ML24085A790
| ML24085A790 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/28/2024 |
| From: | Marlayna Vaaler Doell Reactor Decommissioning Branch |
| To: | Dostal J Oyster Creek Environmental Protection |
| References | |
| Download: ML24085A790 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Jeffrey P. Dostal Site Vice President Oyster Creek Nuclear Generating Station 741 Route 9 South Forked River, NJ 08731
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - PREAPPLICATION READINESS ASSESSMENT OF THE LICENSE TERMINATION PLAN
Dear Jeff Dostal:
By letters dated February 2, 2024, and March 21, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML24033A327 and ML24081A288, respectively), Holtec Decommissioning International, LLC (HDI) requested that the U.S. Nuclear Regulatory Commission (NRC) staff provide feedback on specific topics related to the draft License Termination Plan (LTP) for the Oyster Creek Nuclear Generating Station (OCNGS).
The NRC, through discussions with HDI, has determined that it would be appropriate to conduct a preapplication readiness assessment (hereinafter readiness assessment) in support of HDIs recent requests as part of the preapplication interactions on the OCNGS LTP draft application.
The readiness assessment is not part of the NRCs official acceptance review process. The readiness assessment of the OCNGS LTP application will allow the NRC staff to understand the level of detail in the draft application and identify any major issues or information gaps between the draft application and the technical content required to be included in the application submitted to the NRC. Therefore, the observations from the readiness assessment do not predetermine whether the application will be docketed. The attached readiness assessment plan provides the details and logistics of the upcoming readiness assessment activities. March 28, 2024 In accordance with 10 CFR 2.390 of the NRCs Agency Rules of Practice and Procedure, 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.
If you have any questions concerning this matter or the upcoming readiness assessment, please contact me at (301) 415-3178 or via e-mail at Marlayna.Doell@nrc.gov.
Sincerely, Marlayna V. Doell, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket Nos.: 50-219 and 72-15 License No.: DPR-16
Attachment:
Readiness Assessment Plan cc w/attachment: Oyster Creek ListServ Signed by Doell, Marlayna on 03/28/24
OYSTER CREEK NUCLEAR GENERATING STATION PREAPPLICATION READINESS ASSESSMENT OF THE LICENSE TERMINATION PLAN
Docket No. 50-219
LOCATION
The NRC plans to conduct a virtual readiness assessment review of the OCNGS LTP draft information from April 2-3, 2024. The virtual review will take place at the NRC offices leveraging a secure portal to review the information provided by HDI.
PURPOSE
The Holtec Decommissioning International, LLC (HDI) has voluntarily agreed to engage with the NRC staff in a preapplication readiness assessment (hereinafter readiness assessment) of the Oyster Creek Nuclear Generating Station (OCNGS) draft license termination plan application before the application is submitted for a formal U.S. Nuclear Regulatory Commission (NRC) review. The preapplication readiness assessment will allow the NRC staff to (1) identify information gaps between the draft OCNGS LTP information and the technical content required in the application submitted to the NRC, (2) identify major technical or policy issues that may adversely impact the docketing or technical review of the application, and (3) become familiar with the application, particularly in areas where HDI is proposing new concepts or novel decommissioning approaches. The observations from the readiness assessment process will inform HDI in finalizing the OCNGS LTP application and also will assist the NRC staff in planning NRC resources in preparation for the review once the application is formally submitted.
BACKGROUND
This request is a part of ongoing pre-submittal interactions between the NRC and HDI related to submission of the OCNGS LTP, which is anticipated to be formally provided to the NRC in April 2024. Previous preapplication activities, including two onsite audits, are documented in memos dated October 17, 2022 (ML22290A057), and December 20, 2023 (ML23324A433). The NRC, through discussions with HDI, has determined that it would be appropriate to conduct a readiness assessment in support of HDIs recent requests as part of the preapplication interactions on the OCNGS LTP draft application.
SCOPE OF THE READINESS ASSESSMENT
The NRC staff will use the acceptance criteria contained in NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, Revision 2 (ML18116A124), and the readiness assessment review approach outlined in LIC-116, Preapplication Readiness Assessment (ML20104B698), to determine whether the OCNGS LTP information provided to date appears sufficient to meet the NRCs acceptance standards.
The readiness assessment of the OCNGS LTP draft application will focus on the major areas identified from past reviews of applications to be challenging review areas. Specific areas where the NRC staff plans to focus its review and provide feedback include:
- overall final status survey design and related activities
- deselection of certain radionuclides from the initial suite for the OCNGS site
- use of surrogate ratios for certain hard to detect radionuclides
Attachment
- volumetric contamination considerations, including in concrete
- the approach and criteria used to address excavation survey units
- subsurface soil characterization and continuing characterization plans
- the approach to address discrete radioactive particles and elevated measurement areas
- the dose compliance scenario selected for OCNGS and its alternatives
- multiple lines of support for elimination of groundwater exposure pathways
- development of derived concentration guideline levels (DCGLs)
Several of these areas are anticipated to be addressed in detail during the formal OCNGS LTP review process, but the opportunity to provide a readiness assessment of this information will help ensure the NRC staff has a clearer understanding of the application when it is submitted.
INFORMATION NECESSARY FOR THE READINESS ASSESSMENT
As previously discussed with HDI, the following should be available as needed to support the readiness assessment: full copies of the draft application, all supporting topical reports, all major supporting technical reports, examples of important calculations, and staff who can answer questions related to these documents.
READINESS ASSESSMENT TEAM
The following table shows the technical review areas and the responsible technical staff.
Review Area Reviewer Design and planning for the final status Kathryn Robertson-DeMers survey (FSS) of the OCNGS site Approach for addressing compliance with the Cynthia Barr radiological criteria for license termination Hydrogeological and groundwater Randall Fedors considerations for decommissioning
LOGISTICS
The readiness assessment will take place virtually. It is scheduled to begin on April 2, 2024, and conclude on April 3, 2024. Daily debriefings will take place as needed. The NRC technical staff will charge time to the following fee-billable cost activity code number: 000083/05000219/
L-2022-LRM-0056 - Oyster Creek - LTP Pre-Submittal Activities.
READINESS ASSESSMENT OBSERVATIONS
The NRC will send the readiness assessment observations, including any identified technical concerns or major information gaps, to HDI in a publicly available report that will also summarize the scope of the readiness assessment. The NRC staffs expectation is that HDI will consider the observations from the readiness assessment while finalizing the OCNGS LTP application and will reevaluate the application submission date based on its evaluation of the time to address the readiness assessment observations.
REFERENCES
- 1. NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License Termination Plans, Revision 2 (ML18116A124).
- 2. NUREG-1757, Volume 2, Consolidated Decommissioning Guidance: Characterization, Survey, and Determination of Radiological Criteria - Final Report, Revision 2 (ML22194A859).
- 3. NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), Revision 1 (ML003761445 and ML003761454).
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