ML25027A011
| ML25027A011 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/2025 |
| From: | Robertson-Demers K Reactor Decommissioning Branch |
| To: | Shaun Anderson Reactor Decommissioning Branch |
| References | |
| Download: ML25027A011 (1) | |
Text
MEMORANDUM TO:
Shaun Anderson, Branch Chief Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards FROM:
Kathryn Robertson-DeMers Health Physicist Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF JANUARY 15, 2025, DECOMMISSIONING LESSONS LEARNED PUBLIC MEETING WORKSHOP WITH INDUSTRY DECOMMISSIONING LICENSEES On January 15, 2025, a hybrid public meeting was held at the U.S. Nuclear Regulatory Commission (NRC) with industry decommissioning licensees to discuss lessons learned from recent license termination plan (LTP) submittals and decommissioning projects. The objective of the meeting was to share good practices and lessons learned to improve the overall decommissioning process when transitioning from operations to decommissioning to license termination. In this public meeting, presentations were made by NRC staff, Nuclear Energy Institute (NEI), the Electric Power Research Institute (EPRI), Holtec Decommissioning International (HDI), Omaha Public Power District (OPPD), the Department of Transportation/Maritime Administration (MARAD), Northstar, Energy Solutions, and Southern California Edison.
The meeting notice and agenda, posted December 12, 2024, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML24347A022 and are posted on the NRCs public Web page at http://www.nrc.gov/reading-rm/adams.html. The NRC staff and licensee presentation material are available on the meeting notice. Persons who do not have access to ADAMS or who encounter problems in accessing the meeting materials located in ADAMS should contact the NRC Public Document Room reference staff by telephone at 1-800-397-4209 or by email to PDR.Resource@nrc.gov.
During the meeting, the NRC staff delivered seven presentations: (1) NRC Perspectives on Decommissioning Lessons Learned: Historical and Future Perspectives, (2) Consultation Under Section 106 of the National Historic Preservation Act During Decommissioning:
CONTACT:
Kathryn Robertson-DeMers, NMSS/DUWP 301-415-5793 February 3, 2025 Signed by Robertson-DeMers, Kathryn on 02/03/25
S. Anderson Lessons Learned and Best Practices, (3) Status of NRC ISG on MRCs and RDFAWG Completion, (4) DUWP-ISG-03 Contamination Control, Radiological Survey, and Dose Modeling Considerations to Support License Termination at Sites with Environmental Discrete Radioactive Particle Contamination, (5) NRC Guidance Updates, (6) Site Characterization Lessons Learned, and (7) Inspection Activities.
Industry emphasized the importance of benchmarking research throughout the industry, bringing in experienced companies as a method of gaining insight and expertise, and applying lessons learned from previous decommissioning projects to subsequent projects. Licensees mentioned the importance of maintaining a good safety culture and engaging workers in all phases, which leads to innovation and ensuring work is conducted safely. Oyster Creek conducted removal of control rod guide tubes from the vessel versus normal under-vessel disconnects resulting in substantial dose reduction to workers. Immediate approaches included transferring the nuclear fuel to dry storage, removing environmental hazards, and fire prevention decreasing the overall risk to workers.
Industry shared innovative approaches to eliminating or managing hazards with engineering solutions. Vermont Yankee found bringing equipment into the building and demolishing the building from the top down was the safest approach. Lateral loading in the structure was addressed by filling adjacent rooms to the Reactor Building with the plan to empty the rooms prior to final status survey.
Industry shared their approach to demolition of structures beginning with a surgical demolition of materials based on radiological characteristics and then moving to open air demolition. When removing the reactor vessel, Fort Calhoun Station initially underestimated the friction and found that using a second lift allowed them to break the vessel free, which subsequently allowed them to remove the reactor vessel. The steam generators were removed intact and size reduced at another structure.
Three Mile Island (TMI) Unit 2 has unique challenges with radiation distributed throughout the Reactor Building and portions of the Auxiliary and Fuel Handling Buildings. The licensee established a planning and preparation program, which includes performing mock-up of activities, procuring and training on specialized equipment, and the creation of a Robotics, Instrumentation, Systems, and Tooling Committee to investigate new technologies and ways of conducting chemical decontamination. Active training programs are underway concerning the unique radiological conditions and remote operation of robotic tools necessary to conduct the work.
Industry shared the keys to their success are effective contamination control programs.
Containment structures and ventilation can be used as a controlled environment to manage materials going into and out of containment for contamination control. Fort Calhoun Station also established designated haul paths for radioactive waste that are monitored following shipments.
When size reducing bulk material, they have implemented methods for segregation and control of small highly radioactivity pieces.
The Department of Transportation, Maritime Administration discussed the importance of getting the MARAD Contracting Officer involved as a part of benchmarking and planning to enable design of contract vehicles in conjunction with procedures and programs. Organization structure combined with roles and responsibilities ensured MARAD was fully involved in all project matters, and strong open two-way communication within the project was maintained. MARAD is
S. Anderson actively seeking preservation of the NS Savannah consistent with its designation as a National Historic Landmark.
Industry discussed engagement with the stakeholders to improve confidence in the decommissioning process, which has been successfully implemented across the country.
Licensees have engaged with the stakeholders through Community Engagement Panels/Citizen Advisory Panels, public announcements, community speaking engagements, facility tours, and interaction with state agencies.
There is a path forward for major reactor component (MRC) disposal with the issuance of the NRC interim staff guidance on the use of decommissioning trust funds during these operations.
The Reactor Decommissioning Financial Assurance Working Group (RDFAWG) published a report in 2020 (ML20121A188) evaluating the existing decommissioning financial assurance program and identifying potential enhancements to improve the efficiency, effectiveness, and transparency of the program. Industry shared when decommissioning multiple units simultaneously, work must be closely tracked to ensure proper correlation to the appropriate fund and compliance with the 10 CFR 50.2 definition of decommissioning. NRC staff also discussed lessons learned and best practices associated with Section 106 of the National Historical Preservation Act.
From May 2023 through December 2024, inspectors continued to see issues with radiation protection, transportation, fire protection, decommissioning trust funds usage, discouraging language in disclosure agreements, and industrial safety. San Onofre Nuclear Generation Station shared lessons learned from their two Severity Level IV non-cited violations involving shipment of a pressurizer for disposal, and the comprehensive actions taken to mitigate the situation. They emphasized the importance of verifying critical assumptions. A solid quality assurance program mitigates many transportation and other issues. Based on licensee experience, proactive reporting of low-level issues to regulators and communication with the public promotes confidence in the decommissioning project.
In the Electric Power Research Institute (EPRI) and the United States, there are challenges with locating construction crafts and training personnel new to the nuclear industry and decommissioning of nuclear facilities with its unique safety culture. Other areas require highly skilled technical staff (e.g., technical experts and technicians familiar with final status survey) during the license termination process. PreussenElektra is applying a fleet approach by using similar contractors that travel from one site to the next allowing transfer of lessoned learned, knowledge, and techniques, and shortening decommissioning duration and reducing operational costs. Where conducting first of kind operations, EPRI recommended working with the regulator early and anticipate regulatory challenges. An effort to capture the institutional knowledge from existing decommissioning sites is needed to support future decommissioning efforts, which may be years into the future.
European nuclear power plants have found that decontamination and characterization of buildings are critical to the recycling efforts, reduction of radioactive waste volume and associated costs, and the clearance of structures prior to demolition. Additionally, TMI Unit 2 reiterated the importance of early site characterization to define waste requirements and provide input to license termination plan development. Continuing characterization ensures the most up-to-date radiological information is available.
There were several areas for improvement noted by the NRC staff and industry concerning the license termination process and license termination submittals. The recently submitted
S. Anderson NEI 22-01, License Termination Process, was developed to institutionalize the license termination process and capture good practices proven acceptable to NRC staff. Industry proposed a phased submittal of license termination plans, which is under consideration by NRC staff. NRC staff discussed expectations for site characterization and defining risk significant dose modeling parameters and pointed industry to new guidance, which provides clarification on discrete radioactive particles, continuously collected data, and radiological surveys and dose modeling for land subsurfaces. Both industry and NRC staff agreed that during the license termination plan development process, site visits and engagement between the licensees and the reviewers improve the understanding of both the parties.
One member of the public inquired about major radioactive component (MRC) funding requests from the decontamination and decommissioning fund and available documentation related to applications and exemptions. The exemption request and approval package for PSEG Nuclear, LLC are found in the following:
Request for Exemptions from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) and Proposed Amendment to the Decommissioning Trust Agreement (ML24150A003)
Hope Creek Generating Station, Salem Generating Station, Units 1 & 2, and Peach Bottom Atomic Station, Units 2 & 3 - Exemption from the Requirements of 10 CFR Part 50, Sections 50.82(a)(8)(1)(A) and 50.75(h)(1)(iv) (ML24324A335)
The exemption request submitted by Entergy Operations, Inc. is currently under review:
Arkansas Nuclear One, Units 1 & 2 - Request for Exemptions from 10 CFR 50.82(a)(8)(i) and (ii) for use of Nuclear Decommissioning Trust Funds for Disposal of Major Radioactive Components During Operations (ML24318C273)
A second member of the public asked about the specific steps NRC staff is taking in response to failures by licensees to control airborne radioactivity, implement adequate controls in alpha level 3A areas, and prevent unauthorized access to locked high radiation areas. Staff responded by informing the individual that the licensee is responsible for documenting failures in the radiation protection program as a part of their Corrective Action Program and determining corrective actions. NRC Inspectors review these corrective actions and continued compliance with regulations.
Approximately 170 representatives from industry, state and federal government, international agencies, NRC and the public participated in the meeting. A list of the meeting attendees is enclosed. No public meeting feedback forms were received. No regulatory decisions were made during this meeting. Please direct any inquiries to me at (301) 415-5793 or Kathryn.Robertson-DeMers@nrc.gov.
Enclosure:
List of Attendees
S. Anderson
SUBJECT:
SUMMARY
OF JANUARY 15, 2025, DECOMMISSIONING LESSONS LEARNED PUBLIC MEETING WORKSHOP WITH INDUSTRY DECOMMISSIONING LICENSEES DATE February 3, 2025 DISTRIBUTION:
Public RidsOpa Mail Resource BWatson, NMSS ETorres, OEDO ADAMS Accession Number: ML25027A011 OFFICE NMSS/DUWP/RDB/
HP NMSS/DUWP/SA NMSS/DUWP/RDB
/BC NMSS/DUWP/RDB/
HP NAME KRobertson-DeMers BWatson SAnderson KRobertson-DeMers DATE 1/27/2025 1/27/2025 1/31/2025 2/3/2025 OFFICIAL RECORD COPY
Enclosure LIST OF ATTENDEES JANUARY 15, 2025, DECOMMISSIONING LESSONS LEARNED PUBLIC MEETING WORKSHOP WITH INDUSTRY DECOMMISSIONING LICENSEES Name1 Organization Adam Schwartzman U.S. Nuclear Regulatory Commission (NRC)
Alec Hillier NRC Amy Snyder NRC Andrew Taverna NRC Angela Coggins NRC Beau Goldstein NRC Bill Lin NRC Bill Von Till NRC Boby Abu-eid NRC Bruce Watson NRC Celimar Valentin-Rodriguez NRC Chris Allen NRC Chris McKenney NRC Christian Dennes NRC Christianne Ridge NRC Cynthia Barr NRC David Hills NRC Douglas Mandeville NRC Duane White NRC Elise Eve NRC Emil Tabakov NRC Emma Duncan NRC Fred Miller NRC Gehan Flanders NRC George Alexander NRC Gianni Nelson NRC Gregory Chapman NRC Harry Felsher NRC Jack Parrott NRC Jackson Barth NRC James Smith NRC Jane Marshall NRC Jen Whitman NRC Jennifer Davis NRC Jennifer Gutierrez NRC Name1 Organization Jessica Moses-Arnone NRC Karen Pinkston NRC Katherine Warner NRC Kathryn Robertson-DeMers NRC Kenneth Kline NRC Kevin Hayes NRC Kosmas Lois NRC Lifeng Guo NRC Linda Gersey NRC Lisa Dimmick NRC Lisa Pope NRC Marlayna Doell NRC Martha Poston-Brown NRC Matthew Learn NRC Michael LaFranzo NRC Michelle Rome NRC Nachiketh Chandran NRC Nate Fuguet NRC Nick Eckhoff NRC Patricia Jehle NRC Randy Fedors NRC Richard Turtil NRC Riley Maynard NRC Rob Evans NRC Robert Sun NRC Ron Linton NRC Ron Rolph NRC Shaun Anderson NRC Shawn Harwell NRC Stacey Imboden NRC Stephanie Anderson NRC Steve McCarthy NRC Tanya Hood NRC Tiffany Rushing NRC Travis Jones NRC Steven Mannon AECOM Lawrence E. Boing Argonne National Laboratory Claude Wiblin Chesapeake Nuclear Services, Inc.
J. Stewart Bland Chesapeake Nuclear Services, Inc.
Hannah E. Pell Constellation Jeff Dunlap Constellation Kenneth M. Nicely Constellation Amanda Anderson Department of Energy Angela Wofford Department of Energy Name1 Organization Joseph DeMers Department of Energy Mike Stewart Department of Energy Tom Carver Department of Energy Bradly J McMahon Dominion Energy Douglas B Moss DTE Energy Manuel Leal Gonzalez Endesa Martin Brandauer Energy Power Research Institute Rich McGrath Energy Power Research Institute Amy Hazelhoff Energy Solutions Barb Dotson Energy Solutions Joe Lynch Energy Solutions Mike Carpenter Energy Solutions Richard McIntosh Energy Solutions Robert F. Yetter Energy Solutions Tim Devik Energy Solutions Lori Glander Entergy Nuclear Michael Callahan Government Strategies Incorporated Gordon Madison Holtec Kristin Maddalo Holtec Mark Lawson Holtec Matthew Johnson Holtec William Noval Holtec Daniel J. Shannon Kewaunee Solutions Rick Adams Kewaunee Solutions Tom Schneider Kewaunee Solutions J. Blackburn NR Naval Reactors-08R Bryant Akins Northstar Corey Daniels Northstar John Jernigan Northstar Marshall Blake Northstar Bruce Montgomery Nuclear Energy Institute John Osborne Nuclear Ship Savannah Ben Pearson Omaha Public Power District Daniel R. Whisler Omaha Public Power District Randy Hugenroth Omaha Public Power District Timothy S. Uehling Omaha Public Power District John Mayer Orano Larry McDougal Orano Ricky Furr Orano Sebastien Guillot Orano Al Bates Pacific Gas and Electric George, Dylan Pacific Gas and Electric Coley Chappell PSEG Nuclear Eric Darois Radiation Safety and Control Services Name1 Organization Krista Torda Radiation Safety and Control Services Marc Cyr Radiation Safety and Control Services Susan Strachan San Luis Obispo County Thomas Magnette Severn Nuclear Services Chad A Samples Southern California Edison Mark E Morgan Southern California Edison William H. Barley Southern California Edison Erhard Koehler U.S. Department of Transportation, Maritime Administration Steve Magill Urenco Jim Nuccio Westinghouse Maria Ines De Miguel Martinez Westinghouse Francisco Javier Castillo Tortosa Consejo de Seguridad Nuclear Inmaculada Simón Consejo de Seguridad Nuclear Juan Gonzalez Cadelo Consejo de Seguridad Nuclear Paloma Ozores Diez Consejo de Seguridad Nuclear Sofia Luque Heredia Consejo de Seguridad Nuclear Solis Sanz Susana Consejo de Seguridad Nuclear Boris Brendebach German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV)
Uwe Büttner German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV)
Alicia Gonzalez Fernandez-Conde Iberdrola Elvira Blazquez Arroyo Iberdrola Eva Salas Sanchez Iberdrola Lorea Aresti Allende Iberdrola Susana Gutierrez Martinez Iberdrola Haiyong Jung Korea Institute of Nuclear Safety Raúl Munoz Foro Nuclear RJ Public Rafael Garcia-Bermejo Public Josie Piccone Public Holly Eve Public Jana Bergman Public James Byrne Public Joe Carignan Public Ed Goetchius Public Bill Horin Public Michael Empey Public Timothy P. Matthews Public Clifford Chapin Public Veena Gubbi Public Name1 Organization Mark Kirshe Public Rita Macdonald Public Joy Jiang Public John Egdorf Public 1 An additional four individuals participated by phone without identifying their organization.