBWR LTP (Reference 3) the removal of the VBWR reactor vessel was identified as the only component inseparable from the DPR-1 license. As documented in Reference 4, the VBWR reactor vessel has been successfully removed from the station and properly disposed. Based upon the change in station conditions, was well as the environmental report discussing future demolition activities that are not required to be performed as part of the VBWR LTP process, this update to the Environmental Report was warranted. In summary, there is no further demolition work warranted until the VBWR license has been terminated.
References:
- 1. Letter, USNRC to GEHA Regulatory Affairs., Order Approving Transfer of the Vallecitos Nuclear Center Licenses and Conforming License Amendment (EPID L-2023-LLO-0002), dated April 25, 2024 (ML24039A019).
- 2. Letter, GEH to USNRC, License Termination Plan for the Vallecitos Boiling Water Reactor License DPR-1, dated September 7, 2023 (ML23250A267).
- 3. Letter, GEH to USNRC, License Termination Plan for the Vallecitos Boiling Water Reactor license DPR-1 (Public), dated September 15, 2023 (ML23261A591).
- 4. Email, GEH to USNRC, GEH Vallecitos Nuclear Center, E-mail: Response to acceptance Review of the VBWR License Termination Plan, dated October 31, 2023 (ML23304A300).