ML12268A326

Plum Brook Reactor Facility, Request for Termination of Licenses Nos. TR-3 and R-93

ML12268A326
Person / Time
Site:	Plum Brook
Issue date:	09/18/2012
From:	Liang A US National Aeronautics & Space Admin (NASA), John H. Glenn Research Ctr at Lewis Field
To:	Document Control Desk, NRC/FSME
References
Download: ML12268A326 (13)

Text

National Aeronautics and Space Administration John H. Glenn Research Center Lewis Field Cleveland, OH 44135-3191 September 18, 2012 Rcply to Atin of: Q U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Plum Brook Reactor Facility, Request for Termination of Licenses Nos. TR-3, Docket No. 50-30 and R-93, Docket No, 50-185 The following request is affirmed under 28 USC Section 1746.In accordance with 10 CFR 50.82(b)(6), this letter submits the National Aeronautics and Space Administration (NASA) request for the termination of the Plum Brook Reactor Facility License TR-3 and the NASA Mockup Reactor License R-93. NASA has completed all decommissioning activities specified in the NRC approved "Decommissioning Plan for the Plum Brook Reactor Facility", and has completed all terminal radiation surveys of the Reactor Facility and the associated NASA site as specified in the NRC approved "Final Status Survey Plan for the Plum Brook Reactor Facility".

The terminal radiation surveys as reported in the"Plum Brook Reactor Facility Final Status Survey Report" demonstrate that the facility and surrounding areas meet the criteria for release for unrestricted use stipulated in 10 CFR 20.1402.In addition, all receptor dose modeling and confirmatory radiological surveys have been completed to demonstrate compliance with Condition 4 of both Licenses which states, "Prior to termination of this license, NASA shall assess the residual activity in Plum Brook between the Plum Brook Station and Sandusky Bay and demonstrate that the area meets the radiological criteria for unrestricted use specified in 10 CFR 20.1402".References to the supporting documentation submitted to the Nuclear Regulatory Commission are provided in the enclosures.

All radioactive materials, including calibration and check sources and other sealed sources, have been removed such that any remaining residual radioactivity is within the limits of 10 CFR Part 20, subpart E and is As Low As Reasonably Achievable (ALARA).

2 Should you have any questions or need additional information, please contact Mr. Peter Kolb at NASA Glenn Research Center, 21000 Brookpark Road, M.S. 3-11, Cleveland, Ohio, 44135, or by telephone at (216) 433-3103.This License Termination Request is true and correct to the best of my knowledge and belief. I declare under penalty of perjury that the foregoing is true and correct and I executed this September 18, 2012."ta D. Liang Director, Safety and Miss n Assurance Enclosure cc: USNRC/C. J. Glenn (FSME)USNRC/J. Webb (FSME)USNRC/J. Tapp RIII/DNMS/DB USNRC/L. Rodriguez RIIIiDNMS/DB ODH/M. J. Rubadue I JUSTIFICATION FOR TERMINATION OF LICENSES Title 10, Code of Federal Regulations Section 50.82(b)(6) states: "The Commission will terminate the license if it determines that--(i) The decommissioning has been performed in accordance with the approved decommissioning plan, and (ii) The terminal radiation survey and associated documentation demonstrate that the facility and site are suitable for release in accordance with the criteria for decommissioning in 10 CFR part 20, subpart E. " The following actions have been completed:

The National Aeronautics and Space Administration (NASA) submitted the proposed"Decommissioning Plan for the Plum Brook Reactor Facility", Revision 0, dated December 1999, to the U. S. Nuclear Regulatory Commission (USNRC) for approval by letter dated December 20, 1999 (ML993630054).

The Decommissioning Plan was revised to incorporate NASA responses to NRC Staff comments and Requests for Additional Information (RAI).On March 21, 2000, the USNRC issued the "Plum Brook Reactor and Plum Brook Reactor Mock-Up Reactor Environmental Assessment and Finding of No Significant Environmental Impact" (ML003690089) addressing the proposed facility decommissioning.

This Environmental Assessment was published in the Federal Register March 28, 2000 (65 FR 16241).On March 20, 2002, the USNRC formally approved the "Decommissioning Plan for the Plum Brook Reactor Facility", Revision 2, dated October 2001, by issuance of Amendment 11 to License TR-3 and Amendment 7 to License R-93 (ML020390069).

The amended licenses authorized decommissioning of the Plum Brook Reactor Facility in accordance with Decommissioning Plan and included provisions for future revisions to the Decommissioning Plan without NRC approval or License Amendment provided certain criteria were met regarding the nature of the revisions.

As Decommissioning progressed, additional revisions were made to the Decommissioning Plan. These follow-on revisions were evaluated under the provisions of the Licenses and as specified in section 9 of the Decommissioning Plan as neither requiring approval by the USNRC nor requiring an Amendment to the Licenses.

The following revisions were implemented and submitted to the NRC Staff for information:

• "Decommissioning Plan for the Plum Brook Reactor Facility", Revision 3, dated May 27, 2004, was submitted by letter dated June 23, 2004 (ML041840466).

Enclosure I Page 1 of 11 Enclosure 1, Justification for Termination of Licenses* "Decommissioning Plan for the Plum Brook Reactor Facility", Revision 4, dated April 26, 2005, was submitted by letter dated April 27, 2005 (ML051190339).

• "Decommissioning Plan for the Plum Brook Reactor Facility", Revision 5, dated December 2, 2005, was submitted by letter dated December 5, 2005 (ML053420467).

• "Decommissioning Plan for the Plum Brook Reactor Facility", Revision 6, dated July 22, 2008, was submitted by letter dated July 23, 2008 (ML082070086).

The Decommissioning activities have been completed as specified in the Decommissioning Plan. All radioactive material has been removed to a level that will permit release of the site for unrestricted use as specified in the criteria in 10 CFR 20, subpart E, and is ALARA. All structures, systems, and components have been removed or decontaminated, all sealed sources have been removed by either disposal at a licensed facility or transfer to another licensee, all radioactive waste has been transported for off-site disposal, all structures have either been decontaminated or demolished to an elevation of at least one meter below final grade, and, the site has been graded and contoured to its natural grade.II During the decommissioning program, NASA performed a radiological scoping survey of the Plum Brook stream bed and in environmental areas along banks of Plum Brook. The scoping surveys determined that there were very low levels of detectable radionuclides present in some areas of the stream bed and along the stream banks. Based on the radionuclide mixture present, NASA determined that this material was the result of reactor facility operations.

NASA retained the services of a local environmental consulting firm and performed a detailed radiological study of the off-site environmental area along the discharge flow path between Plum Brook Station and Sandusky Bay. The following table lists the reports of this study submitted to the USNRC with the NRC ADAMS System Accession Numbers for the reports and submittal letters: Table 1: Summary of Plum Brook Environmental Study Report Submittals ADAMS Submittal Submittal Report Til Accession Letter Letter No. Date Number Date Accession No.Characterization Report for Plum Brook Rev 0 Apr 16, ML071270717 May 03, M1L071270714 Sediment in East Sandusky Bay 2007 2007 Characterization Report for Plum Brook Rev 1 Jan 04, ML080080615 Jan 04, ML080080605 Sediment in East Sandusky Bay 2008 2008 Characterization Report for Plum Brook Rev 0 Apr 17, ML071270723 May 03, ML071270714 Sediment in Ponds 2007 2007 Characterization Report for Plum Brook Rev I Jan 04, ML080080608 Jan 04, ML080080605 Sediment in Ponds 2008 2008 Development of Conceptual Model as Basis Jun 06, ML071620294 Jun 07, ML071620127 for Characterization Plan -Plum Brook Rev 0 2007 2007 Reactor Facility Enclosure I Page 2 of II Enclosure 1, Justification for Termination of Licenses ADAMS Submittal Submittal Report Title R Re.ort Accession Letter Letter No. Date Number Date Accession No.Development of Conceptual Model as Basis Jan 04, ML080080613 Jan 04, MLL080080605 for Characterization Plan- Plum Brook Rev 1 2008 2008 Reactor Facility Characterization Report for Sediment in Jan 21, ML080280060 Jan 23, ML080280060 Groundwater Wells Near the Plum Brook Rev 0 2008 2008 Reactor Facility Characterization Report for Plum Brook Rev 0 Feb 08, ML080450300 Feb 11, ML080450274 Sediment in Stream Mouth Wetlands 2008 ML080450276 2008 Characterization Report for Plum Brook Rev I Apr 02, ML081130326 Apr 10, ML081120072 Sediment in Stream Mouth Wetlands 2008 ML081120073 2008 Characterization Report for Plum Brook Rev 0 Mar 18, ML081410649 May 15, ML081410648 Sediment in Flood Plain Wetlands 2008 ML081410650 2008 NASA performed a detailed assessment of the dose consequences of the sediment contamination in Plum Brook environmental areas and documented the assessment in two Technical Basis Documents.

PBRF-TBD-07-005, revision 0, "Assessment of Radiation Exposures from Plum Brook Sediments Contaminated with Cesium-137", was submitted for information to the NRC Staff by letter dated June 27, 2008. PBRF-TBD-08-001, revision 0,"Assessment of Age Dependent Dose from Plum Brook Sediments", was submitted to the NRC Staff by letter dated August 7, 2008 (ML082330186).

A public meeting was convened on September 3, 2008 where the NASA and NRC Staff openly discussed a dose modeling approach to assessing the radioactive contamination in Plum Brook, rather than performance of a MARSSIM based approach to Final Status Survey. Minutes of this meeting were published by the NRC Staff (ML082900916).

As a result of the public meeting, NASA committed to further refine the two previous dose assessments and resubmit in a single document and to initiate a license amendment request that would incorporate a license condition to assure complete evaluation of the residual contamination and its effects prior to terminating the NRC Licenses for the facility.NASA submitted the "Plum Brook Sediment Characterization Data Report -October 2008", by letter dated October 10, 2008 (ML090641013).

It was followed by License Amendment application for licenses TR-3 and R-93 to incorporate a License Condition requiring an assessment of the residual activity in Plum Brook prior to termination of the licenses.

The amendment request was submitted by letter dated January 9, 2009 (ML090140338).

The NASA letter dated March 20, 2009 (ML090900439) submitted Technical Basis Document PBRF-TBD-08-006, "Revised Dose Assessment for Plum Brook Sediments", revision 0, dated March 18, 2009 (ML090900750), and Technical Basis Document PBRF-TBD-08-005, "Radiological Characterization of Plum Brook Sediments", revision 1, dated March 19, 2009 (ML090900748).

The first document provided the refinement of the previous dose models and consolidated them into a single document.

The second document provided the final characterization study technical details.Enclosure I Page 3 of 11 Enclosure 1, Justification for Termination of Licenses The NRC Staff issued a Request for Additional Information by letter dated June 11, 2009 (ML091520480) regarding NASA's January 9, 2009 License Amendment application and March 20, 2009 submittal of documents.

NASA provided a formal response to the RAI by letter dated October 6, 2009 (ML092870784).

The NRC issued the requested license amendments by letter dated February 1, 2010 (ML100120679) that included the Staff Safety Evaluation Report. Amendment 14 to License TR-3 (ML100130129) and Amendment 10 to License R-93 (ML100130131) incorporated Condition 4 into both licenses that states, "Prior to termination of this license, NASA shall assess the residual activity in Plum Brook between the Plum Brook Station and Sandusky Bay and demonstrate that the area meets the radiological criteria for unrestricted use specified in 10 CFR 20.1402".The NRC Safety Evaluation Report stated in part, "The licensee approached the dose assessment of the Plum Brook sediments using several approaches that can be considered ALARA. The licensee used four different dose assessments that are representative of the geographical area. The staff has determined that the licensee applied these alternative pathways to capture reasonable activities that may take place near the Plum Brook.Although contaminants were detected at various depths within the sedimentation of the Pentolite Ditch and the Plum Brook, the licensee used appropriate values for the area and thickness in assessing the radiation dose from Plum Brook sediments.

In addition to these appropriate values, the licensee used the highest or most conservative concentration for Cs-137 and Co-60 for each of the dose scenarios.

This resulted in dose calculations that were still substantially below the regulatory limit of 25 mrem per year for the critical group. In addition, the licensee intends to further reduce the potential dose from radionuclides of PBRF origin in the Plum Brook by digging up isolated hot spots in sediment along the Plum Brook that has an activity above 13.34 pCi/g using hand tools. This activity level corresponds to the same level used upstream in the remediation of the Pentolite Ditch. This remediation will cover the area of the Plum Brook from the Plum Brook station fence-line to the wetlands, and the remediation will be performed during the summer, when the flow rate in the Plum Brook is typically lower and a larger area of stream bank is exposed In areas of the Plum Brook previously covered by characterization surveys, the locations to be remediated will be based on known GPS coordinates of elevated readings.

In the areas that were not previously surveyed (e.g., stream section 2), a 100 percent survey of the bank area will be performed using the same detector that was used during the previous characterization (i.e., Ludlum Model 2350-1 with 44-10 sodium iodide detector, and a gamma-spectrum window set to focus of Cs-137 activity) or an equivalent." NASA committed to perform additional radiological characterization of Plum Brook Section 2 sediments.

This commitment was reflected in the NRC Staff Safety Evaluation supporting NRC issuance of Amendment 14 to License TR-3 and Amendment 10 to License R-93 on February 1, 2010 (ML100120679).

The surveys were performed during July and August of 2010. The results were reported in Technical Basis Document PBRF-TBD 001, "Supplemental Radiological Characterization of Plum Brook Section 2", revision 0, Enclosure 1 Page 4 of II Enclosure 1, Justification for Termination of Licenses dated November 10, 2010. The report was submitted to the NRC by cover letter dated November 12, 2010 (ML103190708).

In order to assure that the ALARA criterion of 10 CFR 20, subpart E was met, NASA implemented a Work Execution Package (PBRF-WEP-10-007, "Plum Brook Remediation", revision 0, dated July 12, 2010, to perform the additional remediation described in the NRC Staff Safety Evaluation Report. Remediation activities, which were periodically observed and evaluated by NRC Region III Inspection Staff and representatives from the Ohio Department of Health, continued until September 13, 2010 when the Work Execution Package was closed. Localized spots of elevated activity were removed using basic hand tools. The soil and sediments were placed in 55-gallon drums and transported to a staging area at the reactor facility.

The contaminated soil and sediments were packaged with other waste materials for off-site disposal as Radioactive Waste.Based on the previous discussion, NASA has met the requirements of Condition 4 of Licenses TR-3 and R-93. NASA has assessed the residual activity in Plum Brook and the environmental areas along the banks of Plum Brook between the Plum Brook Station fence and Sandusky Bay. The assessment and follow-up remediation has satisfactorily demonstrated that the residual activity is within the limits for release for unrestricted use specified in 10 CFR 20, subpart E and is ALARA.III By letter dated October 27, 1976, NASA requested an amendment to Possession Only Licenses TR-3 and R-93 that would remove the Assembly Test and Storage (ATS) Building, the Reactor Office Building (ROB), the ATS Water Storage Tank, and the grounds adjacent to these structures from the Plum Brook Reactor Facility and the control of the Licenses allowing NASA to use the structures and grounds for other purposes.

A letter of clarification dated October 27, 1976 from NASA to the NRC stated that when the previously noted structures were removed from the Facility License control, the Reactor Facility fence would be relocated so that these structures would no longer be within the fenced facility.The NRC Issued Amendment 6 to License TR-3 by letter dated December 17, 1976. The amendment allowed revisions to the Technical Specifications and allowed removal of the listed structures and grounds from the licensed area after isolation of the structures from Reactor Facility systems and demonstration that the structures and grounds were free of licensed material.

The NRC followed with a letter dated February 3, 1977 that provided guidance on the decontamination and survey requirements necessary to release the subject areas for unrestricted use.By letter dated January 7, 1981, NASA reported to the NRC Staff that the required isolation of the subject facilities had been completed and decontamination and release surveys had been completed.

The letter included the Final Radiological Survey for Release of Buildings 1121, 1142, and Structure 1156 at the Plum Brook Reactor Facility, dated November 28, 1980. NASA stated "We believe that the survey results confirm the absence of reactor-originated radioactive material in excess of the limits specified in Amendment No. 6. In accordance with recent telephone conversations with your office, we plan to consider the Enclosure I Page 5 of II Enclosure 1, Justification for Termination of Licenses isolated area free from all Nuclear Regulatory Commission license constraints 30 days from the date of this letter".Based on the foregoing, NASA has demonstrated that those areas of the original Reactor Facility that were removed from control of the Licenses prior to commencement of the decommissioning project and were not addressed in the NRC approved Decommissioning Plan have been appropriately remediated with termination surveys that demonstrate adequate decontamination to a level acceptable to the NRC Staff and the staff regulatory guidance available at the time of completion.

IV NASA submitted a request for amendment to Licenses TR-3 and R-93 by letter dated December 17, 2004 (ML050470053).

The letter requested that the licenses be amended to incorporate the submitted Final Status Survey Plan as a supplement to the Safety Analysis Report and allow performance of Final Status Surveys. The existing Condition 3.A.3 of both licenses required that Licensee submit reports of any characterization surveys that were not part of the original decommissioning application and to submit the Final Status Survey Plan to the USNRC for review prior to performing Final Status Surveys. The letter included the"Supplemental Characterization Report for the Plum Brook Reactor Facility", dated December 16, 2004 (ML050470048), and the "Final Status Survey Plan for the Plum Brook Reactor Facility", revision 0, dated December 3, 2004 (ML050690309 and ML050690310)in fulfillment of License Condition 3.A.3.NASA submitted a request for amendment to Licenses TR-3 and R-93 by letter dated May 18, 2005 (ML051430356).

The amendments consisted of revised Technical Specifications for both licenses.

This was supplemented by a letter dated July 11, 2005 notifying the NRC that the decommissioning schedule would extend beyond the original date of December 31, 2007 to December 31, 2010 (ML051940437).

The License Amendment request was revised by NASA letter dated May 12, 2006,"Submittal of Revised Final Status Survey Plan and Revised Request for Amendment of Licenses TR-3 and R-93" (ML061390292).

The application included "Final Status Survey Plan for the Plum Brook Reactor Facility", revision 0, dated May 2006 (ML061390295 and ML061390297).

The revision to the Plan was based on additional characterization data obtained since the previous submittal.

NASA revised the previous amendment request again by letter dated January 10, 2007 (ML070170174).

This revision requested incorporation of changes to the Project Organization described in the Technical Specifications.

NASA submitted a revision to the proposed Final Status Survey Plan by letter dated February 9, 2007 (ML070450166).

The "Final Status Survey Plan for the Plum Brook Reactor Facility", revision 1, dated February 2007 (ML070450170 and ML070450171) was based on an expanded section 5.3 with a more detailed discussion of the Background Reference Areas.Enclosure 1 Page 6 of II Enclosure 1, Justification for Termination of Licenses The USNRC issued Amend 13 to License TR-3 and Amendment 9 to License R-93 by letter dated March 24, 2008 (ML073020308) and included a Staff Safety Evaluation Report (ML073020316).

The amendments incorporated revised Technical Specifications (ML073100974), Amendment 13 to License TR-3 (ML073100892), and Amendment 9 to License R-93 (ML073100897).

The amendments approved the Final Status Survey Plan and authorized performance of Final Status Surveys with the following section: "3. NASA is authorized to decommission the facility in accordance with the Decommissioning Plan for the Plum Brook Reactor Facility approved by the Commission by issuance of license amendment dated March 20, 2002, as revised pursuant to paragraph 3.A. 1 below, and to perform Final Status Surveys in accordance with the Final Status Survey Plan for the Plum Brook Reactor Facility submitted by letters dated May 12, 2006 and February 9, 2007 and revised purs uant to paragraph 3.A. 1 below.A. This amendment authorizes inclusion of the Decommissioning Plan for the Plum Brook Reactor Facility and the Final Status Survey Plan for the Plum Brook Reactor Facility and their supplements as supplements to the Safety Analysis Report pursuant to 10 CFR 50.82(b)(5).

1. The licensee may make changes to the above plans and revisions without prior U.S. Nuclear Regulatory Commission approval provided the proposed changes do not: a. Require Commission approval pursuant to 10 CFR 50.59;b. Reduce the coverage requirements for scan measurements;

c. Increase the derived concentration guideline level and related minimum detectable concentrations (for both scan and fixed measurement methods);d. Use a statistical test other than the Sign test or the Wilcoxon Rank Sum test for evaluation of the final status survey;e. Result in significant environmental impacts not previously reviewed;f Increase the radioactivity level, relative to the applicable derived concentration guideline level, at which an investigation occurs;g. Increase the Type I decision error;h. Decrease an area classification (i. e., impacted to unimpacted; Class I to Class 2; Class 2 to Class 3; Class I to Class 3)." Following issuance of the above license amendments, NASA began performing the terminal radiation surveys in accordance with the NRC approved Final Status Survey Plan for the Plum Brook Reactor Facility, revision 1 dated February 2007. Survey results were documented in the Final Status Survey Report which consisted of eighteen attachments which reported the survey results and evaluations of the results against the License Termination criteria.

Each attachment addressed a specific area of the facility.

The final section of the report was Report Main Body which summarized the results of the eighteen attachments and presented the basis for NASA's conclusions that the facility had been remediated to a level that would permit release for unrestricted use.Enclosure I Page 7 of II Enclosure 1, Justification for Termination of Licenses In addition to the above, NASA assessed the dose from residual contamination in ground water in Technical Basis Document PBRF-TBD-12-001, "Evaluation of Radionuclides in PBRF Groundwater and Surface Water ", revision 0, dated March 14, 2012 (ML121160080).

This document was submitted to the USNRC electronically on April 23, 2011.The following table lists the reports of the Final Status Surveys submitted to the USNRC with the NRC ADAMS System Accession Numbers for the reports and submittal letters: Table 2: Summary of Final Status Survey Report Submittals Final Status Survey Report Section Title, Date, Date of NRC ADAMS ACCESSION NUMBERS Revision Number Submittal to NRC Final Status Survey Report, Report Main Body, March 30, Transmittal Letter ML12095A156 Revision 0, dated March 30, 2012. 2012 Report Body ML12095AI56 Final Status Survey Report, Attachment 1, March 25, Transmittal Letter ML100880265 Reactor Office Laboratory Building, Revision 0, 2010 Report Body ML100880265 dated March 25, 2010.Report Appendices ML100880265 Final Status Survey Report, Attachment 1, October 28, Transmittal Letter ML103060324 Reactor Office Laboratory Building, Revision 1, 2010 Report Body ML103060323 dated October 25, 2010 (Revision 1 in response to NRC Staff Comments dated 10/27/10).

Report Appendices ML103060323 Final Status Survey Report, Attachment 2, May 4, 2010 Transmittal Letter ML101270331 Services Equipment Building, Revision 0, dated Report Body & ML101270329 May 4,2010. Appendix A Appendix B ML101270332 Final Status Survey Report, Attachment 2, October 28, Transmittal Letter ML103060324 Services Equipment Building, Revision 1, dated 2010 Report Body & ML103060331 October 25, 2010 (Revision I in response to NRC Appendix A Staff Comments dated 10/27/10).

Appendix B ML103080859 Final Status Survey Report, Attachment 3, Fan May 27, 2010 Transmittal Letter ML102030280 House, Revision 0, dated May 26, 2010. Report Body ML102030280 Report Appendices ML102030280 Final Status Survey Report, Attachment 3, Fan October 28, Transmittal Letter ML103060324 House, Revision 1, dated October 25, 2010 2010 Report Body ML103060333 (Revision I in response to NRC Staff Comments dated 10/27/10).

Report Appendices ML103060333 Final Status Survey Report, Attachment 4, August 26, Transmittal Letter ML102390408 Pentolite Ditch, Revision 0, dated August 25, 2010 Report Body ML102390408 2010.Report Appendices ML102390408 Final Status Survey Report, Attachment 5, Hot May 27, 2010 Transmittal Letter ML102030279 Retention Area, Revision 0, dated May 19, 2010. Report Body MLl02030279 I Report Appendices ML102030279 Enclosure I Page 8 of 11 Enclosure 1, Justification for Termination of Licenses Final Status Survey Report Section Title, Date, Date of NRCADAMSACCESSION NUMBERS Revision Number Submittal to INRCI Final Status Survey Report., Attachment 5, Hot October 28, Transmittal Letter ML103060324 Retention Area, Revision 1, dated October 25, 2010 Report Body ML103060329 2010 (Revision I in response to NRC Staff Comments dated 10/27/10).

Report Appendices ML103060329 Final Status Survey Report, Attachment 6, Waste September 13, Transmittal Letter ML102580334 Handling Building, Revision 0, dated September 2010 Report Body ML102580334 13, 2010.Report Appendices ML102580334 Final Status Survey Report, Attachment 6, Waste October 28, Transmittal Letter ML103060324 Handling Building, Revision 1, dated October 25, 2010 Report Body ML103060328 2010 (revision I in response to NRC Staff Comments dated 10/27/10).

Report Appendices ML103060328 Final Status Survey Report, Attachment 7, Storm March II, Transmittal Letter ML110740227 Drains, Pipe Trenches & Other Sub-Surface 2011 Report Body ML110740227 Excavations, Revision 0, dated March 10, 2011.Report Appendices ML110740227 Final Status Survey Report, Attachment 7, Storm April 5, 2012 Transmittal Letter ML12100Ai23 Drains, Pipe Trenches & Other Sub-Surface Report Body & ML12100AI24 Excavations, Revision 1, dated April 3, 2012 (Revision 1 in response to NRC Staff Comments Appendix A dated 12/22/11).

Appendices B & C ML12100AI26 Final Status Survey Report, Attachment 8, Hot July 19, 2011 Transmittal Letter ML11203A360 Laboratory, Revision 0, dated July 18, 2011. Report Body & ML11203A361 Appendix A Report Appendix B, ML11203A355 pages 1 -68 Appendix B, pages 69 -ML11203A357 147, Appendix C Final Status Survey Report, Attachment 8, Hot April 5, 2012 Transmittal Letter ML12100AI23 Laboratory, Revision 1, dated April 3, 2012 Report Body & ML12100A129 (Revision 1 in response to NRC Staff Comments Appendix A dated 12/22/11)Appendix B, pages 1- ML12100AI30 100 Appendix B, pages 101- ML12100A125 147, Appendices C & D Final Status Survey Report, Attachment 9, October 7, Transmittal Letter MLI 1286A071 Embedded Piping, Revision 0, dated October 6, 2011 Report Body ML11286A071 2011.Report Appendices MLI 1286A071 Final Status Survey Report, Attachment 9, April 5, 2012 Transmittal Letter ML12100A123 Embedded Piping, Revision 1, dated April 3, 2012 Report Body ML12100AI27 (Revision 1 in response to NRC Staff Comments dated 12/22/11).

Report Appendices ML12100A127 Enclosure I Page 9 of I1 Enclosure

1. Justification for Termination of Licenses Final Status Survey Report Section Title, Date, Date of NRCADAMSACCESSION NUMBERS Revision Number Submittal to[ NRC I I Final Status Survey Report, Attachment 10, August 29, Transmittal Letter ML11243A183 Emergency Retention Basin, Revision 0, dated 2011 Report Body ML11243A183 August 29, 2011.Report Appendices MLI 1243A183 Final Status Survey Report, Attachment 11, September 15, Transmittal Letter ML11262A287 Reactor Containment Vessel, Revision 0, dated 2011 Report Body & ML11262A285 September 25, 2011. Appendix A Appendix B ML I 1262A286 Final Status Survey Report, Attachment 12, January 25, Transmittal Letter ML12030A231 Reactor Building, Revision 0, dated January 24, 2012 Report Body & ML12030A229 2012. Appendix A Appendices B, pages 1 -MLL12030A230 93 Appendix B, pages 94 -ML12030A232 150, Appendices C and D Final Status Survey Report, Attachment 13, August 11, Transmittal Letter ML11228A024 Primary Pump House, Revision 0, dated August 2011 Report Body MLI 1228A024 11, 2011.Report Appendices ML11228A024 Final Status Survey Report, Attachment 13, January 18, Transmittal Letter ML12020A100 Primary Pump House, Revision 1, dated January 2012 Report Body & ML12020A096 4, 2012 (Revision 1 in response to NRC Staff Appendix A Comments dated 12/22/11).

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_________Appendix B ML12020A097 Final Status Survey Report, Attachment 14, March 6, 2012 Transmittal Letter ML12068A261 Transport Roadways and Parking Lots, Revision Report Body ML12068A261 0, dated March 6, 2012.0,_ dated March6,2012.Report Appendices ML12068A261 Final Status Survey Report, Attachment 15, January 23, Transmittal Letter ML12025A128 Miscellaneous Structures and Pads, Revision 0, 2012 Report Body & ML12025AI26 dated January 19, 2012. Appendix A, pages 1 -15 Appendix A, pages 16 -ML12025A127 27, Appendices B & C Final Status Survey Report, Attachment 16, Open February 23, Transmittal Letter ML12065A214 Land Areas within Restricted Area and Outside 2012 Report Body ML12065A334 Buffer Area, Revision 0, dated February 23, 2012.Report Appendices ML12065A334 Final Status Survey Report, Attachment 17, March 29, Transmittal Letter MLL12090A600 Buried and Miscellaneous Piping, Revision 0, 2012 Report Body ML12090A600 dated March 29, 2012.Report Appendices MLI 2090A600 Final Status Survey Report, Attachment 17, July 13, 2012 Transmittal Letter ML12201AI 11 Buried and Miscellaneous Piping, Revision 1, Report Body ML12201AI 11 dated July 16, 2012 (Revision I in response to NRC Staff Comments dated 05/01/12).

1 Report Appendices MLI2201AI II Enclosure I Page 10 of I1 I Enclosure 1, Justification for Termination of Licenses Final Status Survey Report Section Title, Date, Date of NRC ADAMS ACCESSION NUMBERS Revision Number Submittal to I NRC II Final Status Survey Report, Attachment 18, February 23, Transmittal Letter ML12059A333 Excavated and Backfill Materials, Revision 0, 2012 Report Body ML12059A365 Report Appendices ML12059A365 Each of the Final Status Survey Report sections included a discussion providing a technical justification and basis that remediation of each affected area had been performed to a level that is As Low As Reasonably Achievable.

Based on the documentation listed above, National Aeronautics and Space Administration has completed the terminal radiation surveys and submitted the associated documentation for NRC review. The survey documents support our conclusion that the facility and site are suitable for release in accordance with the criteria for decommissioning in 10 CFR part 20, subpart E. The site should be considered acceptable for unrestricted use. NASA has demonstrated that the residual radioactivity that is distinguishable from background radiation results in a Total Effective Dose Equivalent to an average member of the critical group that does not exceed 25 mrem (0.25 mSv) per year, including that from groundwater sources of drinking water, and the residual radioactivity has been reduced to levels that are as low as reasonably achievable (ALARA).The foregoing discussion describes the actions taken by National Aeronautics and Space Administration to remediate and decommission the Plum Brook Reactor Facility.

The actions taken have successfully achieved the license termination goals and the reports submitted to the NRC Staff provide documentary evidence that the facility and surrounding areas meet the criteria for release for unrestricted use stipulated in 10 CFR 20.1402. All associated license conditions necessary to terminate the licenses have been satisfied.

All radioactive materials have been removed such that any remaining residual radioactivity is within the limits of 10 CFR Part 20, subpart E and is As Low As Reasonably Achievable (ALARA). All licensed materials have been disposed at or transferred to appropriately licensed facilities in accordance with the NRC regulatory requirements.

Enclosure I Page 11 of 11