Information Notice 2024-01, Minimization and Control of Contamination Involving Discrete Radioactive Particles at Decommissioning Facilities: Difference between revisions

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OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS


WASHINGTON, DC 20555-0001
WASHINGTON, DC 20555-0001  


February 9,                                 2024
February 9, 2024  


NRC INFORMATION NOTICE 2024         -01:                                           MINIMIZATION AND CONTROL OF
NRC INFORMATION NOTICE 2024-01: MINIMIZATION AND CONTROL OF


CONTAMINATION INVOLVING DISCRETE
CONTAMINATION INVOLVING DISCRETE
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All holders of and applicants for an operating license or construction permit for a nuclear power
All holders of and applicants for an operating license or construction permit for a nuclear power


reactor issued under Title 10 of the Code of Federal Regulations                                                     (10 CFR) Part           50, Domestic
reactor issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic


Licensing of P          roduction and Utilization Facilities, including those that have permanently ceased
Licensing of Production and Utilization Facilities, including those that have permanently ceased


operations and certified that fuel has been permanently removed from the reactor vessel.
operations and certified that fuel has been permanently removed from the reactor vessel.
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All holders of and applicants for a power reactor combined license, standard design approval, or
All holders of and applicants for a power reactor combined license, standard design approval, or


manufacturing license under 10         CFR                             Part 52, Licenses,   Certifications, and A                                pprovals for
manufacturing license under 10 CFR Part 52, Licenses, Certifications, and Approvals for


Nuclear Power Plants.   All applicants for a standard design certification, including such
Nuclear Power Plants. All applicants for a standard design certification, including such


applicants after initial issuance of a design certification rule.
applicants after initial issuance of a design certification rule.


All holders of and applicants for an independent spent fuel storage installation license                   under
All holders of and applicants for an independent spent fuel storage installation license under


10                                             CFR                             Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste.
10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste.


All holders of, and applicants for, a fuel facility license under 10                                                     CFR                             Part 70, Domestic
All holders of, and applicants for, a fuel facility license under 10 CFR Part 70, Domestic


Licensing of Special Nuclear Material.
Licensing of Special Nuclear Material.


==PURPOSE==
==PURPOSE==
The U.S. Nuclear Regulatory C          ommission (NRC) is issuing this information notice                     (IN) to inform
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform


licensees of recent challenges involving                                           detection and contamination control of                                                                                                                                   hot particles, commonly referred to as discrete radioactive particles           (DRPs                                                       ), 1 during plant operations and
licensees of recent challenges involving detection and contamination control of hot particles, commonly referred to as discrete radioactive particles (DRPs),1 during plant operations and


decommissioning.                                           This communication is intended to reinforce compliance with the
decommissioning. This communication is intended to reinforce compliance with the


10                                             CFR                             Part 20, Subpart F,   Surveys and Monitoring,                                             10 CFR                             20.1501 General   requirement
10 CFR Part 20, Subpart F, Surveys and Monitoring, 10 CFR 20.1501 General requirement


to use appropriate           survey practices to detect and in coordination with 10                                                       CFR 20.1406
to use appropriate survey practices to detect and in coordination with 10 CFR 20.1406  


1 DRPs are typically called hot particles ,   which have been described as particles less than 1                   mm in any
1 DRPs are typically called hot particles, which have been described as particles less than 1 mm in any


dimension, of high activity, and                                                           generally insoluble in water. Particles or objects         greater than 1                             mm that
dimension, of high activity, and generally insoluble in water. Particles or objects greater than 1 mm that


approximate point sources                   when field scanning or measuring                                       are                   also addressed                                         in this discussion due to
approximate point sources when field scanning or measuring are also addressed in this discussion due to


their similarities to DRPs especially         in detection and potential risk-significance. Examples of DRPs are
their similarities to DRPs especially in detection and potential risk-significance. Examples of DRPs are


fuel fleas, activated metal shavings from reactor component wear or segmentation,                             and activated
fuel fleas, activated metal shavings from reactor component wear or segmentation, and activated


bioshield concrete fragments from segmentation.
bioshield concrete fragments from segmentation. Minimization of contamination, reduce the spread of residual radioactivity. Residual


IN 2024-                                                                                                  01 Minimization of contamination,                                                reduce the spread of residual radioactivity.          Residual
radioactivity may include hot particles and, therefore, licensees are reminded of the importance
 
radioactivity                     may include hot particles and, therefore,                     licensees are reminded of the importance


of documenting issues important to decommissioning in the reporting and recordkeeping files
of documenting issues important to decommissioning in the reporting and recordkeeping files


required by 10                                                       CFR 50.75,                     Reporting and recordkeeping for decommissioning planning.
required by 10 CFR 50.75, Reporting and recordkeeping for decommissioning planning.


Similar requirements for subject addresses are contained in                     10 CFR                           72.30,   Financial
Similar requirements for subject addresses are contained in 10 CFR 72.30, Financial


assurance and recordkeeping for decommissioning                                             and 10                                             CFR                             70.25, Financial assurance
assurance and recordkeeping for decommissioning and 10 CFR 70.25, Financial assurance


and recordkeeping for decommissioning. These efforts           will help mitigate future challenges
and recordkeeping for decommissioning. These efforts will help mitigate future challenges


associated with the           survey and remediation                                             of contaminated areas at decommissioning sites
associated with the survey and remediation of contaminated areas at decommissioning sites


and potential delays in license termination.                                           The NRC expects that recipients will review the
and potential delays in license termination. The NRC expects that recipients will review the


information for applicability to their facilities and consider actions, as appropriate, to avoid
information for applicability to their facilities and consider actions, as appropriate, to avoid


potential challenges with mitigation and remediation. However, the information                                                     contained in this
potential challenges with mitigation and remediation. However, the information contained in this


IN are not NRC requirements; therefore, no specific action or written response is required.
IN are not NRC requirements; therefore, no specific action or written response is required.


==BACKGROUND==
==BACKGROUND==
The regulations                                           at 10                                             CFR 20,                                             Subpart F, require that each licensee conduct           surveys in areas, including the subsurface, that (1) are necessary for compliance with regulations and (2) are
The regulations at 10 CFR 20, Subpart F, require that each licensee conduct surveys in areas, including the subsurface, that (1) are necessary for compliance with regulations and (2) are


deemed reasonable under the circumstances to assess the magnitude and extent of radiation
deemed reasonable under the circumstances to assess the magnitude and extent of radiation
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levels, concentrations or quantities of residual radioactivity, and the potential radiological
levels, concentrations or quantities of residual radioactivity, and the potential radiological


hazards associated with the detected radiation levels and residual radioactivity. Additionally, according to 10 CFR                           20.1201(a)(2)(ii), licensees are                                           required to control the occupational dose to
hazards associated with the detected radiation levels and residual radioactivity. Additionally, according to 10 CFR 20.1201(a)(2)(ii), licensees are required to control the occupational dose to


individual adults to a shallow-                                               dose equivalent of 50 rem (0.5 Sv) to the skin of the whole body or
individual adults to a shallow-dose equivalent of 50 rem (0.5 Sv) to the skin of the whole body or


to the skin of any extremity. The occupational skin dose limit applies to that dose from exposure
to the skin of any extremity. The occupational skin dose limit applies to that dose from exposure


to hot particles or DRPs   during operations. If these radioactive particles are                     not properly
to hot particles or DRPs during operations. If these radioactive particles are not properly


controlled and dispositioned during operations, they may become a residual radioactivity
controlled and dispositioned during operations, they may become a residual radioactivity


concern at the time of decommissioning of the facility with potential public exposure                     concerns
concern at the time of decommissioning of the facility with potential public exposure concerns


after license termination.
after license termination.
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During plant operations and major component replacement outages, hot particles are likely to
During plant operations and major component replacement outages, hot particles are likely to


be present and additional           surveys and controls are commonly instituted         . Addressing
be present and additional surveys and controls are commonly instituted. Addressing


contamination in a timely manner will prevent both the spread of contamination and exposure to
contamination in a timely manner will prevent both the spread of contamination and exposure to


residual radioactivity. Regular surveys of areas likely to have hot par                              ticles are typically
residual radioactivity. Regular surveys of areas likely to have hot particles are typically


conducted with the intent to control, identify, and remediate contamination at the source.
conducted with the intent to control, identify, and remediate contamination at the source.


Controlling and minimizing the spread of contamination are vital                 to prevent productivity and
Controlling and minimizing the spread of contamination are vital to prevent productivity and


efficiency losses                     during decommissioning.
efficiency losses during decommissioning.


The regulation at 10                                                       CFR 50.75(g)(1) requires                     that licensees maintain a record of spills or other
The regulation at 10 CFR 50.75(g)(1) requires that licensees maintain a record of spills or other


unusual occurrences involving the spread of contamination in and around a facility or site.
unusual occurrences involving the spread of contamination in and around a facility or site.
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quantities, forms, and concentrations. These records may be limited to instances when
quantities, forms, and concentrations. These records may be limited to instances when


significant contamination remains even after any clean-                                                               up                                           procedures are used or when there is
significant contamination remains even after any clean-up procedures are used or when there is


a reasonable likelihood that contaminants may have spread to inaccessible areas or porous
a reasonable likelihood that contaminants may have spread to inaccessible areas or porous
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materials and apply during decommissioning.
materials and apply during decommissioning.


In the 1997 final rule                     on decommissioning planning (76 FR 35511),                                                                                                                                   the NRC amended its
In the 1997 final rule on decommissioning planning (76 FR 35511), the NRC amended its


regulations to improve decommissioning planning by                               establishing a new regulation at
regulations to improve decommissioning planning by establishing a new regulation at


10                                             CFR                             20.1406, Minimization of contamination, and amending the regulation in
10 CFR 20.1406, Minimization of contamination, and amending the regulation in 10 CFR 20.1501(a). These regulations state that the surveys of areas include the subsurface to
 
IN 2024-                                                                                                  01 10                                             CFR                             20.1501(a). These regulations state         that the surveys of areas include the subsurface to


evaluate residual radioactivity. As described in the 1997 final rule, residual radioactivity that is
evaluate residual radioactivity. As described in the 1997 final rule, residual radioactivity that is


significant for decommissioning planning is                                                       a quantity of radioactive material that would         require
significant for decommissioning planning is a quantity of radioactive material that would require


remediation during decommissioning to meet the unrestricted use criteria of 10         CFR                             20.1402, Radiological criteria for unrestricted use.                       Consistent with 10 CFR                             50.75(g) requirements, licensees maintain                     records of spills or other unusual occurrences involving the spread of
remediation during decommissioning to meet the unrestricted use criteria of 10 CFR 20.1402, Radiological criteria for unrestricted use. Consistent with 10 CFR 50.75(g) requirements, licensees maintain records of spills or other unusual occurrences involving the spread of


contamination in and around the facility, equipment, or site until the license is terminated. The
contamination in and around the facility, equipment, or site until the license is terminated. The


regulation applies to events that occur while the plant is operating and                                                     during decommissioning.
regulation applies to events that occur while the plant is operating and during decommissioning.


The requirement outlined in 10                                                                             CFR                             20.1501(b) is associated with the existing 10                                                                                                   CFR                             50.75(g)
The requirement outlined in 10 CFR 20.1501(b) is associated with the existing 10 CFR 50.75(g)  
provisions in requiring that survey records of subsurface residual radioactivity are         kept with
provisions in requiring that survey records of subsurface residual radioactivity are kept with


records important for decommissioning.
records important for decommissioning.
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Radioactive Waste Generation: Life Cycle Planning, and, in 2012, issued Regulatory
Radioactive Waste Generation: Life Cycle Planning, and, in 2012, issued Regulatory


Guide                                           4.22, Decommissioning Planning During Operations. Both Regulatory Guides are
Guide 4.22, Decommissioning Planning During Operations. Both Regulatory Guides are


focused on contamination control during design and operations to facilitate future
focused on contamination control during design and operations to facilitate future
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While DRPs in the outside environment (outside buildings or containment) are not specifically
While DRPs in the outside environment (outside buildings or containment) are not specifically


addressed in NRC guidance                     during decommissioning, reviewing the lessons learned below, employing the above containment management           philosophy, having a good understanding of
addressed in NRC guidance during decommissioning, reviewing the lessons learned below, employing the above containment management philosophy, having a good understanding of


NUREG-1575,                                                                                           Multi-       Agency Radiation Survey and Site Investigation Manual   (MARSSIM)
NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)  
guidance and maintaining good surveying practices could prevent delays in decommissioning.
guidance and maintaining good surveying practices could prevent delays in decommissioning.


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with dose or risk-based regulations or standards. MARSSIM focuses on the demonstration of
with dose or risk-based regulations or standards. MARSSIM focuses on the demonstration of


compliance during the final status survey following scoping, characterization,                                         and any necessary
compliance during the final status survey following scoping, characterization, and any necessary


remedial actions. The NRC staff is currently determining the appropriate guidance to address
remedial actions. The NRC staff is currently determining the appropriate guidance to address
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==DISCUSSION==
==DISCUSSION==
As more plants have entered decommissioning, the         NRC noted inconsistencies in the types of
As more plants have entered decommissioning, the NRC noted inconsistencies in the types of


events entered in the 10                                                       CFR                           50.75(g) file and the level of detail documenting spill or leak
events entered in the 10 CFR 50.75(g) file and the level of detail documenting spill or leak


events at decommissioning sites.                                                                           In accordance with 10                                             CFR                           50.75(g), licensees are required to
events at decommissioning sites. In accordance with 10 CFR 50.75(g), licensees are required to


document significant residual radioactivity that remains or when there is reasonable likelihood
document significant residual radioactivity that remains or when there is reasonable likelihood
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that contaminants may have spread to inaccessible areas. These records combined with
that contaminants may have spread to inaccessible areas. These records combined with


characterization information such as the         involved nuclides, quantities, forms, and concentrations
characterization information such as the involved nuclides, quantities, forms, and concentrations


are important to maint                                ain so that NRC staff can review         how the licensee conducted                                                                                                 surveys and
are important to maintain so that NRC staff can review how the licensee conducted surveys and


assessed                                                                                     the dose from material left                     in place.                     Licensee understanding                                                                                                                         of the characteristics and
assessed the dose from material left in place. Licensee understanding of the characteristics and


location                                             of residual radioactivity                     for final status surveys is vital to           addressing the impacts           of
location of residual radioactivity for final status surveys is vital to addressing the impacts of


inaccessible areas. A site may be challenged                                                                                                                         with demonstrating compliance with the
inaccessible areas. A site may be challenged with demonstrating compliance with the


radiological criteria for license termination                                           if contamination                                           is not resolved before a final                                 status
radiological criteria for license termination if contamination is not resolved before a final status


survey (FSS)                                                     begins.
survey (FSS) begins. As discussed in the Examples of Lessons Learned section, demolition and decommissioning
 
IN 2024-                                                                                                  01 As discussed in the Examples of Lessons Learned section, demolition and decommissioning


activities can generate or release DRPs that were unknowingly present in equipment or
activities can generate or release DRPs that were unknowingly present in equipment or


components being removed or dismantled as p        art of the decommissioning process. The
components being removed or dismantled as part of the decommissioning process. The


presence of DRPs could result from inadvertent or unintentional contamination of soil during
presence of DRPs could result from inadvertent or unintentional contamination of soil during


waste loading or from           a lack of sufficient ventilation           and containment during waste handling
waste loading or from a lack of sufficient ventilation and containment during waste handling


operations.
operations.


Consistent with 10                                                       CFR 50.82, Termination of license,                         specific information is required in a
Consistent with 10 CFR 50.82, Termination of license, specific information is required in a


License Termination Plan (LTP). As described in NUREG 1700, Standard Review Plan for
License Termination Plan (LTP). As described in NUREG 1700, Standard Review Plan for


Evaluating Nuclear Power Reactor License Termination Plans, a                                   description of the techniques
Evaluating Nuclear Power Reactor License Termination Plans, a description of the techniques


that will be employed to remove or remediate surface and subsurface soils, groundwater, and
that will be employed to remove or remediate surface and subsurface soils, groundwater, and


surface water and sediments should be contained in the LTP. DRPs                                                                                 may become an issue even
surface water and sediments should be contained in the LTP. DRPs may become an issue even


at sites with no history of fuel failure or releases during operation,                                         because DRPs may be
at sites with no history of fuel failure or releases during operation, because DRPs may be


produced and released during the segmentation                                           or dismantling of reactor vessel internals and
produced and released during the segmentation or dismantling of reactor vessel internals and


other contaminated piping, equipment, or components. Often, the Historical Site Assessment
other contaminated piping, equipment, or components. Often, the Historical Site Assessment
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to the NRC. In some cases, site characterization occurs prior to many of the segmentation and
to the NRC. In some cases, site characterization occurs prior to many of the segmentation and


dismantling activities that           may contribute to the spread of contamination. In multiple cases, contamination events have occurred after the LTP license amendment request is submitted to
dismantling activities that may contribute to the spread of contamination. In multiple cases, contamination events have occurred after the LTP license amendment request is submitted to


the NRC and, in some cases, after the LTP is approved.
the NRC and, in some cases, after the LTP is approved.
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compliance with regulations when uncertainties arise regarding the appropriateness of licensee
compliance with regulations when uncertainties arise regarding the appropriateness of licensee


surveys. This may include requests for additional information                                                                                                                     and potential license amendment
surveys. This may include requests for additional information and potential license amendment


requests to incorporate the appropriate survey techniques or dose considerations into the LTP.
requests to incorporate the appropriate survey techniques or dose considerations into the LTP.


===Examples of Lessons Learned===
Examples of Lessons Learned


During active decommissioning, r                                          adioactive cross-contamination of site soil involving DRPs has
During active decommissioning, radioactive cross-contamination of site soil involving DRPs has


occurred at reactor         facilities due to material movement from buildings, debris piles or stockpiles, or waste containers. There have                                                                             been instances of untimely or inadequate surveys conducted
occurred at reactor facilities due to material movement from buildings, debris piles or stockpiles, or waste containers. There have been instances of untimely or inadequate surveys conducted


after cross-                   contamination                     involving DRPs. Discovery of DRPs during decommissioning
after cross-contamination involving DRPs. Discovery of DRPs during decommissioning


operations and during confirmatory surveys         resulted in increased regulatory oversight licensee
operations and during confirmatory surveys resulted in increased regulatory oversight licensee


effort to assess the presence and risk significance         of the DRPs         .
effort to assess the presence and risk significance of the DRPs.


Below are summaries of recent DRP issues:
Below are summaries of recent DRP issues:  


Example 1
Example 1  


Licensee surveys at                                                 a decommissioning nuclear power reactor site detected         DRPs near
Licensee surveys at a decommissioning nuclear power reactor site detected DRPs near


containment hatch openings and surrounding survey units. The surveys were to be used                                                       for
containment hatch openings and surrounding survey units. The surveys were to be used for


FSS                                                   to show license termination compliance                     within the power block land area.                                           The DRPs, in the
FSS to show license termination compliance within the power block land area. The DRPs, in the


form of fuel fragments and metal shavings generated during           reactor internal segmentation
form of fuel fragments and metal shavings generated during reactor internal segmentation


activities, were thought to have been released from containment and deposited on soil. The
activities, were thought to have been released from containment and deposited on soil. The


release occurred due to                     insufficient negative pressure during the movement of potentially
release occurred due to insufficient negative pressure during the movement of potentially


contaminated equipment and large components through enlarged equipment hatches of
contaminated equipment and large components through enlarged equipment hatches of


containment buildings before         the erection of waste loadout tents.         The DRPs could have been
containment buildings before the erection of waste loadout tents. The DRPs could have been


dislocated by rain or wind, or during rigging                                         activities from packaged waste during loading.
dislocated by rain or wind, or during rigging activities from packaged waste during loading. Without appropriate use of safety and radiological control protocols, it is possible for DRPs to be


IN 2024-                                                                                                  01 Without appropriate                      use of safety and radiological control protocols, it is          possible for DRP          s to be
dislocated from the material during the removal process or waste liner transfers to licensed


dislocated from the material during the removal process or waste liner                                transfers to licensed
casks. DRP clean-up was achieved through a combination of FSS and a confirmatory survey for
 
casks.                                                           DRP clean-up was achieved through a combination of FSS                                                                                       and a confirmatory                   survey                   for


the area.
the area.


Example 2
Example 2  


When a                                                                 liner was loaded into an                                                       overpack, contamination                                             on the outside of the inner liner was
When a liner was loaded into an overpack, contamination on the outside of the inner liner was


spread to the ground                                                                                       and cask, then spread further when the shipping cask was moved                                                                 to
spread to the ground and cask, then spread further when the shipping cask was moved to


another area of the site. The licensee determined that the contamination was spread         by the
another area of the site. The licensee determined that the contamination was spread by the


action of inserting the liner into the overpack. Contamination on the inner liner had dried over a
action of inserting the liner into the overpack. Contamination on the inner liner had dried over a


long storage period and was therefore more           easily dispersible                     than normal when the inner liner
long storage period and was therefore more easily dispersible than normal when the inner liner


was loaded into the overpack. In addition,                                           high ambient radiation levels hindered the ability to
was loaded into the overpack. In addition, high ambient radiation levels hindered the ability to


perform a thorough survey. A timely survey after the packing of the inner liner could have
perform a thorough survey. A timely survey after the packing of the inner liner could have


prevented the spread of contamination beyond the localized area.                                                     DRP clean-up was achieved
prevented the spread of contamination beyond the localized area. DRP clean-up was achieved


through a combination of FSS                                                                                     and Confirmatory Survey.
through a combination of FSS and Confirmatory Survey.


Example 3
Example 3  


Concrete debris that was determined                                                                               to be free of residual radioactive material was in an area
Concrete debris that was determined to be free of residual radioactive material was in an area


that had previously undergone an                                                                                                                         FSS.                                                     Concrete debris that had been cleared by surveys prior
that had previously undergone an FSS. Concrete debris that had been cleared by surveys prior


to demolition                                             was being staged for removal from the site. The concrete was consolidated in
to demolition was being staged for removal from the site. The concrete was consolidated in


temporary staging areas and may have been moved between staging areas. Some of these
temporary staging areas and may have been moved between staging areas. Some of these


staging                                             areas were placed on units                                                                                       that had undergone FSS. Subsequently,           DRPs were found
staging areas were placed on units that had undergone FSS. Subsequently, DRPs were found


in these previously surveyed                                 land areas. The licensee was not able to determine where the
in these previously surveyed land areas. The licensee was not able to determine where the


DRPs                                                         came from or how they           were transported. The DRPs           may have resulted from                               building
DRPs came from or how they were transported. The DRPs may have resulted from building


demolition or from           subsequent movement of the concrete from the building demolition                                           area into
demolition or from subsequent movement of the concrete from the building demolition area into


the areas previously determined to be free of residual radioactive material. These practices
the areas previously determined to be free of residual radioactive material. These practices


were not in compliance with the                                 licensees isolation and control measures         . DRP clean-up was
were not in compliance with the licensees isolation and control measures. DRP clean-up was


achieved through a combination of FSS                                 and Confirmatory Survey.
achieved through a combination of FSS and Confirmatory Survey.


===PAPERWORK REDUCTION ACT STATEMENT===
===PAPERWORK REDUCTION ACT STATEMENT===
This IN does not contain new or amended information collection requirements that are subject to
This IN does not contain new or amended information collection requirements that are subject to


the Paperwork Reduction Act of 1995 (44 U.S.C. 10                                             CFR                           3501 et seq.). Existing requirements
the Paperwork Reduction Act of 1995 (44 U.S.C. 10 CFR 3501 et seq.). Existing requirements


were approved by the Office of Management and Budget (OMB) under approval control
were approved by the Office of Management and Budget (OMB) under approval control


numbers 3150-                                                                                                 0009, 3150-                                           0011, 3150-                                                                                       0014,                                           3150-                                           0132, and 3150-0151.
numbers 3150-0009, 3150-0011, 3150-0014, 3150-0132, and 3150-0151.


===PUBLIC PROTECTION NOTIFICATION===
===PUBLIC PROTECTION NOTIFICATION===
Line 383: Line 375:


valid OMB control number.
valid OMB control number.
IN 2024-                                                                                                  01


==CONTACT==
==CONTACT==
Line 391: Line 381:
This IN requires no specific action or written response. Please direct any questions about this
This IN requires no specific action or written response. Please direct any questions about this


matter to the technical contact listed below or the appropriate Office of N        uclear Material Safety
matter to the technical contact listed below or the appropriate Office of Nuclear Material Safety


and Safeguards (NMSS), Reactor Decommissioning Branch, Project Manager.
and Safeguards (NMSS), Reactor Decommissioning Branch, Project Manager.


/RA/                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           /RA/
/RA/  
  Kevin Williams, Director                                                                                                              Russell Felts, Director


Division of Materials Safety, Security, State,                                                                                        Division of Reactor Oversight
/RA/
Kevin Williams, Director


and Tribal Programs                                                                                                                   Office of Nuclear Reactor Regulation
Division of Materials Safety, Security, State, and Tribal Programs


Office of Nuclear Material Safety
Office of Nuclear Material Safety


and Safeguards
and Safeguards
Russell Felts, Director
Division of Reactor Oversight
Office of Nuclear Reactor Regulation


===Technical Contact:===
===Technical Contact:===
Amy Snyder, NMSS


===Amy Snyder, NMSS===
301-415-6822 E-mail: Amy.Snyder@nrc.gov REFERENCES
                                                      301-                                                                 415-                                                                 6822 E-mail: Amy.Snyder@nrc.gov


IN 2024-                                                                                                  01 REFERENCES
Kelly J. J. and Gustafson S., Industry experience with discrete radioactive particles.
 
Kelly J. J. and Gustafson S., Industry experience with discrete radioactive particles                                 .


EPRI-Report TR-104125, July 1994.
EPRI-Report TR-104125, July 1994.


NEI 08-08A, Generic FSAR Template Guidance for Life Cycle                     Minimization of           Contamination, Revision 0, October 2009 (ML093220445).
NEI 08-08A, Generic FSAR Template Guidance for Life Cycle Minimization of Contamination, Revision 0, October 2009 (ML093220445).


NRC, Regulatory Guide 1.206, Applications for Nuclear Power Plants, Rev. 1, October 2018 (ML18131A181).
NRC, Regulatory Guide 1.206, Applications for Nuclear Power Plants, Rev. 1, October 2018 (ML18131A181).


NRC, Regulatory Guide 4.22, Decommissioning Planning                                           during Operations, December 2012 (ML12158A361).
NRC, Regulatory Guide 4.22, Decommissioning Planning during Operations, December 2012 (ML12158A361).


NRC, Regulatory Guide 4.21, Minimization of Contamination and Radioactive Waste
NRC, Regulatory Guide 4.21, Minimization of Contamination and Radioactive Waste


Generation: Life-                     Cycle Planning,                                               July 2013 (ML13168A049).
Generation: Life-Cycle Planning, July 2013 (ML13168A049).


NRC, Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),
NRC, Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),  
Revision 2, issued February 1978 (ML003739995).
Revision 2, issued February 1978 (ML003739995).


NRC, Information Notice 86-                                           23, Excessive Skin Exposures Due to Contamination with Hot
NRC, Information Notice 86-23, Excessive Skin Exposures Due to Contamination with Hot


Particles, dated April 9, 1986 (ML8604040321, Legacy Library).
Particles, dated April 9, 1986 (ML8604040321, Legacy Library).


NRC, Information Notice 87-                                           39, Control of Hot Particle Contamination at Nuclear Power
NRC, Information Notice 87-39, Control of Hot Particle Contamination at Nuclear Power


Plants, dated August 21, 1987 (ML8708170408 (Legacy Library)).
Plants, dated August 21, 1987 (ML8708170408 (Legacy Library)).


NRC, NUREG-1575, Multi -Agency Radiation Survey and Site Investigation Manual
NRC, NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual


(MARSSIM), Revision 1, issued August 2000 (ML003761445).
(MARSSIM), Revision 1, issued August 2000 (ML003761445).
Line 450: Line 444:
Decommissioning Plans and License Termination Plans, dated January 16, 2002 (ML013510432).
Decommissioning Plans and License Termination Plans, dated January 16, 2002 (ML013510432).


NRC, Regulatory Issue Summary 2002-10, Revision of the Skin Dose Limit in 10                                                         CFR                             Part 20,
NRC, Regulatory Issue Summary 2002-10, Revision of the Skin Dose Limit in 10 CFR Part 20,  
dated July 9, 2002 (ML021860332).
dated July 9, 2002 (ML021860332).


NRC,                                                                                       Decommissioning Planning,                                             Federal Register, Vol. 76, No. 117,                                                                 pp. 35511-35575                                                                                                                                   ,
NRC, Decommissioning Planning, Federal Register, Vol. 76, No. 117, pp. 35511-35575, June 17, 2011.
June                                                                 17, 2011.


NRC, Regulatory Guide 1.185, Standard Format and Content for Post                                                                                               -Shutdown
NRC, Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown


Decommissioning Activities Report, Revision 1, issued June 2013 (ML13140A038).
Decommissioning Activities Report, Revision 1, issued June 2013 (ML13140A038).
Line 462: Line 455:
NRC, NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License
NRC, NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License


Termination Plans, Revision 2, issued April 2018 (ML18116A124).
Termination Plans, Revision 2, issued April 2018 (ML18116A124). NRC, Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for
 
IN 2024-                                                                                                  01 NRC, Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for


Nuclear Power Reactors, Revision 2, issued July 2019 (ML110490419).
Nuclear Power Reactors, Revision 2, issued July 2019 (ML110490419).
Line 476: Line 467:
RCD Report, Dose Coefficients for Discrete Radioactive Particles (DRPs), May 1, 2023 (ML23136A178).
RCD Report, Dose Coefficients for Discrete Radioactive Particles (DRPs), May 1, 2023 (ML23136A178).


ML23195A074                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       EPIDS No. L-2023-                   GEN-0005
ML23195A074  
 
EPIDS No. L-2023-GEN-0005 OFFICE Tech Editor
 
NMSS/DUWP/RDP NMSS/DUWP/RTAB
 
NMSS/DUWP/RDB
 
OE
 
OCIO
 
NAME
 
JDougherty
 
ASnyder
 
CMcKenney
 
SAnderson
 
JPeralta
 
DCullsion
 
DATE
 
6/12/2023
7/24/2023
7/24/2023
7/272023
2/1/2024
2/1/2024 OFFICE NRR/DRO/IOEB
 
NRR/DRO/IOLB
 
NRR/DRO/IOEB
 
NMSS/DUWP
 
NMSS/DFM/IOB
 
NMSS/DFM/IOB
 
NAME
 
PClark
 
IBetts
 
LRegner
 
JMarshall
 
JTapp
 
ARivera-Varona
 
DATE


OFFICE          Tech Editor                        NMSS/DUWP/R                DP      NMSS/DUWP/RTAB                          NMSS/DUWP/R                DB        OE                                      OCIO
2/1/202
2/1/2024
  2/2/2024
1/16/2024
1/23/2024
1/23/2024 OFFICE NMSS/DFM


NAME          JDougherty                          ASnyder                            CMcKenney                                SAnderson                            JPeralta                                DCullsion
NMSS/MSST


DATE          6/12    /2023                      7/24/2023                          7/24/2023                                7/272023                            2/1/2024                                2/1/2024
NRR/DRO


OFFICE          NRR/DRO/IOEB                        NRR/DRO/IOLB                        NRR/DRO/IOEB                            NMSS/DUWP                            NMSS/DFM/IOB                            NMSS/DFM/IOB
NAME


NAME          PClark                              IBetts                              LRegner                                  JMarshall                            JTapp                                  ARivera      -Varona
SHelton


DATE          2/1/202                            2/1/2024                              2/2/2024                              1/16/2024                            1/23/2024                              1/23/2024
KWilliams


OFFICE          NMSS/DFM                            NMSS/MSST                          NRR/DRO
RFelts (PMckenna for) 


NAME          SHelton                            KWilliams                          RFelts (PMckenna for)
DATE


DATE          1/26/2024                           2/8/2024                           2/9/2024}}
1/26/2024  
2/8/2024  
2/9/2024}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 02:41, 27 November 2024

Minimization and Control of Contamination Involving Discrete Radioactive Particles at Decommissioning Facilities
ML23195A074
Person / Time
Issue date: 02/09/2024
From: Russell Felts, Kevin Williams
NRC/NMSS/DMSST, NRC/NRR/DRO/IOEB
To:
References
IN-24-001
Download: ML23195A074 (9)
v • d • e


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, DC 20555-0001

February 9, 2024

NRC INFORMATION NOTICE 2024-01: MINIMIZATION AND CONTROL OF

CONTAMINATION INVOLVING DISCRETE

RADIOACTIVE PARTICLES AT DECOMMISSIONING

FACILITIES

ADDRESSEES

All holders of and applicants for an operating license or construction permit for a nuclear power

reactor issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic

Licensing of Production and Utilization Facilities, including those that have permanently ceased

operations and certified that fuel has been permanently removed from the reactor vessel.

All holders of and applicants for a power reactor combined license, standard design approval, or

manufacturing license under 10 CFR Part 52, Licenses, Certifications, and Approvals for

Nuclear Power Plants. All applicants for a standard design certification, including such

applicants after initial issuance of a design certification rule.

All holders of and applicants for an independent spent fuel storage installation license under

10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste.

All holders of, and applicants for, a fuel facility license under 10 CFR Part 70, Domestic

Licensing of Special Nuclear Material.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform

licensees of recent challenges involving detection and contamination control of hot particles, commonly referred to as discrete radioactive particles (DRPs),1 during plant operations and

decommissioning. This communication is intended to reinforce compliance with the

10 CFR Part 20, Subpart F, Surveys and Monitoring, 10 CFR 20.1501 General requirement

to use appropriate survey practices to detect and in coordination with 10 CFR 20.1406

1 DRPs are typically called hot particles, which have been described as particles less than 1 mm in any

dimension, of high activity, and generally insoluble in water. Particles or objects greater than 1 mm that

approximate point sources when field scanning or measuring are also addressed in this discussion due to

their similarities to DRPs especially in detection and potential risk-significance. Examples of DRPs are

fuel fleas, activated metal shavings from reactor component wear or segmentation, and activated

bioshield concrete fragments from segmentation. Minimization of contamination, reduce the spread of residual radioactivity. Residual

radioactivity may include hot particles and, therefore, licensees are reminded of the importance

of documenting issues important to decommissioning in the reporting and recordkeeping files

required by 10 CFR 50.75, Reporting and recordkeeping for decommissioning planning.

Similar requirements for subject addresses are contained in 10 CFR 72.30, Financial

assurance and recordkeeping for decommissioning and 10 CFR 70.25, Financial assurance

and recordkeeping for decommissioning. These efforts will help mitigate future challenges

associated with the survey and remediation of contaminated areas at decommissioning sites

and potential delays in license termination. The NRC expects that recipients will review the

information for applicability to their facilities and consider actions, as appropriate, to avoid

potential challenges with mitigation and remediation. However, the information contained in this

IN are not NRC requirements; therefore, no specific action or written response is required.

BACKGROUND

The regulations at 10 CFR 20, Subpart F, require that each licensee conduct surveys in areas, including the subsurface, that (1) are necessary for compliance with regulations and (2) are

deemed reasonable under the circumstances to assess the magnitude and extent of radiation

levels, concentrations or quantities of residual radioactivity, and the potential radiological

hazards associated with the detected radiation levels and residual radioactivity. Additionally, according to 10 CFR 20.1201(a)(2)(ii), licensees are required to control the occupational dose to

individual adults to a shallow-dose equivalent of 50 rem (0.5 Sv) to the skin of the whole body or

to the skin of any extremity. The occupational skin dose limit applies to that dose from exposure

to hot particles or DRPs during operations. If these radioactive particles are not properly

controlled and dispositioned during operations, they may become a residual radioactivity

concern at the time of decommissioning of the facility with potential public exposure concerns

after license termination.

During plant operations and major component replacement outages, hot particles are likely to

be present and additional surveys and controls are commonly instituted. Addressing

contamination in a timely manner will prevent both the spread of contamination and exposure to

residual radioactivity. Regular surveys of areas likely to have hot particles are typically

conducted with the intent to control, identify, and remediate contamination at the source.

Controlling and minimizing the spread of contamination are vital to prevent productivity and

efficiency losses during decommissioning.

The regulation at 10 CFR 50.75(g)(1) requires that licensees maintain a record of spills or other

unusual occurrences involving the spread of contamination in and around a facility or site.

These records include any known information on the identification of involved nuclides and their

quantities, forms, and concentrations. These records may be limited to instances when

significant contamination remains even after any clean-up procedures are used or when there is

a reasonable likelihood that contaminants may have spread to inaccessible areas or porous

materials and apply during decommissioning.

In the 1997 final rule on decommissioning planning (76 FR 35511), the NRC amended its

regulations to improve decommissioning planning by establishing a new regulation at

10 CFR 20.1406, Minimization of contamination, and amending the regulation in 10 CFR 20.1501(a). These regulations state that the surveys of areas include the subsurface to

evaluate residual radioactivity. As described in the 1997 final rule, residual radioactivity that is

significant for decommissioning planning is a quantity of radioactive material that would require

remediation during decommissioning to meet the unrestricted use criteria of 10 CFR 20.1402, Radiological criteria for unrestricted use. Consistent with 10 CFR 50.75(g) requirements, licensees maintain records of spills or other unusual occurrences involving the spread of

contamination in and around the facility, equipment, or site until the license is terminated. The

regulation applies to events that occur while the plant is operating and during decommissioning.

The requirement outlined in 10 CFR 20.1501(b) is associated with the existing 10 CFR 50.75(g)

provisions in requiring that survey records of subsurface residual radioactivity are kept with

records important for decommissioning.

In 2008, the NRC issued Regulatory Guide 4.21, Minimization of Contamination and

Radioactive Waste Generation: Life Cycle Planning, and, in 2012, issued Regulatory

Guide 4.22, Decommissioning Planning During Operations. Both Regulatory Guides are

focused on contamination control during design and operations to facilitate future

decommissioning. This guidance provides a threefold contaminant management philosophy

during active decommissioning: (1) prevention of unintended releases, (2) early detection, if

there is unintended release of radioactive contamination, and (3) prompt assessment to support

a timely and appropriate response.

While DRPs in the outside environment (outside buildings or containment) are not specifically

addressed in NRC guidance during decommissioning, reviewing the lessons learned below, employing the above containment management philosophy, having a good understanding of

NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)

guidance and maintaining good surveying practices could prevent delays in decommissioning.

MARSSIM provides detailed guidance on planning, conducting, evaluating, and documenting

building surface and surface soil final status radiological surveys for demonstrating compliance

with dose or risk-based regulations or standards. MARSSIM focuses on the demonstration of

compliance during the final status survey following scoping, characterization, and any necessary

remedial actions. The NRC staff is currently determining the appropriate guidance to address

this form of contamination throughout decommissioning.

DISCUSSION

As more plants have entered decommissioning, the NRC noted inconsistencies in the types of

events entered in the 10 CFR 50.75(g) file and the level of detail documenting spill or leak

events at decommissioning sites. In accordance with 10 CFR 50.75(g), licensees are required to

document significant residual radioactivity that remains or when there is reasonable likelihood

that contaminants may have spread to inaccessible areas. These records combined with

characterization information such as the involved nuclides, quantities, forms, and concentrations

are important to maintain so that NRC staff can review how the licensee conducted surveys and

assessed the dose from material left in place. Licensee understanding of the characteristics and

location of residual radioactivity for final status surveys is vital to addressing the impacts of

inaccessible areas. A site may be challenged with demonstrating compliance with the

radiological criteria for license termination if contamination is not resolved before a final status

survey (FSS) begins. As discussed in the Examples of Lessons Learned section, demolition and decommissioning

activities can generate or release DRPs that were unknowingly present in equipment or

components being removed or dismantled as part of the decommissioning process. The

presence of DRPs could result from inadvertent or unintentional contamination of soil during

waste loading or from a lack of sufficient ventilation and containment during waste handling

operations.

Consistent with 10 CFR 50.82, Termination of license, specific information is required in a

License Termination Plan (LTP). As described in NUREG 1700, Standard Review Plan for

Evaluating Nuclear Power Reactor License Termination Plans, a description of the techniques

that will be employed to remove or remediate surface and subsurface soils, groundwater, and

surface water and sediments should be contained in the LTP. DRPs may become an issue even

at sites with no history of fuel failure or releases during operation, because DRPs may be

produced and released during the segmentation or dismantling of reactor vessel internals and

other contaminated piping, equipment, or components. Often, the Historical Site Assessment

and site characterization activities are completed well in advance of when the LTP is submitted

to the NRC. In some cases, site characterization occurs prior to many of the segmentation and

dismantling activities that may contribute to the spread of contamination. In multiple cases, contamination events have occurred after the LTP license amendment request is submitted to

the NRC and, in some cases, after the LTP is approved.

The NRC may need to perform additional work to evaluate the adequacy of the licensee's

compliance with regulations when uncertainties arise regarding the appropriateness of licensee

surveys. This may include requests for additional information and potential license amendment

requests to incorporate the appropriate survey techniques or dose considerations into the LTP.

Examples of Lessons Learned

During active decommissioning, radioactive cross-contamination of site soil involving DRPs has

occurred at reactor facilities due to material movement from buildings, debris piles or stockpiles, or waste containers. There have been instances of untimely or inadequate surveys conducted

after cross-contamination involving DRPs. Discovery of DRPs during decommissioning

operations and during confirmatory surveys resulted in increased regulatory oversight licensee

effort to assess the presence and risk significance of the DRPs.

Below are summaries of recent DRP issues:

Example 1

Licensee surveys at a decommissioning nuclear power reactor site detected DRPs near

containment hatch openings and surrounding survey units. The surveys were to be used for

FSS to show license termination compliance within the power block land area. The DRPs, in the

form of fuel fragments and metal shavings generated during reactor internal segmentation

activities, were thought to have been released from containment and deposited on soil. The

release occurred due to insufficient negative pressure during the movement of potentially

contaminated equipment and large components through enlarged equipment hatches of

containment buildings before the erection of waste loadout tents. The DRPs could have been

dislocated by rain or wind, or during rigging activities from packaged waste during loading. Without appropriate use of safety and radiological control protocols, it is possible for DRPs to be

dislocated from the material during the removal process or waste liner transfers to licensed

casks. DRP clean-up was achieved through a combination of FSS and a confirmatory survey for

the area.

Example 2

When a liner was loaded into an overpack, contamination on the outside of the inner liner was

spread to the ground and cask, then spread further when the shipping cask was moved to

another area of the site. The licensee determined that the contamination was spread by the

action of inserting the liner into the overpack. Contamination on the inner liner had dried over a

long storage period and was therefore more easily dispersible than normal when the inner liner

was loaded into the overpack. In addition, high ambient radiation levels hindered the ability to

perform a thorough survey. A timely survey after the packing of the inner liner could have

prevented the spread of contamination beyond the localized area. DRP clean-up was achieved

through a combination of FSS and Confirmatory Survey.

Example 3

Concrete debris that was determined to be free of residual radioactive material was in an area

that had previously undergone an FSS. Concrete debris that had been cleared by surveys prior

to demolition was being staged for removal from the site. The concrete was consolidated in

temporary staging areas and may have been moved between staging areas. Some of these

staging areas were placed on units that had undergone FSS. Subsequently, DRPs were found

in these previously surveyed land areas. The licensee was not able to determine where the

DRPs came from or how they were transported. The DRPs may have resulted from building

demolition or from subsequent movement of the concrete from the building demolition area into

the areas previously determined to be free of residual radioactive material. These practices

were not in compliance with the licensees isolation and control measures. DRP clean-up was

achieved through a combination of FSS and Confirmatory Survey.

PAPERWORK REDUCTION ACT STATEMENT

This IN does not contain new or amended information collection requirements that are subject to

the Paperwork Reduction Act of 1995 (44 U.S.C. 10 CFR 3501 et seq.). Existing requirements

were approved by the Office of Management and Budget (OMB) under approval control

numbers 3150-0009, 3150-0011, 3150-0014, 3150-0132, and 3150-0151.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct or sponsor, and a person is not required to respond to, a collection

of information unless the document requesting or requiring the collection displays a currently

valid OMB control number.

CONTACT

S

This IN requires no specific action or written response. Please direct any questions about this

matter to the technical contact listed below or the appropriate Office of Nuclear Material Safety

and Safeguards (NMSS), Reactor Decommissioning Branch, Project Manager.

/RA/

/RA/

Kevin Williams, Director

Division of Materials Safety, Security, State, and Tribal Programs

Office of Nuclear Material Safety

and Safeguards

Russell Felts, Director

Division of Reactor Oversight

Office of Nuclear Reactor Regulation

Technical Contact:

Amy Snyder, NMSS

301-415-6822 E-mail: Amy.Snyder@nrc.gov REFERENCES

Kelly J. J. and Gustafson S., Industry experience with discrete radioactive particles.

EPRI-Report TR-104125, July 1994.

NEI 08-08A, Generic FSAR Template Guidance for Life Cycle Minimization of Contamination, Revision 0, October 2009 (ML093220445).

NRC, Regulatory Guide 1.206, Applications for Nuclear Power Plants, Rev. 1, October 2018 (ML18131A181).

NRC, Regulatory Guide 4.22, Decommissioning Planning during Operations, December 2012 (ML12158A361).

NRC, Regulatory Guide 4.21, Minimization of Contamination and Radioactive Waste

Generation: Life-Cycle Planning, July 2013 (ML13168A049).

NRC, Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation),

Revision 2, issued February 1978 (ML003739995).

NRC, Information Notice 86-23, Excessive Skin Exposures Due to Contamination with Hot

Particles, dated April 9, 1986 (ML8604040321, Legacy Library).

NRC, Information Notice 87-39, Control of Hot Particle Contamination at Nuclear Power

Plants, dated August 21, 1987 (ML8708170408 (Legacy Library)).

NRC, NUREG-1575, Multi-Agency Radiation Survey and Site Investigation Manual

(MARSSIM), Revision 1, issued August 2000 (ML003761445).

NRC, Information Notice 2002 03, Highly Radioactive Particle Control Problems During Spent

Fuel Pool Cleanout, dated January 10, 2002 (ML011790547).

NRC, Regulatory Issue Summary 2002-02, Lessons Learned Related to Recently Submitted

Decommissioning Plans and License Termination Plans, dated January 16, 2002 (ML013510432).

NRC, Regulatory Issue Summary 2002-10, Revision of the Skin Dose Limit in 10 CFR Part 20,

dated July 9, 2002 (ML021860332).

NRC, Decommissioning Planning, Federal Register, Vol. 76, No. 117, pp. 35511-35575, June 17, 2011.

NRC, Regulatory Guide 1.185, Standard Format and Content for Post-Shutdown

Decommissioning Activities Report, Revision 1, issued June 2013 (ML13140A038).

NRC, NUREG-1700, Standard Review Plan for Evaluating Nuclear Power Reactor License

Termination Plans, Revision 2, issued April 2018 (ML18116A124). NRC, Regulatory Guide 1.179, Standard Format and Content of License Termination Plans for

Nuclear Power Reactors, Revision 2, issued July 2019 (ML110490419).

ORISE Report, Spatially-Dependent Measurements of Surface and Near-Surface Radioactive

Material Using In Situ Gamma Ray Spectrometry (ISGRS) for Final Status Surveys, November

15, 2006 (ML17284A121).

RCD Report, Dose Coefficients for Discrete Radioactive Particles (DRPs), May 1, 2023 (ML23136A178).

ML23195A074

EPIDS No. L-2023-GEN-0005 OFFICE Tech Editor

NMSS/DUWP/RDP NMSS/DUWP/RTAB

NMSS/DUWP/RDB

OE

OCIO

NAME

JDougherty

ASnyder

CMcKenney

SAnderson

JPeralta

DCullsion

DATE

6/12/2023

7/24/2023

7/24/2023

7/272023

2/1/2024

2/1/2024 OFFICE NRR/DRO/IOEB

NRR/DRO/IOLB

NRR/DRO/IOEB

NMSS/DUWP

NMSS/DFM/IOB

NMSS/DFM/IOB

NAME

PClark

IBetts

LRegner

JMarshall

JTapp

ARivera-Varona

DATE

2/1/202

2/1/2024

2/2/2024

1/16/2024

1/23/2024

1/23/2024 OFFICE NMSS/DFM

NMSS/MSST

NRR/DRO

NAME

SHelton

KWilliams

RFelts (PMckenna for)

DATE

1/26/2024

2/8/2024

2/9/2024


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