RS-24-047, 2023 Annual Radioactive Effluent Release Report

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2023 Annual Radioactive Effluent Release Report
ML24122C647
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 05/01/2024
From: Humphrey M
Constellation Energy Generation
To:
Office of Nuclear Material Safety and Safeguards, Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-24-047
Download: ML24122C647 (1)


Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office

RS-24-047

May 1, 2024

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295, 50-304 and 72-1037

Subject:

Zion Nuclear Power Station 2023 Annual Radioactive Effluent Release Report

Reference:

Letter from A. M. Snyder (U.S. NRC) to D. P. Rhoades (Constellation Energy Generation, LLC) and J. Sauger (Energy Solutions, LLC), "Issuance of Conforming Amendments Regarding Direct Transfer of DPR-39 and DPR-48 Facility Operating Licenses from Zion Solutions, LLC to Constellation Energy Generation, LLC (EPID-L-2023-LLN-0003)," dated November 16, 2023

In the Reference, the NRC issued confor ming amendments for Zion Nuclear Power Station (ZNPS), Units 1 and 2, to reflect the direct transfers of the ZNPS licenses from Zion Solutions, LLC (ZS) to Constellation Energy Generat ion, LLC (CEG). The conforming amendments became effective on November 16, 2023, when the direct license transfer was consummated.

In accordance with the CEG Decommissioning Quality Assurance Program (DQAP),

Appendix F, "Zion Specific Administrative Requirements," CEG is submitting the 2023 Annual Radioactive Effluent Release Report (ARERR) for Zion Nuclear Power Station, Units 1 and 2.

The DQAP requires the ARERR, covering the activities of the site in the previous year, to be submitted by May 1 of each year. However, due to the license transfer discussed above, the 2023 ARERR is being submitted as follows.

  • Attachment 1 provides the ARERR that was developed by ZS and includes radiological information covering the period when ZS was the licensee of ZNPS (i.e., from January 1, 2023, through November 16, 2023). CEG is submitting Attachment 1 on behalf of ZS.
  • Attachment 2 provides the ARERR covering the period from November 17, 2023, through December 31, 2023. CEG began operations at ZNPS on November 17, 2023.

May 1, 2024 U.S. Nuclear Regulatory Commission Page 2

There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Kenneth M. Nicely at (779) 231-6119.

Respectfully,

Mark D. Humphrey Sr. Manager Licensing Constellation Energy Generation, LLC

Attachments:

1. 2023 Zion Nuclear Station Annual Radioactive Effluent Release Report (ARERR)
2. Zion ISFSI Annual Radiological Effluent Release Report

ATTACHMENT 1

2023 Zion Nuclear Station Annual Radioactive Effluent Release Report (ARERR) 2023 ZION NUCLEAR STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (ARERR)

LIST OF SECTIONS

Section No. Description

I. Executive Summary II. Supplemental Information

1. Abnormal Releases and Abnormal Discharges (e.g., leaks and spills)

2.

Offsite Dose Calculation Manual Changes

3. Process Control Program Changes
4. Other (narrative description of other informati on that is provided to the U.S. Nuclear Regulatory Commission, ( e.g., the ARERR for ISFSIs)

III. Appendices Appendix A -Tables Appendix B - Error Estimation Appendix C - Errata Appendix D - ODCM Revisions Appendix E - PCP Revisions

Zion Station 2023ARERR Page 1of 14 May 1, 2024 2023 ZION NUCLEAR STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (ARERR)

Zion Station 2023ARERR Page 2of 14 May 1, 2024 2023 ZION NUCLEAR STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (ARERR)

I. EXECUTIVE

SUMMARY

The 2023Zion Nuclear Power Station (Zion Station) Annual Radioactive Effluent Release Report (ARERR) is presented here. As a note, the Zion Station Operating License,that transitioned to a decommissioning license was terminated ( upon completion of the Zion Station License Termination Plan LTP) ,by the Nuclear Regulatory Commission in August of 2023.

No liquid or gaseous effluents were released from Zion Station in 2023. However, as in 2022,some additional plant material consisting of analytical samples , small amounts of construction concrete,cores, iron, soil samples, plastic sample containers and wood were removed from storage and shipped to the Energy Solutions Low Level Radioactive Bulk Waste Facility in Clive Utah as detailed in Table A -3 Low Level Waste Section of this report. All of this 2023 material was declared waste upon termination of the Zion Station License in accordance with the License Termination Plan (LTP) approved in October of 2018 by the NRC, and the actual termination of the license by the NRC in August of 2023.

This low -level waste was shipped off site on 11/10/ 2023 by Hittman Transportation Services Inc. The total volume of waste shipped consisted of 2200.0cubic feet, or 62.28 cubic meters of Dry Active Waste (DAW) shipped as Low Specific Activity (LSA -I) consisting of analytical samples containing 2.25E+0 1m illicuries, or 2.25E -02 Curies in total, of licensed material . The most significant radionuclide in the waste shippedwas 1.37 E-02Curies of Ni -63.

The only off-site dose reported for 2023was the result of direct dose from radioactive material stored on site; principally spent nuclear fuel and Greater than Class C ( GTCC) waste stored on the Independent Spent Fuel Storage Installation (ISFSI) facility. Total direct dose at the protected area boundary was 0.68 mrem in 2023at location Z -131; see sector Q on Figure 1.1- A. This is the location on site where sky shine has historically had its most significant measured impactto a location accessible to a member of the public.

With average background levels subtracted, the annual dose to a member of the public was adjusted for occupancy resulting in the highest off- site dose to a member of t he public being reported as 0.68mrem after summing all four quarters in 2023.

Lastly, this result is finalized by ratio ing it up for neutron exposure as a measure of conservatism when neutron dose is detected.

The highest neutron dose to gamma radiation ratio level identified was 14/56 +1.0 =

1.25. 1.25 x 0.68 mrem is the highest dose accessible to a member of the public. 0.68 mrem x 1.25 = 0.85 mrem of direct external dose to a member of the public in 2023. The 2nd Quarter of 2023 had the highest neutron to gamma ratio at ISFSI West.

Principal activities on- site in 2023included shipping and confirmation surveys of the waste on- site, final site grading, performance of follow up final status surveys and additional sample collection with on- site and off-site analysis conducted under the site s License Termination Plan (LTP), Revision 2, approved by the NRC in October 2018.

Zion Station 2023ARERR Page 3of 14 May 1, 2024 2023 ZION NUCLEAR STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (ARERR)

Decommissioning was completed in the 4th quarter of 2023with the NRC approving termination of Zion Station s license.

  • There were no liquid effluent or gaseous effluent releases in 2023.
  • 2200c ubic feet, or 62.28 cubic meters, of DAW including poured concrete demolition material,and plant material consisting of analytical samples, small amounts of construction concrete debris, cores, iron, soil samples, plastic sample containers and woodEnergySolutions low level waste facility in Utah byHittman T ransport S ervices In c. trucks to the BWF and Treatment Facilities .

II. SUPPLEMENTAL INFORMATION

1. Abnormal Releases and Abnormal Discharges (e.g., leaks and spills)

There were no Abnormal Releases or Abnormal Discharges (e.g., spills or leaks of radioactive material) during decommissioning in 20 23.

2. Non-routine, Planned Discharges (e.g., pumping of leaks and spills for remediation, results of ground water monitoring to quantify effluent releases to the offsite environment)

There were no non- routine, planned radioactive discharges for remediation resulting in releases off- site, and therefore, no resulting off -site impact.

3. Offsite Dose Calculation Manual Changes There were no revisions to the Zion Station Off Site Dose Calculation Manual (ODCM).
4. Errata/Corrections to Previous ARERRs There wereno Errata/Corrections to previouslyissued ARERRs in 2023.
5. Other (narrative description of other information provided to the U.S. Nuclear Regulatory Commission, e.g., the ARERR for ISFSIs)
a. The ISFSI facility is located wi thin the Zion Station Site and Controlled Area Boundaries . With all significant source term shipped off site, t he IS FS I is the primary source of direct radiation exposure on site and to a member of the public in any unrestricted areas. The station boundary and owner -controlled boundary doses include the direct radiation component of the ISFSI.

The Zion Station decommissioning and Final Status Survey effort s proceeded under the 10 CFR 50 license guidance - ODCM. The ISFSI Facility is operated per its general license issued under 10 CFR 72. The determination of off -site public dose impact is identical for both licenses during this period until August of 2023 when the Part 50 license was terminated.A lthough the Part 50 ODCM methodology need not be followed post -termination of P art 50, it can continue to be utilized until the part 72 license- holder decides to simplify the off- site dose reporting process and documents these changes in a revisionto the ODCM or equivalent reporting guidance.

Zion Station 2023ARERR Page 4of 14 May 1, 2024 2023 ZION NUCLEAR STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (ARERR)

Direct dose was the only contributor of plant-related radiation exposure to a member of the public as shown in Table A-5 with projected whole-body dose of 0.85 mrem per year in 2023 or 3.4% of the annual 40 CFR 190 dose limit of 25 mrem/year measured 300 feet from the center of the ISFSI pad . This TLD is on the road leading to the ISFSI delivery gate, about 100 feet from the gate, and fully visible from the gate. Th is is th e location where highest dose to a member of the public could be received and the expectation is that S ecurity would keep this area clear.

The occupancy factor assumed is an annual 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year, and specifically assumes a member of the public stands at that TLD location for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for four weeks every year. This translates to an occupancy factor of 0.018.

To date, the only activity in that location is delivery personnel who drive by that TLD periodically .

Additionally, and upon review of the Mirion environmental neutron doses reported in the second quarter , it was discovered the neutron doses were excessively high. The most likely cause of the high neutron doses was the application of an operational versus decommissioning dose conversion factor (identified as a source of incorrect doses reported in previous years with quarters of neutron doses 10 times those normally observed).

Mirion was notified, they issued a condition report (CR) (Condition Adverse to Quality, CAQ-226) to confirm the use of an incorrect neutron dose conversion factor and re-issued the corrected neutron environmental dose results. The corrected neutron dose results were used to generate the correct neutron dose ratio.

Zion Station 2023 ARERR Page 5 of 14 May 1, 2024 2023 ZION NUCLEAR STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (ARERR)

Figure 1.1- A -ZION STATION DIRECT DOSE TLD LOCATIONS

Zion Station 2023ARERR Page 6of 14 May 1, 2024 2023 ZION NUCLEAR STATION ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT (ARERR)

III. APPENDICES APPENDI X A - TABLES

Note: In accordance with Regulatory Guide 1.21, Revision 2, Tables do not need to be included if all effluent monitoring results were not detectable and met the required lower limit of detection (LLD). As no effluents were released from Zion Station in 2023, effluent data tab les are not included in the 2023ARERR.

Zion Station 2023ARERR Page 7of 14 May 1, 2024 Zion Station 2023 Annual Radioactive Effluent Release Report

Table A-3. Low-Level Waste Resins, Filters, and Evaporator Volume Curies Shipped Bottoms Waste Class ft3 m3 Curies A 0.00E+00 0.00E+00 0.00E+00

B 0.00E+00 0.00E+00 0.00E+00 C 0.00E+00 0.00E+00 0.00E+00

ALL 0.00E+00 0.00E+00 0.00E+00

Major Nuclides for the Above Table: N/A

Dry Active Waste Volume Curies Shipped Waste Class ft3 m3 Curies

A 2.20E+0 3 6.228E+ 01 2.25E-02 B 0.00E+00 0.00E+00 0.00E+00 C 0.00E+00 0.00E+00 0.00E+00

ALL 2.20E+03 6.228E+01 2.25E-02

Major Nuclides for the Above Table: Co -60 (28.29%), Ni-63 (60.71%), Cs-137 (8.13%), all other nuclides < 1.0%

Irradi ated Components Volume Curies Shipped Waste Class ft3 m3

A 0.00E+00 0.00E+00 0.00E+00 B 0.00E+00 0.00E+00 0.00E+00 C 0.00E+00 0.00E+00 0.00E+00 ALL 0.00E+00 0.00E+00 0.00E+00

Major Nuclides for the Above Table - N/A

Zion Station 2023 ARERR Page 8 of 14 May 1, 2024 Zion Station 2023 Annual Radioactive Effluent Release Report

Table A-3. Low-Level Waste (continue d)

Other Wast e Volume Curies Shipped

WASTE CLASS ft3 m3

A 0.00E+00 0.00E+00 0.00E+00

B 0.00E+00 0.00E+00 0.00E+00

C 0.00E+00 0.00E+00 0.00E+00

ALL 0.00E+00 0.00E+00 0.00E+00

Major Nuclides for the Above Table: N/A

Sum of All Low-Level Wast e Volume Curies Shipped Shipped from S ite

Waste Class ft3 m3

A 2.20E+03 6.228E+01 2.25E-02

B 0.00E+00 0.00E+00 0.00E+00

C 0.00E+00 0.00E+00 0.00E+00

ALL 2.20E+03 6.228E+01 2.25E-02

Major Nuclides for the Above Table: Co -60 (28.29%), Ni-63 (60.71%), Cs-137 (8.13%), all other nuclides < 1.0%

Zion Station 2023 ARERR Page 9 of 14 May 1, 2024 Zion Station 2023 Annual Radioactive Effluent Release Report

Table A-4. Dose Asse ssments, 10 CFR Part 50, Appendix I

Qua rte r 1 Qua rte r 2 Qua rte r 3 Qua rte r 4 Y early Gamma Air Dose 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00

% of Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Gaseous Effluent Dose 10 mrad 10 mrad 10 mrad 10 mrad 20 mrad Lim it , Bet a Air 1 Beta Air Dose 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00

% of Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Gaseous Effluent Dose Limit, Any Organ(Iodine, Tritium, 7.5 mrem 7.5 mrem 7.5 mrem 7.5 mrem 15 mrem Particulateswith >8 -day half-life)

Gaseous Effluent 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 (Iodine, Tritium, Particulate s with > 8-Day half-life)

% of Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00

1 Dose to air (mrad) is applied to noble gas emissions only - noble gases are no longer created by fission at Zion Station or released from site following spent fuel transfer in 2014, and spent fuel pool treatment and drain down in 2015.

Table A-5. EPA 40 CFR Part 190 Dose to Indivi dual in the Unres tricted Area (mrem/year)

Whole Body1 Thyroid1 Any other organ1 Dose Limit 25 mrem/year 75 mrem/year 25 mrem/year Direct Dose 0.85E+00 0.85E+00 0.85E+00 Dose From Liquid 0.00E+00 0.00E+00 0.00E+00 Dose From Gaseous 0.00E+00 0.00E+00 0.00E+00 Postulated H-3 Dose 0.00E+00 0.00E+00 0.00E+00 TOTAL DOSE 0.85E+00 0.85E+00 0.85E+00

% of Limit 3.40E+00 1.13E+ 00 3.40E+00

1 - The 40 CFR190 dose is the sum of internal exposure (consumption of food stuffs and water),

inhalation and direct radiation in the highest X/Q sector at the site boundary for gaseous releases (sector A - North - zero (0)mrem as there were no gaseous releases) and the sector with the highest direct dose (sector Q - Northwest for quarters 1 through 4) at the controlled area boundary with occupancy factors applied. The reported total dose is in units of mrem per year.

Zion Station 2023 ARERR Page 10 of 14 May 1, 2024 Zion Station 2023 Annual Radioactive Effluent Release Report

Appendix B

Error Estimation - Uncertainty

Estimates of Total Error

The following is a calculated estimate of the maximum potential total error associated with reported values in the Annual Radioactive Effluent Release Report. The Total error is determined by calculating the square root of the sum of the squares of the individual errors.

= (2 + 2 + 2 + 2 )

23% = (52 + 102 + 172 + 102 )

a. Gaseous Effluents

Sampling Error (S) 5%

Calibration Error ( C) 10%

Counting Statistics Error ( CS) 17%

Sample Volume Error (V) 10%

Total Error 23%

Zion Station 2023 ARERR Page 11 of 14 May 1, 2024 Zion Station 202 3 Annual Radioactive Effluent Release Report

Appendix C - Errata

No Errata to Previously Issued ARERRs

Zion Station 2023ARERR Page 12of 14 May 1, 2024 Zion Station 202 3 Annual Radioactive Effluent Release Report

Appendix D - ODCM Revisions

There were no revisions to the Zion Station ODCM in 2023.

Zion Station 2023ARERR Page 13of 14 May 1, 2024 Zion Station 2023 Annual Radioactive Effluent Release Report

Appendix E - PCP Revisions

The Process Control Program (PCP) was terminated in 2020 as the only waste still remaining on site is spent nuclear fuel and GTCC waste sealed in shielded steel canisters, stored in thick-walled steel rebar and concrete over packs.

The spent fuel and GTCC waste will remain at the station until the National Spent Fuel Repository is completed and ready to accept it.

Zion Station 2023 ARERR Page 14 of 14 May 1, 2024 ATTACHMENT 2

Zion ISFSI Annual Radiological Effluent Release Report Zion 2023 ARERR Page 1 of 6 Zion ISFSI Annual Radiological Effluent Release Report

Facility Operating License: DPR-39 and DPR-48 NRC Docket: 50-295, 50-304, and 72-1037 Period: 11/17/23 to 12/31/23

SRRS 2C.111 Zion 2023 ARERR Page 2 of 6

Table of Contents I. Executive Summary .........................................................................................................3

II. Supplemental Information ................................................................................................3

1. Abnormal Releases and Abnormal Discharges .....................................................3
2. Non-routine, Planned Discharges .........................................................................3
3. Offsite Dose Calculation Manual Changes ............................................................3
4. Process Control Program Changes.......................................................................3
5. Other .....................................................................................................................3

III. Appendices ................................................................................................................. .....4 A. Effluent, Waste, and Dose Tables .........................................................................4 B. Error Estimation ....................................................................................................6 C. There is no Errata to previously issued ARERRs .................................................. 6 D. Revision 12 of the ODCM was implemented in 2020 ............................................6 E. The Process Control Program was terminated in 2020 .........................................6

SRRS 2C.111 Zion 2023 ARERR Page 3 of 6

I. Executive Summary The license for Zion ISFSI was transferred to Constellation on 11/16/23 with Constellation operations beginning on 11/17/23. This report will cover operations after the transfer and ZionSolutions will provide a separa te report for their operations prior to 11/17/23. The 2023 Zion ISFSI Annual Radioactive Effluent Releas e Report (ARERR) is attached. The ISFSI canisters are the only source of radioactivity on site. No liquid or gaseous effluents were released from the facility in 2023. Those pathways no longer exist with the fuel in stainless steel containers with welded lids. There were no radioactive material or waste shipments from the facility after 11/16/23. There is an overlap in monitoring provided in 2023 by ZionSolutions and Constellation.

II. Supplemental Information

1. Abnormal Releases and Abnormal Discharges (e.g. leaks and spills)

There are no effluent pathways.

2. Non-Routine, Planned Discharges (e.g. pumping of leaks and spills for remediation)

There were no non-routine, planned radioactive discharges for remediation resulting in releases offsite, and therefore, no resulting offsite impact.

3. Offsite Dose Calculation Manual (ODCM) Changes Revision 12 of the ODCM was issued in Jan 2020
4. Errata/Corrections to previously issues ARERRs.

Monitoring by Constellation began 11/17/23 with no previous reports.

5. Other (narrative description of other information provided to the NRC)

Direct dose was the only exposure pathway and is also described in the 10CFR72.212 report.

SRRS 2C.111 Zion 2023 ARERR Page 4 of 6

III. Appendices In accordance with Regulatory Guide 1.21, Revision 2, tables do not need to be included if all effluent monitoring results were not detectable and met the required lower limit of detection (LLD). As no effluents were released from Zion ISFSI in 2023, effluent data tables are not included in the 2023 ARERR. Additionally, there have been no radioactive waste shipments since Constellation became the licensee on 11/17/23.

Appendix A - Tables

There are no effluent pathways. All radioactive material is contained in stainless steel containers with welded lids in concrete over pack structures.

Table A-4 Dose Assessments, 10 CFR Part 50, Appendix I

Quarter 1 Quarter 2 Quarter 3 Quarter 4 Yearly

Gamma Air Dose 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00

% of Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Gaseous Effluent Dose Limit Beta 10 mrad 10 mrad 10 mrad 10 mrad 20 mrad Air Beta Air Dose 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00

% of Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Gaseous Effluent Dose Limit, Any 7.5 mrem 7.5 mrem 7.5 mrem 7.5 mrem 15 mrem Organ (Iodine, Tritium, Particulates with >8 day half-life)

Gaseous Effluent (Iodine, Tritium, 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00 Particulates with >8 day half-life)

% of Limit 0.00E+00 0.00E+00 0.00E+00 0.00E+00 0.00E+00

SRRS 2C.111 Zion 2023 ARERR Page 5 of 6

Direct dose is the only exposure pathway. There are no effluent pathways.

Table A-5 EPA 40 CFR Part 190 Dose to Individual in Unrestricted Area (mrem/yr)

Whole Body Thyroid Any Other Organ Dose Limit 25 mrem/yr 75 mrem/yr 25 mrem/yr Direct Dose 12.9 N/A N/A Dose from Liquid 0.00E+00 0.00E+00 0.00E+00 Dose from Gaseous 0.00E+00 0.00E+00 0.00E+00 Postulated H-3 Dose 0.00E+00 0.00E+00 0.00E+00 Total Dose 12.9 0.00E+00 0.00E+00

% of Limit 51.6 0.00E+00 0.00E+00

The source of the data is current 10CFR72.212 report revision 12. The dose rates are gamma and neutron calculated by Monte Carlo (MCNP) codes by NAC personnel. Occupancy factors were then determined by ZionSolutions personnel and applied to calculate dose to the maximally exposed individual. There have been no changes to the community surrounding the facility to impact the dose to the public.

Dose to Maximally Exposed Individual in Unrestricted Areas

Distance from Center of Limit Value ISFSI Pad (mrem/yr) (mrem/yr) (meters) Description 25 12.9 319 Unrestricted area, long-term camper, to the south at campsite 248 in Illinois Beach State park 11.8 235 Unrestricted area, Illinois Beach State worker to the south site boundary

SRRS 2C.111 Zion 2023 ARERR Page 6 of 6

Appendix B

Error Estimation - Uncertainty

There is no effluent pathway to estimate the sources of error

Appendix C - Errata

Constellation operations began on 11/17/23 so there is no errata for any previous report.

Appendix D - ODCM Revisions

Revision 12 of the ODCM was issued 1/30/20

Appendix E - PCP Revisions

The Process Control Program (PCP) was terminated in 2020 as the only waste remaining onsite is spent nuclear fuel and GTCC waste sealed in shielded steel canisters, stored in thick walled steel rebar and concrete over packs.

The spent fuel and GTCC waste will remain at the station until the National Spent Fuel Repository is completed and ready to accept it. The spent nuclear fuel and GTCC waste do not need to be processed nor will they be processed and therefore, the Process Control Program was terminated.

SRRS 2C.111