ML25006A196
| ML25006A196 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute, 99902028 |
| Issue date: | 01/06/2025 |
| From: | Montgomery B Nuclear Energy Institute |
| To: | Barwell O Office of Nuclear Reactor Regulation, NRC/OCFO, Document Control Desk |
| References | |
| Download: ML25006A196 (1) | |
Text
Bruce Montgomery Director, Decommissioning &
Used Fuel Phone: 202.739.8128 Email: bsm@nei.org January 6, 2025 Mr. Owen F. Barwell Chief Financial Officer U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Fee Exemption Request for Review and Endorsement of NEI 22-01, Revision 1, License Termination Process Project Number: 689
Dear Mr. Barwell:
The Nuclear Energy Institute (NEI)1 has submitted Revision 1 to technical report NEI 22-01, License Termination Process, for review and endorsement by the U.S. Nuclear Regulatory Commission (NRC).
This report will assist decommissioning reactor licensees in the development and implementation of license termination plans (LTP) that satisfy NRCs requirements in 10 CFR 20, Subpart E, Radiological Criteria for License Termination.2 On behalf of its members, NEI requests that NRCs review of NEI 22-01, Revision 1, including any subsequent meetings and submittals associated with the review, be granted a fee waiver pursuant to 10 CFR 170.11. The document meets the exemption requirement in 10 CFR 170.11(a)(1)(ii) in that it will assist the NRC in generic regulatory improvements or efforts. NRC review and endorsement will promote a consistent approach to development of LTPs by NRC licensees that are decommissioning commercial nuclear reactors. This outcome will increase the efficiency of NRC licensing actions and inspection activities associated with the license termination process.
1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.
2 Bruce Montgomery (NEI) to Jane Marshall (NRC), NEI 22-01 Revision 1, License Termination Process, dated January 6, 2025.
Mr. Owen Barwell January 6, 2025 Page 2 Nuclear Energy Institute By email dated June 21, 2023,3 the NRC approved NEIs fee exemption request related to the review of NEI 22-01 Revision 0, which was submitted to NRC on February 13, 2023,4 as supplemented by letters dated April 11, 2023,5 and December 12, 2023.6 By letter dated April 30, 2024, NRC issued the results of its technical review, providing comprehensive insights and observations on NEI 22-01.7 Revision 1 to NEI 22-01 incorporates these valuable inputs.
Over the next decade, the industry and the NRC will be challenged by the need to develop, review, execute and approve an unprecedented number of license termination plan (LTP) submittals. For the most part, these submittals will be for sites that have chosen DECON as the decommissioning approach, with total project timelines ranging from ten years to as few as eight.
The complexity of the license termination process coupled with near-term project timelines requires that licensee LTPs be closely aligned with NRC expectations. To support timely completion of decommissioning projects in a safe and environmentally responsible fashion, it is critical that quality LTPs are submitted by licensees and that NRC completes reviews and issues safety evaluation reports in approximately one year. Recent experience indicates a significant misalignment between NRC expectations for LTP quality and completeness and license submittals. This has led to LTP approvals typically requiring several years of NRC staff review along with multiple requests for additional information.
NRC has published a vast compendium of guidance on license termination and related technical topics applicable to reactors, materials licensees, and fuel cycle facilities. Because of the very diverse nature of these facilities and the unique radiological remediation challenges they present, this compendium of guidance is necessarily complex and voluminous. For example, a key source of guidance, NUREG-1575, Multi-Agency Radiological Site Survey Implementation Manual (MARSSIM), is a collaboration between the EPA, DOE, DOD and NRC. It addresses survey design for a broad range radiological decommissioning projects including former defense sites posing very complex remediation challenges, many of which do not apply to the typical commercial reactor site. At the same time, MARSSIM does not provide guidance to the industry or the NRC on the design and conduct of surveys for subsurface 3 ADAMS Accession No. ML23103A329 4 ADAMS Accession No. ML23045A322 5 ADAMS Accession No. ML23102A030 6 ADAMS Accession No. ML23347A211 7 Jennifer Whitman (NRC) to Bruce Montgomery, U.S. Nuclear Regulatory Commission Observations and Insights of Nuclear Energy Institute (NEI) Technical Report NEI 22-01, License Termination Process (EPID L-2023-NFO-0010) dated April 30, 2024 (ML24039A183)
Mr. Owen Barwell January 6, 2025 Page 3 Nuclear Energy Institute structures and soils, which is an issue of significant regulatory interest for commercial reactor decommissioning.
NEI 22-01 addresses these issues by providing guidance to licensees in all aspects of the process including advance planning, historical site assessments, exposure scenarios, the design and conduct of surveys, radiological compliance, and reporting of final status survey results. Compliance with the standard format and content for LTPs as outlined in R.G. 1.179 is emphasized for uniformity and consistency and then enhanced with a discussion of the importance of those features unique to the specific site in question. NEI 22-01 also provides recommendations for promoting transparency in these activities by recommending a standard communications protocol with NRC, state, and local agencies at appropriate points during decommissioning. Operating experience and lessons gleaned from past decommissioning projects have been extensively incorporated into the document.
NEI believes that NRC endorsement of this report will benefit both the NRC and the commercial reactor fleet by enhancing the safe, environmentally responsible, and timely completion of license termination-related activities, thus providing broad public benefit. These benefits apply to existing decommissioning projects and even more importantly to future decommissioning projects for which the documentation of todays lessons learned is critical. As the industry continues to gain experience and develop improved technical capabilities and methodologies, NEI will update NEI 22-01 in future revisions and submit these revisions for NRC review, thereby ensuring continued improvement in license termination practices and alignment with NRC requirements.
NRC endorsement of NEI 22-01 will provide licensees with confidence that the approach provided in the guidance is consistent with the NRCs expectations.
If you have any questions on this matter, please contact me at bsm@nei.org.
Sincerely, Bruce Montgomery, Director, Decommissioning & Used Fuel C:
Ms. Jane Marshall, NMSS/DUWP Ms. Jennifer Whitman NRC Document Control Desk