ML25133A100
| ML25133A100 | |
| Person / Time | |
|---|---|
| Issue date: | 05/21/2025 |
| From: | John Marshall, Philip Mckenna, Pelton J Division of Decommissioning, Uranium Recovery and Waste Programs, Division of Operating Reactor Licensing, NRC/NRR/DRO |
| To: | Russell Felts, Jack Giessner, Mark King, Andrea Kock, John Monninger Office of Nuclear Reactor Regulation, NRC Region 1, NRC/RGN-III, NRC Region 4 |
| References | |
| Download: ML25133A100 (1) | |
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MEMORANDUM TO:
Andrea Kock, Regional Administrator Region I Jack Giessner, Regional Administrator Region III Michael King, Acting Director Office of Nuclear Reactor Regulation Russell Felts, Director Division of Reactor Oversight Office of Nuclear Reactor Regulation FROM:
Jane Marshall, Director Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Materials Safety and Safeguards Jamie Pelton, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Philip McKenna, Deputy Director Division of Reactor Oversight Office of Nuclear Reactor Regulation
SUBJECT:
CLARIFICATION ON USE OF MC 2561 DURING FACILITY RESTART ACTIVITIES UNDER IMC 2562 Recent experience with the Palisades Nuclear Plant and Christopher M. Crane Clean Energy Center (formerly Three Mile Island Nuclear Station, Unit 1) facilities highlighted the need for clarification regarding the use of potentially duplicative inspection resources during the transition from a decommissioning status to a state that would support potential restart. This memorandum clarifies that Inspection Manual Chapter (IMC) 2561, CONTACT: Shaun M. Anderson, NMSS/RDB 301-415-2039 May 21, 2025 Signed by Marshall, Jane on 05/16/25 Signed by Pelton, Jamie on 05/16/25 Signed by McKenna, Philip on 05/21/25
A. Kock, et al.
2 Decommissioning Power Reactor Inspection Program, remains applicable and should supplement inspection planning when a licensee formally initiates restart activities under IMC 2562, Light-Water Reactor Inspection Program for Restart of Reactor Facilities Following Permanent Cessation of Power Operations. Specifically, the requirement to complete the reactor decommissioning inspection program under IMC 2561 will be in abeyance when official restart activities begin under IMC 2562. However, adequate inspections shall be completed to meet the objective of ensuring licensee activities are conducted safely, spent fuel is safely secured and stored on site, and that site operations are in conformance with applicable regulatory requirements.
Key Guidance:
IMC 2562, Section 06.03.b: When a licensee ceases decommissioning and pursues restart, IMC 2562 governs the creation of the ROP transition plan. Restart activities formally begin when a licensee requests an exemption from 10 CFR 50.82(a)(2) to reload fuel and resume operations.
IMC 2561, Section 06.04: Decommissioning inspections continue until the NRC determines they are no longer necessary. These inspections offer valuable insight into a licensees readiness for restart and should inform the development of a risk-informed inspection plan, avoiding duplication while maintaining comprehensive oversight.
The restart panel created for each facility may assign decommissioning inspection staff to support the overall inspection oversight to the associated restart team.
Clarification/Implementation:
IMC 2561 ensures the facility's ongoing safe and secure storage of spent fuel. IMC 2562 confirms readiness for safe and compliant reactor operations.
While restart activities must align with IMC 2562, necessary inspections under IMC 2561 should continue to ensure ongoing safe operation of the facility throughout the transition period. These inspections should be incorporated where they address safety aspects not fully covered by IMC 2562.
Completion of IMC 2561 is not required.
Time and resources should generally be charged to IMC 2562. However, specific activities tied to continued decommissioning oversight should be charged to IMC 2561.
This approach ensures programmatic requirements are met even if restart efforts are unsuccessful.
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Conclusion:==
A facility undergoing restart under IMC 2562 is not deviating from the decommissioning inspection program and does not require special approval. Inspection planning should be risk-informed and include IMC 2561 activities as appropriate to ensure continued safe operations and regulatory compliance throughout the transition period to potential restart.
ML25133A100; Memo ML25133A100 OFFICE NMSS/DUWP/RDB NRR/DRO/IRIB NMSS/REFS
/RRPB NMSS/DUWP NAME SAnderson DBollock IBerrios JMarshall DATE May 15, 2025 May 14, 2025 May 16, 2025 May 16, 2025 OFFICE NRR/DORL NRR/DRO NAME JPelton PMcKenna DATE May 16, 2025 May 21, 2025