ML24347A096
| ML24347A096 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/26/2024 |
| From: | Amy Snyder Reactor Decommissioning Branch |
| To: | Shaun Anderson Reactor Decommissioning Branch |
| References | |
| Download: ML24347A096 (1) | |
Text
MEMORANDUM TO:
Shaun Anderson, Branch Chief Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards FROM:
Amy Snyder, Senior Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards
SUBJECT:
LICENSE TERMINATION PLAN LICENSE AMENDMENT REQUEST - MEETING
SUMMARY
FROM CLARIFICATION CALL ON REQUEST FOR SUPPLEMENTAL INFORMATION On October 4, 2024 (Agencywide Documents and Management System (ADAMS) Accession No. ML24269A043 Pkg), the U.S. Nuclear Regulatory Commission (NRC) issued a request for supplemental information (RSI) related to the acceptance review of the Holtec Decommissioning International, LLC (HDI) Oyster Creek Nuclear Generating Station License Termination Plan License Amendment Request (LAR) (ML24214A037). On October 10, 2024 (ML24284A174),
the NRC issued an updated RSI and Pending Request for Additional Information due to discovery of a version control issue. On December 10, 2024, the NRC held clarification call with HDI on RSI 1 and RSI 13. A summary of HDIs RSI comments and questions and the NRC staffs clarification responses and comments are documented in Enclosure 1. A list of attendees is documented in Enclosure 2. The NRC staff made no decisions at this meeting. The NRC staff will evaluate the HDI RSI responses upon submittal.
In accordance with 10 CFR 2.390, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs ADAMS. ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html.
Docket Nos.: 50-219 and 72-15 License No.: DPR-16
Enclosures:
- 1. Clarification Questions and Comments
- 2. List of Attendees CONTACT: Amy Snyder, NMSS/DUWP (301) 415-6822 December 26, 2024 Doell, Marlayna signing on behalf of Snyder, Amy on 12/26/24
ML24347A096 OFFICE NMSS/DUWP NMSS/DUWP NMSS/DUWP NMSS/DUWP NAME A. Snyder S. Anderson C. McKenney A. Snyder DATE 12/18/2024 12/26/2024 12/26/2024 12/26/2024 OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS)
REQUEST FOR SUPPLEMENTAL INFORMATION (RSI) -
ACCEPTANCE REVIEW FOR THE LICENSE TERMINATION PLAN LICENSE AMENDMENT REQUEST MEETING
SUMMARY
FROM CLARIFICATION CALL ON RSI-1 AND RSI-13 Item No.
RSI LICENSEE QUESTION AND STAFF RESPONSE RSI-1 Identify and describe the survey units within each area of the site, including the classification, area, and general information on surrounding survey units. Include maps with defined boundaries of the survey units, the scan and sample locations, and survey unit sizes.
Holtec Decommissioning International (HDI)-OCNGS Questions/Comments: In the NRCs clarification to RSI-1, as documented in the October 25 and 29, 2024, clarification call summary (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24341A035),
the staff indicated that the NRC will accept, at a minimum, the designation of survey areas during the acceptance review phase of the OCNGS license termination plant (LTP). HDI asked does this imply that the response to RSI-1 is complete if it meets the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM) guidance, or is there other work/evaluations/documentation that is needed to close out this RSI?
NRC Staffs Comments: For site characterization, the staff stated that HDI would have to provide its initial survey area classifications and describe its method of making changes to the unit classifications in the area so the NRC staff could review and approve the method. The method should include when HDI plans to inform the NRC staff of the changes. The changes should be communicated to the staff when made but in all cases before HDI conducts the Final Status Survey for the survey unit.
If the licensee is going to follow MARSSIM, the licensees method should reference the sections of MARSSIM it will follow and provide details on the representativeness of the data and the number of samples it will take to ensure statistical significance and uncertainty when making any decisions regarding changing the classification of a survey unit to another classification different than that of the associated initial classified survey area. The NRC staff noted that a decrease in survey unit area classification is of importance to the staff.
Given there are no preliminary survey units defined in the OCNGS LTP, the NRC staff will assume the initial classification for surveys units within a survey area defined in the LTP to be the same as that of the survey area in which it resides. If as the NRC staff understands, the survey units are defined immediately prior to final status survey, HDI would need to describe the method for updating survey maps, including survey unit boundaries, classifications, and areas, as well as the process for communicating this information to the NRC staff.
2 Item No.
RSI LICENSEE QUESTION AND STAFF RESPONSE If the NRC staff finds the method of making changes to the survey unit classifications acceptable, then a future LTP amendment may not be necessary in order to adequately address this topic.
Additionally, the LTP includes an option for exceeding the survey unit size recommendations in MARSSIM. The NRC staff noted HDI would need to describe the method or criteria for exceeding recommended survey unit sizes.
NRC Response: The NRC staff stated that for any other survey area changes that HDI intends to make as it gathers more classification data, HDI should also describe its method for re-establishing values such as surrogate ratios.
RSI-1 (continued)
NRC Question: The NRC staff asked the licensee to clarify whether or not it plans to change its characterization strategy of updating characterization data and parameters associated with characterization data as decommissioning progresses up to final status survey.
HDI-OCNGS Response: HDI stated that its overall characterization strategy as described in the LTP submittal will not change; however, it will provide additional characterization information to reflect the characterization that is ongoing now, as well as include the methods it will use for changing parameters or information associated with characterization as it continues to be performed at OCNGS.
3 Item No.
RSI LICENSEE QUESTION AND STAFF RESPONSE RSI-13 Environmental: Provide an assessment of reasonable alternative actions as required under 10 CFR 51.45(3).
HDI-OCNGS Questions/Comments: In accordance with the guidance in NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (ML032450279), HDI has identified in Chapter 8 of the OCNGS LTP why the proposed action, i.e.,
decommissioning of the facility, is needed. As stated in NUREG-0586, Supplement 1, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, the only alternative to the action of decommissioning is not to decommission the facility. The option to restart the reactor is not considered in NUREG-0586 to be an alternative to decommissioning because the regulations do not allow the licensee to reload fuel and restart the facility after submitting a certification that the fuel has been removed from the reactor vessel. HDI for Oyster Creek has compared the impact of site-specific decommissioning activities with previously analyzed termination activities in NUREG-0586.
Please clarify the basis for requiring Oyster Creek to identify alternatives to individual decommissioning actions, such as methods for transporting radioactive waste.
NRC Staffs Comments: The NRC staff acknowledged that the no-action alternative is the only alternative required by regulations to be discussed in the alternatives review section; however, the staff stated that including details on the waste transportation by barge scenario in the environmental report is important because it involves different potential off-site dose pathways than other scenarios considered in the environmental report for waste transportation and disposal. In addition, the staff stated that a license may decide to not include the barge scenario in the initial LTP submittal and state that if it plans on barge transportation, it would submit an additional license amendment request to address the environmental assessment for barge transportation before any such transportation would take place.
HDI-OCNGS Response: HDI stated that it would consider how it wanted to proceed in the RSI response, based on the option of not including information on the barge transport in the LTP.
LIST OF ATTENDEES AT THE DECEMBER 10, 2024, CLARIFICATION CALL ON THE OYSTER CREEK NUCLEAR GENERATING STATION (OCNGS)
ACCEPTANCE REVIEW FOR THE LICENSE TERMINATION PLAN LICENSE AMENDMENT REQUEST REQUEST FOR SUPPLEMENTAL INFORMATION (RSI) 1 and 13 Nuclear Regulatory Commission (NRC): December 10, 2025 Amy Snyder Cynthia Barr Kathryn Robertson-DeMers Randy Fedors Issac Johnston Holtec Decommissioning International, Oyster Creek and its Contractors: December 10, 2025 Steven Johnston, S.Johnston@holtec.com Tom Williamson, t.williamson@holtec.com