NUREG-1757 Volume 2, Rev 2 Guidance Updates October 11 2022 Information Meeting
| ML22292A227 | |
| Person / Time | |
|---|---|
| Issue date: | 10/24/2022 |
| From: | Cynthia Barr NRC/NMSS/DDUWP/RTAB |
| To: | Chris Mckenney NRC/NMSS/DDUWP/RTAB |
| Barr C, 30-415-4015 | |
| Shared Package | |
| ML22291A443 | List: |
| References | |
| NUREG-1757 V2 R2 | |
| Download: ML22292A227 (4) | |
Text
October 24, 2022 MEMORANDUM TO: Christepher A. McKenney, Chief Risk and Technical Analysis Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards Signed by Barr, Cynthia FROM: Cynthia S. Barr, Senior Risk Analyst on 10/24/22 Risk and Technical Analysis Branch Division of Decommissioning, Uranium Recovery, and Waste Programs Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF OCTOBER 11, 2022, HYBRID INFORMATION MEETING ON NUREG-1757, VOLUME 2, REV. 2, GUIDANCE UPDATES On October 11, 2022, the U.S. Nuclear Regulatory Commission (NRC) held a hybrid public meeting in-person and via Teams to provide information on the final NUREG-1757, Volume 2, Revision 2, Consolidated Decommissioning Guidance, Characterization, Survey, and Determination of Radiological Criteria, guidance revisions. The meeting was noticed on the NRCs public website at the NRCs Agencywide Documents Access and Management System (ADAMS) at Accession No. ML22283A020. The NRC staffs presentation is available in ADAMS at Accession No. ML22280A041. NRC staff presented information on (i) changes that were made to Revision 2 of the guidance document, (ii) significant comments received on the draft document and how they were addressed in the final document, and (iii) continuing guidance updates and code development initiatives.
Approximately 35 people participated in the public meeting including industry representatives, state representatives, and NRC staff. After NRC staffs presentation, the Nuclear Energy Institute (NEI) provided a presentation on NEI 22-01, License Termination Process, which was described as providing how to guidance on how to navigate the license termination process specific to nuclear reactor licensees. The NEIs presentation is available in ADAMS at Accession No. ML22291A444.
NEI would like to meet with NRC in mid-November 2022 in a pre-submittal meeting and requested NRC to provide input on the types of information it would like to see to facilitate the review and approval of NEI 22-01 in 2023.
CONTACT: Cynthia S. Barr, NMSS/DUWP/RTAB (301) 415-4015
C. McKenney 2 A Question-and-Answer period was conducted after NRC staff and NEI presentations. A summary of the questions and comments discussed in the meeting is listed below:
Several questions were raised regarding new guidance on the possible need for additional site-specific support for risk-significant distribution coefficients (or Kds) including the following:
- i. What constitutes a significant or insignificant contribution to dose when determining the need for site-specific support for the parameter value?
ii. What is the pedigree of data provided in Argonne National Laboratorys Data Collection Handbook (can any of the parameter distributions be relied on)?
iii. When is experimental support versus other types of site-specific support needed to support the parameter value?
iv. Do license termination plans submitted prior to issuance of the final Revision 2 to NUREG-1757, Volume 2, need to be revised to address the change in guidance?
NRC responded that the issue with use of literature values for Kds is that data available to develop the parameter distributions could be based on (i) sparse data, or (ii) reflect a range of sites with 25th or 75th percentile values not necessarily being with the range of values for any particular site. Additional information in the form of site-specific information on soil/mineral types, groundwater chemistry and quality could be used to support the parameter values if the parameter is found to be risk-significant and sufficient information is available in the literature to support the parameter value for a particular set of site-specific conditions (i.e., site-specific field or laboratory experiments are not always needed to support the site-specific parameter value even if found to be risk-significant). Radionuclides contributing less than 10 percent of the dose standard are considered insignificant and additional support for these radionuclides would not be required. Depending on the radionuclides of concern and the importance of the parameter value to dose, a graded approach will be used to determine the need for additional site-specific support. Licensees should work with NRC reviewers early in the process to determine the need for additional site-specific support for risk-significant parameters such as Kd. Finally, NRC staff also plans to evaluate information available in the literature for distribution coefficients for radionuclides of concern typical for reactor licensees in its interim staff guidance for subsurface (typically only a few radionuclides dominate the dose for reactor sites and the uncertainty in Kd values for those radionuclides may be low or well understood limiting the need for experimental support).
A comment was made on the need for interim staff guidance on subsurface investigations to address contaminated bedrock.
A comment was made on the need for research efforts to consider different types of technological advancements for continuously collected data.
A comment was made on the compounding conservatisms in survey and dose modeling efforts to support license termination (e.g., resident farmer scenario, surrogate ratios).
A comment was made supporting the flexibility in allowing reactor licensees to find large construction projects that could bring reactor basement substructures to the surface less likely but plausible or implausible.
A question was raised in chat about NRCs experience with buried residual radioactivity and how it behaves including case studies, and site data. NRC responded in chat that it has experience with buried residual radioactivity at decommissioning sites (e.g., West Valley Demonstration Project and USDA Beltsville), as well as low-level waste disposal facilities, waste-incidental-to-reprocessing sites, and uranium recovery sites.
A question was raised about the schedule for completion of NUREG-1757, Volume 1, Rev. 3. NRC responded that due to higher priority items the draft NUREG is now expected to be issued for public comment the end of CY2023.
Enclosure:
List of Attendees
List of Attendees Industry, State and Other Participants Bruce Montgomery (in-person) NEI Gerry van Noordennen (in-person) Energy Solutions Jana Bergman Curtis Wright Bill Barley PGE Eric Darois Radiation Safety and Control Services Ed Everett NEI Jean Fleming Holtec Rich McGrath EPRI Sarah Roberts Energy Solutions Jane Schlueter American Nuclear Michael Smith NEI Karen Tuccillo New Jersey Department of Environmental Protection Jenny Goodman New Jersey Department of Environmental Protection James McCullough New Jersey Department of Environmental Protection Paul Schwartz New Jersey Department of Environmental Protection Jerry Bingaman State of Tennessee Roger Fenner State of Tennessee Josie Piccone Participating NRC Staff Shaun Anderson (in-person)
Cynthia Barr (in-person)
David Esh (in-person)
Randall Fedors Brett Klukan (in-person)
Michael LaFranzo Sarah Lopas (in-person)
Chris McKenney (in-person)
Leah Parks Ashley Roberts (in-person)
Adam Schwartzman (in-person)
Other NRC Staff Louis Caponi Kim Conway Tanya Hood (in-person)
Adam Lee Kerstun Norman ENCLOSURE
ML22291A443; Memo ML22292A227 NMSS/DUWP NMSS/DUWP OFFICE NMSS/DUWP/RDB NMSS/DUWP/RTAB
/RTAB /RTAB NAME CBarr CB SAnderson SA CMcKenney CM CBarr CB DATE Oct 19, 2022 Oct 21, 2022 Oct 21, 2022 Oct 24, 2022