Information Notice 1996-47, Recordkeeping, Decommissioning Notifications for Disposals of Radioactive Waste by Land Burial Authorized Under Former 10 CFR 20.304, 20.302, and Current 20.2002
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555 August 19. 1996 NRC INFORMATION NOTICE 96-47: RECORDKEEPING. DECOMMISSIONING NOTIFICATIONS
FOR DISPOSALS OF RADIOACTIVE WASTE BY LAND
BURIAL AUTHORIZED UNDER FORMER 10 CFR 20.304.
20.302, AND CURRENT 20.2002
Addressees
All U.S. Nuclear Regulatory Commission licensees.
Purpose
I
NRC is issuing this information notice to: (1)inform addressees byof land problems
identified at several sites where disposals of radioactive waste
burial were made under the authorization of former 10 CFR 20.304 and 10 CFR
20.2002 (revision to the former 10 CFR Section 20.302); (2)emphasize of the
recordkeeping requirements of such burials; and (3) remind licensees with
submittal dates (September 15, and October 15. 1996) for compliance
"Final Rule on Timeliness in Decommissioning of Materials Facilities"
"Timeliness
(59 FR 36026, effective August 15, 1994) (hereafter called the position on
Rule"). This information notice emphasizes the current NRC
recordkeeping and notification requirements for such disposals. NRC expects
that recipients will review the information for applicability to their
to
facilities and consider actions, as appropriate, to avoid similar problems notice
those identified. However, suggestions contained in this information
is
are not NRC requirements: therefore, no specific action or written response
required, other than as specified for compliance with the regulations
described herein.
Description of Circumstances
On-site burials have been problematic for licensees during their past
decommissioning of sites containing such burials. A limited number of even
burial sites have been required to be exhumed during decommissioning, though the materials in these sites were disposed of in accordance with former
10 CFR 20.304 requirements. In certain cases, portions of the buried
materials were required to be shipped off-site to a licensed disposalon this
facility, before NRC released the site for unrestricted use. Based if they have
experience, NRC regulations now require licensees to notify NRCrecords of these
burial sites that may require decommissioning and to maintain V!
burials. TI
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. -- i IN 96-47 August 19, 1996 Discussion
The Timeliness Rule includes requirements pertaining to buildings and outside
areas that have been unused for a period of 24 months, at facilities licensed
under 10 CFR Parts 30, 40, 70. and 72. Outside areas include those where
disposals made pursuant to former 10 CFR 20.304, 20.302. and current
20.2002,which is the focus of this information notice. Further, this
information notice reiterates the NRC Position on the applicability of its
present decommissioning rules. This NRC position was first stated in the
Final Rule on the "General Requirements for Decommissioning Nuclear
Facilities" (53 FR 24021), published June 27, 1988 (hereafter called
"Decommissioning Rule"), and repeated in NRC NUREG-1444, "Site Decommissioning
Management Plan."
Burial of certain quantities of radioactive waste in soil by licensees without
prior Agency approval was authorized on January 29, 1959 (22 FR 548).
Originally, this authorization was codified in former 10 CFR 20.304. On
January 28, 1981, the Commission concluded that it was inappropriate to
continue generic authorizations of burials pursuant to 10 CFR 20.304 without
regard to factors such as location of burial, concentrations of radioactive
material, form of packaging. and notification of NRC, and therefore NRC
rescinded 10 CFR 20.304 (45 FR 71761). As of January 28, 1981, licensees
wishing to perform on-site disposals of the type previously authorized under
10 CFR 20.304 were required to obtain prior NRC approval in accordance with
10 CFR 20.302. The current requirements of 10 CFR 20.2002 (revised from
10 CFR 20.302) remain in force.
The evaluations required before the Commission terminates a license or makes a
regulatory decision related to disposed material were discussed in the supple- mental information to the Decommissioning Rule. There, the Commission stated
that it "...will take a hard look at the extent to which the site has been
previously used to dispose of low-level radioactive waste by land burial and
decide what remedial measures, including removal of such soil off-site, are
appropriate before the site can be released for unrestricted use and the
license terminated." The Timeliness Rule established specific time periods
for decommissioning unused areas of an operating site and for decommissioning
the entire site, on termination of operations.
This information notice describes the recordkeeping requirements for disposals
authorized under former 10 CFR 20.304 and 20.302 regulations, as well as the
current 10 CFR 20.2002. and the notification requirements in the Timeliness
Rule for these disposal sites. Note that, in this information notice, references to 10 CFR 20.2002, also apply to previous disposals under former
-'~\" IN 96-47 August 19. 1996 1. Recordkeeping
At the time of decommissioning, complete records of 10 CFR 20.304. 20.302, and
Section 20.2002 disposals are necessary for NRC to evaluate the acceptability
of the disposals. Each licensee is required. per 10 CFR 20.2108. to maintain
records of disposals made under 10 CFR 20.2002. and to preserve such records
until the Commission terminates the license requiring these records. Former
10 CFR 20.401(c)(3) stated that records of disposals made pursuant to 10 CFR
Section 20.302. and 20.304 should be maintained until the Commission
authorizes their disposition. In addition, the final rule on "Decommissioning
Recordkeeping and License Termination: Documentation Additions," issued
July 26, 1993 (58 FR 39628). requires a single document listing (1)all areas
outside restricted areas where current and previous wastes have been buried, (as documented under 10 CFR Section 20.2108); and (2)other information
necessary to ensure that decommissioning is carried out in accordance with the
Commission's regulations. This rule is applicable to licenses issued under
10 CFR Parts 30, 40, 70, and 72. See 10 CFR 30.35(g)(3). 40.46(f)(3),
Part 70.25(g)(3). and 72.30(d)(3).
At present. 10 CFR 20.2002 states that the licensee must apply to the
Commission for approval of proposed procedures to dispose of licensed material
in a manner not otherwise authorized in 10 CFR Part.20. The former 10 CFR
20.302 required this also. After the application is approved by NRC. records
of actual 10 CFR 20.2002 disposals must be maintained per 10 CFR 20.2108.
These records should be sufficient to demonstrate compliance with the approved
procedures contained in the application.
Pursuant to the former 10 CFR 20.401 requirements, the records of disposals
performed under former 10 CFR 20.304 were required. The following
requirements were placed on burials made under 10 CFR 20.304:
1. the total quantity of licensed and other radioactive material buried
at any one location and time does not exceed. at the time of burial,
1000 times the amount specified in Appendix C to Part 20:
2. the burial is at a minimum depth of four feet. and
3. successive burials are separated by distances of at least 6 feet and
not more than 12 burials are made in any year.
NRC expects that licensees who disposed of radioactive waste in accordance
with Section 20.304. 20.302, and 20.2002, comply with the applicable
recordkeeping requirements. Further, if the NRC determines that the minimum
IN 96-47 August 19, 1996 records required for disposals that may pose a significant risk to the public
after release have not been kept, the licensee may then be expected to
characterize the disposal sites by compiling the necessary information (e.g..
sampling and survey data). The acceptability of the timing and extent of
characterization will be determined by the NRC on a case-by-case basis.
2. Decommissioning
Disposals made pursuant to former 10 CFR 20.304, 20.302, and current 20.2002 at facilities licensed under 10 CFR Parts 30, 40. 70, and 72, and that have
been unused for NRC licensed operations for a period of 24 months, are subject
to the requirements of the Timeliness Rule. For timing provisions see 10 CFR
30.36(d), 40.42(d), 70.38(d), and 72.54(d). The following guidance was
provided in the Timeliness Rule, "Statements of Consideration" (59 FR 36033):
VII Implementation
The timing provisions of this rule begin on the effective date.
Thus, licensees that currently have unused facilities at the time of
publication of the final rule would not need to submit notifications
required by this rule earlier than 2 years after the rule becomes
effective. This provides these licensees with the same period of
time (2 years) in which to determine whether the unused facility
would be put into use again or submit notification as required by
the rule.
Therefore, licensees who have unused outside areas (i.e., burial areas) that
contain elevated levels of licensed radioactive materials, and have declared
that licensed operations have ceased in those areas, are subject to the
Timeliness Rule. In addition. for an outside area (i.e.. burial area) that
has been unused for NRC licensed operations for a period of 24 months prior to
August 15, 1996, the licensee should:
1. No later than October 15. 1996, notify NRC of the above and either:
(1) begin decommissioning; or (2)submit. within 12 months of
notification, a decommissioning plan. if required by the regulations; or
2. Submit a request to extend the above time periods by no later than
September 15, 1996, in accordance with the provisions of the rule.
When notifying NRC, as stated above, the licensee should specify the type of
outside area that is being considered for decommissioning (storage area, Section 20.304 burial, land application, etc.). -
IN 96-47 August 19, 1996 During decommissioning, NRC will evaluate disposals authorized under former
Section 20.304, 20.302. and current 20.2002 to determine their potential
impact on the health and safety of the public. The acceptability of a
disposal will depend on two factors: (1)the potential for the disposed
material to migrate and significantly contaminate the groundwater; and (2)the
potential for significant exposure to members of the public who may. at some
time in the future, develop and use the disposal site for a private residence, farm, business, or other purpose.
The NRC staff is currently developing a methodology that can be used to
determine the acceptability of prior burials. This methodology will be used
as a screening tool to determine which burial sites have the greatest
potential to impact public health and safety. This screening tool will be
based on the total activity disposed of in the burial ground and the potential
for that activity to produce a significant dose to a member of the public.
Staff will require no further effort on sites that pass this screening. Those
sites that do not pass the screening would require more detailed environmental
pathway analysis. This may require site characterization information and a
dose assessment. The staff will consider the magnitude of the projected dose.
and existing radiological criteria for decommissioning, to determine in
conjunction with the objective of keeping residual contamination levels as low
as reasonably achievable if the waste may pose a significant risk to the
public and if the burial requires remediation. This methodology will be
completed and distributed for use by the licensees prior to September 15,
1996.
Currently NRC does not have a list of sites that contain former 10 CFR 20.304 burials. Therefore, it would be beneficial for licensees affected by this
notice, to notify the staff that it is in possession of a burial site, by the
October 15, 1996 deadline, even though many of those sites will not need to be
remediated. In the alternative, NRC will acquire this information during
routine inspections. Once the licensee has notified NRC. it can then use the
screening methodology to determine if its burial site requires further action.
If the burial site passes the screening method, the licensee would notify NRC
that the site passed and would not need to take further action. If the site
does not pass. then the licensee would have to further assess the prior burial
through site characterization and/or radiological surveys and potentially
submit a decommissioning plan and proceed with decommissioning in accordance
with NRC's existing requirements.
IN 96-47 August 19. 1996 This information notice requires no specific action or written response.
However, licensees must comply with the notification requirements in the
Timeliness Rule as stated above. As stated in NRC's revised enforcement
policy (NUREG-1600), failure to meet requirements in the Timeliness Rule can
be classified as a Severity Level III violation and subject to a civil
penalty. Licensees who notify NRC should provide such notices to the
appropriate offices listed in Sections 30.6. 40.5. 70.5. and 72.4 of the
regulations. If you have any questions about the information in this notice.
please contact the technical contacts listed below or the appropriate regional
office.
Margaret V. Federline. Acting Director
Division of Waste Management
Office of Nuclear Material Safety
and Safeguards
Technical contacts: David N. Fauver, NMSS
(301) 415-6625 E-mail: dnf@nrc.gov
Heather M. Astwood, NMSS
(301) 415-5819 E-mail: hma@nrc.gov
Attachments:
1. List of Recently Issued NMSS Information Notices
2. List of Recently Issued NRC Information Notices
4'SS / Ag!
Attachment 1 IN 96-47 August 19. 1996 LIST OF RECENTLY ISSUED
NMSS INFORMATION NOTICES
Information Date of
Notice No. Subject Issuance Issued to
96-35 Failure of Safety Systems 06/11/96 All U.S. Nuclear Regulatory
on Self-Shielded Irradia- Commission irradiator
tors Because of Inadequate licensees and vendors
Maintenance and Training
96-33 Erroneous Data from Defec- 05/224/96 All material and fuel cycle
tive Thermocouple Results licensees that monitor tem- in a Fire perature with thermocouples
96-28 Suggested Guidance Relat- 05/01/96 All material and fuel cycle
ing to Development and licensees
Implementation of Correc- tive Action
96-21 Safety Concerns Related 04/10/96 All NRC Medical Licensees
to the Design of the Door authorized to use brachy- Interlock Circuit on therapy sources in high- Nucletron High-Dose Rate and pulsed-dose-rate remote
and Pulsed Dose Rate
Remote Afterloading Brachy- therapy Devices
96-20 Demonstration of Associ- 04/04/96 All industrial radiography
ated Equipment Compliance licensees and radiography
with 10 CFR 34.20 equipment manufacturers
96-18 Compliance With 10 CFR 03/25/96 All material licensees
Part 20 for Airborne authorized to possess and
Thorium use thorium in unsealed form
96-04 Incident Reporting 01/10/96 All Radiography Licensees
Requirements for and Manufacturers of
Radiography Licensees Radiography Equipment
95-58 10 CFR 34.20: Final 12/18/95 Industrial Radiography
Effective Date Licensees.
95-55 Handling Uncontained 12/6/95 All Uranium Recovery
Yellowcake Outside of a Licensees.
Facility Processing Circuit
Attachment 2 IN 96-47 August 19. 1996 LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
Information Date of
Notice No. Subject Issuance Issued to
96-46 Zinc Plating of Hardened 08/12/96 All holders of OLs or CPs
Metal Parts and Removal for nuclear power reactors
of Protective Coatings
in Refurbished Circuit
Breakers
96-45 Potential Common-Mode 8/12/96 All holders of OLs or CPs
Post-Accident Failure of for nuclear power reactors
Containment Coolers
96-44 Failure of Reactor 8/05/96 All holders of OLs or CPs
Trip Breaker from Cracking for nuclear power reactors
of Phenolic Material in
secondary contact assembly
96-43 Failures of General 08/02/96 All holders of OLs or CPs
Electric Magne-Blast for nuclear power reactors
Circuit Breakers
96-42 Unexpected Opening of 08/05/96 All holders of OLs or CPs
Multiple Safety Relief for nuclear power reactors
Valves
96-41 Effects of a Decrease in 07/26/96 All holders of OLs or CPs
Feedwater Temperature on for pressurized water
Nuclear Instrumentation reactors
96-40 Deficiencies in Material 07/25/96 All holders of OLs or CPs
Dedication and Procurement for nuclear power reactors
Practices and in Audits of
Vendors
96-09. Damage in Foreign Steam 07/10/96 All holders of OLs or CPs
Supp. 1 Generator Internals for pressurized-water
reactors
96-39 Estimates of Decay Heat 07/05/96 All holders of OLs or CPs
Using ANS 5.1 Decay Heat for nuclear power reactors
Standard May Vary Signi- ficantly
OL = Operating License
CP = Construction Permit
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555 June XX, 1996 NRC INFORMATION NOTICE 96-XX: RECORDKEEPING, DECOMMISSIONING NOTIFICATIONS FOR
DISPOSALS AUTHORIZED UNDER FORMER 10 CFR 20.304,
20.302, AND CURRENT 20.2002
Addressees
All U.S. Nuclear Regulatory Commission licensees.
Purpose
NRC is issuing this information notice to: (1) inform addressees of problems
identified at several sites where disposals were made under the authorization
of former 10 CFR 20.304 and 10 CFR 20.2002 (revision to the former 10 CFR
Section 20.302); (2) emphasize recordkeeping requirements; and (3) remind
licensees of the submittal dates (September 15, and October 15, 1996) for
compliance with 'Final Rule on Timeliness in Decommissioning of Materials
Facilities" (59 ER 36026, effective August 15, 1994) (hereafter called the
"Timeliness Rule"). This information notice emphasizes the current NRC
position on recordkeeping and notification requirements for such disposals.
NRC expects that recipients will review the information for applicability to
their facilities and consider actions, as appropriate, to avoid similar
problems to those identified. However, suggestions contained in this
information notice are not new NRC requirements; therefore, no specific action
or written response is required, other than as specified for compliance with
the regulations described herein.
Description of Circumstances
On-site burials have been problematic during the decommissioning of a number
of sites containing such burials. A limited number of past burial sites have
been required to be exhumed during decommissioning, even though the materials
in these sites were disposed of in accordance with former 10 CFR 20.304 requirements. In certain cases, portions of the buried materials were
required to be shipped off-site to a licensed disposal facility, before NRC
released the site for unrestricted use. Based on this experience, NRC
regulations now require licensees to notify NRC if they have burial sites that
may require decommissioning and to maintain records of these burials.
Attachment
I .
IN 96-XX
June XX, 1996 Discussion:
The Timeliness Rule includes requirements pertaining to buildings and outside
areas that have been unused for a period of 24 months, at facilities licensed
under 10 CFR Parts 30, 40, 70, and 72. Outside areas include disposals made
pursuant to former 10 CFR 20.304, 20.302, and current 20.2002, which is the
focus of this information notice. Further, this information notice reiterates
the NRC position on the applicability of its present decommissioning rules.
This NRC position was first stated in the Final Rule on the "General
Requirements for Decommissioning Nuclear Facilities" (53 fR 24021), published
June 27, 1988 (hereafter called "Decommissioning Rule"), and repeated in NRC
NUREG-1444, "Site Decommissioning Management Plan."
Burial of certain quantities of radioactive waste in soil without prior
approval was authorized on January'29, 1959 (22 ER 548). Originally, this
authorization was codified in former 10 CFR 20.304. On January 28, 1981, the
Commission concluded that it was inappropriate to continue generic
authorizations of burials pursuant to 10 CFR 20.304 without regard to factors
such as location of burial, concentrations of radioactive material, form of
packaging, and notification of NRC, and therefore NRC rescinded 10 CFR 20.304
(45 FR 71761). As of January 28, 1981, licensees wishing to perform on-site
disposals of the type previously authorized under 10 CFR 20.304 were required
to obtain prior NRC approval in accordance with 10 CFR 20.302. The current
requirements of 10 CFR 20.2002 (revised from 10 CFR 20.302) remain in force.
The evaluations required before the Commission terminates a license or makes a
regulatory decision related to disposed material were discussed in the supple- mental information to the Decommissioning Rule. There, the Commission stated
that it "...will take a hard look at the extent to which the site has been
previously used to dispose of low-level radioactive waste by land burial and
decide what remedial measures, including removal of such soil off-site, are
appropriate before the site can be released for unrestricted use and the
license terminated." The Timeliness Rule established specific time periods
for decommissioning unused areas of an operating site and for decommissioning
the entire site, on termination of operations.
This information notice describes the recordkeeping requirements for disposals
authorized under former 10 CFR 20.304 and 20.302 regulations, as well as the
current 10 CFR 20.2002, and the notification requirements in the Timeliness
Rule for these disposal sites. Note that, in this information notice, references to 10 CFR 20.2002, also apply to previous disposals under former 10
CFR 20.302.
Attachment
IN 96-XX
June XX, 1996 1. Recordkeeping
At the time of decommissioning, complete records of 10 CFR 20.304, 20.302, and
Section 20.2002 disposals are necessary for NRC to evaluate the acceptability
of the disposals. Each licensee is required, per 10 CFR 20.2108, to maintain
records of disposals made under 10 CFR 20.2002, and to preserve such records
until the Commission terminates the license requiring these records. Former
10 CFR 20.401(c)(3) stated that records of disposals made pursuant to 10 CFR
Section 20.302, and 20.304 should be maintained until the Commission
authorizes their disposition. In addition, the final rule on 'Decommissioning
Recordkeeping and License Termination: Documentation Additions," issued July
26, 1993 (58 FR 39628), requires a single document listing (1) all areas
outside restricted areas where current and previous wastes have been buried, as documented under 10 CFR Section 20.2108.); and (2) other information
necessary to ensure that decommissioning is carried out in accordance with the
Commission's regulations. This rule is applicable to licenses issued under 10 CFR Parts 30, 40, 70, and 72. See 10 CFR 30.35(g)(3), 40.46(f)(3),
Part 70.25(g)(3), and 72.30(d)(3).
At present, 10 CFR 20.2002 states that the licensee must apply to the
Commission for approval of proposed procedures to dispose of licensed material
in a manner not otherwise authorized in 10 CFR Part 20. The former 10 CFR
20.302 required this also. After the application is approved by NRC, records
of actual 10 CFR 20.2002 disposals must be maintained per 10 CFR 20.2108.
These records should be sufficient to demonstrate compliance with the approved
procedures contained in the application.
Pursuant to the former 10 CFR 20.401 requirements, the records of disposals
performed under former 10 CFR 20.304 were required. The following
requirements were placed on burials made under 10 CFR 20.304:
1. the total quantity of licensed and other radioactive material buried
at any one location and time does not exceed, at the time of burial,
1000 times the amount specified in Appendix C to Part 20;
2. the burial is at a minimum depth of four feet, and
3. successive burials are separated by distances of at least six feet
and not more than 12 burials are made in any year.
NRC expects compliance with the applicable recordkeeping requirements for
Section 20.304, 20.302, and 20.2002 disposals. Further, licensees that NRC
has identified by NRC as not having the minimum records required for disposals
that may pose a significant risk to the public after release, have been
Attachment
IN 96-XX
June XX, 1996 expected to characterize the disposal sites by compiling the necessary
information (e.g., sampling and survey data). The timing and extent of
characterization will be determined on a case-by-case basis.
2. Decommissioning
Disposals pursuant to former 10 CFR 20.304, 20.302, and current 20.2002 at
facilities licensed under 10 CFR Parts 30, 40, 70, and 72, and that have been
unused for NRC licensed operations for a period of 24 months, are subject to
the requirements of the Timeliness Rule. For timing provisions see 10 CFR
30.36(d), 40.42(d), 70.38(d), and 72.54(d). The following guidance was
provided in the Timeliness Rule, "Statements of Consideration" (59 FR 36033):
VII Implementation M
The timing provisions of this rule begin on the effective date.
Thus, licensees that currently have unused facilities at the time of
publication of the final rule would not need to submit notifications
required by this rule earlier than 2 years after the rule becomes
effective. This provides these licensees with the same period of
time (2 years) in which to determine whether the unused facility
would be put into use again or submit notification as required by
the rule.
Therefore, licensees who have unused buildings or outside areas that contain
elevated levels of licensed radioactive materials, and have declared that
licensed operations have ceased in those areas, are subject to the Timeliness
Rule. In addition, for a building or outdoor area (i.e., burials) that has
been unused for NRC licensed operations for a period of 24 months prior to
August 15, 1996, the licensee should:
1. No later than October 15, 1996, notify NRC of the above and either:
(1) begin decommissioning; or (2) submit, within 12 months of
notification, a decommissioning plan, if required by the regulations; or
2. Submit a request to extend the above time periods by no later than
September 15, 1996, in accordance with the provisions of the rule.
When notifying NRC, as stated above, the licensee should specify the type of
outside area that is being.considered for decommissioning (storage area, Section 20.304 burial, land application, etc.).
During decommissioning, NRC evaluates disposals authorized under former
Section 20.304, 20.302, and current 20.2002 to determine their potential
Attachment
A
IN 96-XX
June XX, 1996 impact on the health and safety of the public. The acceptability of a
disposal depends on two factors: 1) the potential for the disposed material
to migrate and significantly contaminate the groundwater; and 2) the potential
for significant exposure to members of the public who may, at some time in the
future, develop and use the disposal site for a private residence, farm, business, or other purpose.
The NRC staff is currently developing a methodology that can be used to
determine the acceptability of prior burials. This methodology will be used
as a screening tool to determine which burial sites have the greatest
potential to impact public health and safety. This screening tool will be
based on the total activity disposed of in the burial ground and the potential
for that activity to produce a significant dose to a member of the public.
Staff will require no further effort on sites that pass this screening. Those
sites that do not pass the screening would require more detailed environmental
pathway analysis. This may require site characterization information and a
dose assessment. The staff will consider the magnitude of the projected dose, and existing radiological criteria for decommissioning, to determine in
conjunction with the objective of keeping residual contamination levels as low
as reasonably achievable if the waste may pose a significant risk to the
public and if the burial requires remediation. This methodology will be
completed and distributed for use by the licensees prior to September 15,
1996.
Currently NRC does not have a list of sites that contain former 10 CFR 20.304 burials. Therefore, it would be beneficial for a licensee to notify the staff
that it is in possession of a burial site, by the October 15, 1996 deadline, even though many of those sites will not need to be remediated. In the
alternative, NRC will acquire this information during routine inspections.
Once the licensee has notified NRC, it can then use the screening methodology
to determine if its burial site requires further action. If the burial site
passes the screening method, the licensee would notify NRC that the site
passed and would not need to take further action. If the site does not pass, then the licensee would have to further assess the prior burial through site
characterization and/or radiological surveys and potentially submit a
decommissioning plan and proceed with decommissioning in accordance with NRC's
existing requirements.
This information notice requires no specific action or written response.
However, licensees must comply with the notification requirements in the
Timeliness Rule as stated above. As stated in NRC's revised enforcement
policy (NUREG 1600), failure to meet requirements in the Timeliness Rule can
be classified as a Severity Level III violation and subject to a civil
penalty. If you have any questions about the information in this notice, Attachment
IN 96-XX
June XX, 1996 please contact the technical contact listed below or the appropriate regional
office.
Margaret V. Federline, Acting Director
Division of Waste Management
Office of Nuclear Material Safety and
Safeguards
Technical contacts: David N. Fauver, NMSS
(301) 415-6625 Internet: dnf~nrc.gov
Heather M. Astwood, NMSS
(301) 415-5819 Internet: hma~nrc.gov
Attachments:
1. List of Recently Issued NMSS Information Notices
2. List of Recently Issued NRC Information Notices
Attachment
total disposed of 8 burial ground
ictivity and the pote , for that activity to produce
a significant dose to a memo _f the public. Staff willthereqiuh/ no further effort on sites
that pass this screening. Those sites that do not pass require screening method would require
more detailed environmental pathway analysis. This may site characterization
information and a dose assessment. The staff will consider the magnitude of the projected
dose, and existing radiological criteria for decommissioning to determine, inconjunction with
the objectives of keeping residual contamination levels ALARA, remediation. to determine if the waste may
pose a significant risk to the public and the burial requires This methodology
to September 15, 1996.
will be completed and distributed for use by the licensees prior
NRC does not currently have a list of sites that contain former 10 CFR 20.304 burials. It
would therefore be beneficial for licensees to notify the staff that they are in possession of
a burial site by the October 15, 1996 deadline, even though they ofcanthosemany sites will not need
the screening
to be remediated. Once the licensees have notified the further action. Ifuse
NRC, then
the burial site
methodology to determine if their burial site requires that the site passed and would not
passes the screening method, the licensee would notify NRC
then the licensee would have to submit a
need further action. Ifthe site does not pass, with NRC's existing
decommissioning plan and proceed with decommissioning in accordance
requirements.
This information notice requires no specific action or writtenRule response. However, licensees
must comply with the notification requirements in the 'Final on Timeliness in
Decommissioning,w as stated above. Failure to meet requirements in the Timeliness Rule can be
classified as a Severity Level III violation. Ifyou have any questions about the information
regional
inthis notice, please contact the technical contact listed below or the appropriate
office.
Margaret V. Federline, Acting Director
Division of Waste Management
Office of Nuclear Materials Safety and
Safeguards
Technical contact: David N. Fauver, NMSS
(301) 415-6625 Internet: dnf~nrc.gov
Heather M. Astwood, NMSS
(301) 415-5819 Internet: hma@nrc.gov
Attachments:
1. List of Recently Issued NMSS Information Notices
2. List of Recently Issued NRC Information Notices
CONCURRENCE
SUBJECT: Information Notice 96-_, 'Recordkeeping and Decommissioning Notifications for
Disposals Authorized under Former 10 CFR 20.304, 20.302, and current 20.304"
S:\DWM\LLDP\HMA\BURIAL .IL *See previous concurrence l
OFC DWM I DWM l DWM I [Wm OGCl
NAME HAstwood * PSobel * RNelson * MWeber * STreby *
DATE 6/10/96 6/10/96 6/11 96 6/17/96 6/18/96 OFC INNS l NRR QWM l
NAME DCool CMiller * MFederline
DATE 6/19/96 1 6/18/96 / /96 I n /
IN - Ofu J.ur
C . COVER E D GOVtK & LhLU4UKL " - "V Our I
- . V_T mmee4 ^ e 12
-
radiological criteria for decommissioning to determine, in conjunction with
the objectives of keeping residual contamination levels ALARA, if the waste
may pose a significant risk to the public and the burial therefore requires
remediation. This methodology will be completed and distributed for use by
the licensees prior to September 15, 1996.
Once both the information notice and the methodology are issued, the licensees
should be: 1) informed of the requirements in the rule; 2) have sufficient
time to notify NRC by the October 15, 1996 deadline; and 3) have a methodology
to determine if they need to submit a decommissioning plan by the next
deadline (12 months after notification). In addition NRC staff will only have
to review on a case-by-case basis, the sites that do not pass the screening
method. Limited resources are included in the FY 96-97 budget to support
these reviews.
A second generic communication will be sent to all licensees providing
additional information related to the application of the Timeliness Rule to
activities in addition to on-site burials that were not included in this
Information Notice.
This information notice is necessary to ensure licensees are aware of the
schedule contained in the rule so that they can comply with the notification
requirements in a timely fashion. The staff intends to issue this IN within
10 days of the date of this letter unless otherwise directed by the
Commission.
SECY please track.
Attachment: Draft NRC Information Notice 96-XX:
Recordkeeping and Decommissioning for
Disposals Authorized Under
10 CFR 20.304 and 20.2002.
cc: OGC
SECY
DISTRIBUTION: *w or *w/o att
&ntmal=EAJde LLDP r/f JGreeves MFederline JAustin
JHolonich NMSS r/f DWM t/f ?Well WBell
RNelson TCJohnson PUBLIC
DOCUMENT NAME:s:\dwm\lidp\onsite.mem *See Previous concurrence
iF LLDP l LLDP lLLDP l LLDP OGCl
NAME HAstwoood * EKraus * PSobel * RNelson * RFonner *
/14/96 6 /14/96 I 6/14/96 I 6/14/96 6/24/96 OFCDWM lNMS lEOI/WS EMSS
NAME MFederline* JGreeves * *
CPaperiello vor
DATE 6/17/96 969 6/19/96 l 7/3//96 96 OFFICIAL RECORD COPY
ACNW: YES NO
IG : YES = NO Delete file after distribution: Yes No
LSS : YES NO
06/14/1995 12;18 2023375133 FETZERRAUSL INC. PAGE 05
3 rvmadiatod. Once the licensees hbav notifed. NRC they can then use the
screening methodology to determine If their hurial file requires further
action. If the burial site passes the screening method the licensee would
notify IRt that the site passed and would not nmed furtAar action. If the
sit does not pass, then the licensee would have to submit a decomlssioning
plan In accordance with the rule.
This/for tion 4tce is necessary to ensure licensees are awva f the
scheaule contairne In the rl so that they can comply with t4 otiffeatitn
reguiaments in a tilmey fashion. Th staff Intends to issue is ithifn
e lD ays of the date of this letter unless otherwise direc the
n.
isbs1 /
Attachment: Infomation Notice, cc, OCC
SECY
PIStRlpTMM: low r1 o* tt
cent F11e LLWP r/f 06reevi KFderl le tAuitln
JMolontch H1SS r/f DM t/ lell LBel1 AMOl co TC~ohnson PIC
DOcu Agsy__te.W
C HPLOPP LLDP LQ G
ENAE Hkbsmouvd PSobel.- Rk~elsn Manonr
r
ER Hoderlin~ Greves CI'aperillo HLTh~pom -lNT yl r
DATE 9 6 ACNV: TFS
I& .:YES
_ O _- 'W - W I
I YE __ no
No _- . Delete file* after distribution: N _Y
Yes No_ __
so, a 1oo, nN 9S: I 9G .PtT
£0d OO~ liInb
N8S:L M6S-S~TP-10E 13 i WMa/S8WN/OSN
P Q S N /~
The Commissioners 3 the waste may pose a significant risk to the public and the burial requires
remediation. This methodology will be completed and distributed for use by
the licensees prior to September 15, 1996.
Once both the information notice and the methodology are issued, the licensees
should be: 1) informed of the requirements in the rule; 2) have sufficient
time to notify NRC by the October 15, 1996 deadline; and 3) have a methodology
to determine if they need to submit a decommissioning plan by the next
deadline (12 months after notification). In addition NRC staff will only have
to review on a case-by-case basis, the sites that do not pass the_ sreening
method. Limited resources are included in the FY 96-97 budge o suppoft
these reviews.
This information notice is necessary to ensure licens s are aware of the
schedule contained in the rule so that they can couy with the notification
requirements in a timely fashion. The staff int ds to issue this IN within
10 days of the date of this letter unless othe ise directed by the
Commission.
Attachment: NRC Information Notice 96-XX:
Recordkeeping and Decommissi ing for
Disposals Authorized Under
10 CFR 20.304 and 20.2002 cc: OGC
SECY
DISTRIBUTION: *w or *w att
Central File LLOP r/f JGreeves MFederline JAustin
JHolonich NMSS r f DWM t/f MBell LBell
RNelson TCJo son PUBLIC
DOCUMENT NAME:s:\dwm\lldp\o site.mem *See Previous concurrence ___ A.4. I
OR C LLDP l 4 LLDP
g LLDP OGC%
NAME HAstwoood * Kraus PSobel * RNelson *
DATE 16/14/96 1/ 6 /14i6l 6/14/96 6/14/96 £ /96 OR DWM W S
NS NMSS l DEDO l EDOl
NAME MFeder ne* JGreeves a CPaperiello HLThompson JMTaylor
DATE 6/17/96 l /11/96 l f I / /96 t/96 l /96 OFFICIAL RECORD COPY
ACNW: YES NO
IG : YES = NO Delete file after distribution: Yes No
LSS : YES NO
The Commissioners 3 the waste may pose a significant risk to the public and the burial requires
remedlation. This methodology will be completed and distributed for use by
the licensees prior to September 15, 1996.
Once both the information notice and the methodology are issued, the licensees
should be: 1) informed of the requirements in the rule; 2) hav sufficient
time to notify NRC by the October 15, 1996 deadline; and 3) h e a methodology
to determine if they need to submit a decommissioning plan b the next
deadline (12 months after notification). In addition NRC taff will only have
to review on a case-by-case basis, the sites that do not piss the screening
method. Limited resources are included in the FY 96-97 udget to support
these reviews.
This information notice is necessary to ensure lice ees are aware of the
schedule contained in the rule so that they can co ply with the notification
requirements in a timely fashion. The staff mt ds to issue this IN within
10 days of the date of this letter unless othe se directed by the
Commission.
Attachment: NRC Information Notice'96-XX:
Recordkeeping and Decommission g for
Disposals Authorized Under
10 CFR 20.304 and 20.2002.
cc: OGC
SECY
DISTRIBUTION: *w or *w/o t
Central File LLOP r/f JGreeves MFederline JAustin
JHolonich NMSS r/f DWM t/f MBell LBell
RNelson TCJohns PUBLIC
DOCUMENT NAME:s:\dwm\lldp\ons e.mem *See Previous concurrence .i
OFC LLDP l l LLDP/ jLLDP LLDP OGC
NAME HAstwoood * E aus * PSobel * RNelson * RFonner
DATE 6/14/96 [ /67- 6/ l 6/14/96 l 6/14/96 _ / /96 OFC DWM NMI$%( DD EDO
NAME MFederline* W Afprje Ao HLThompson JMay.lo
DATE /96 96 RcInnn ir mo
/96
/6/96
.rrf'VIff
urr I1ML nLUonu Uvr l
ACNW: YES _ NO
IG : YES _NO N Delete file after distribution: Yes - No -
LSS : YES _ NO
I --
The Commissioners 3 the waste may pose a significant risk to the public and the burial requires
remediation. This methodology will be completed and distributed for use by
the licensees prior to September 15, 1996.
Once both the information notice and the methodology are issued, the licensees
should be: 1) informed of the requirements in the rule; 2) have sufficient
time to notify NRC by the October 15, 1996 deadline; and 3) have a methodology
to determine if they need to submit a decommissioning plan by the next
deadline (12 months after notification). In addition NRC staff will only have
to review on a case-by-case basis, the sites that do not pass the screening
method. Limited resources are included in the FY 96-97 budget to s pport
these reviews.
This information notice is necessary to ensure licensees are are of the
schedule contained in the rule so that they can comply with he notification
requirements in a timely fashion. The staff intends to I ue this IN within
10 days of the date of this letter unless otherwise dir ted by the
Commission.
Attachment: NRC Information Notice 96-XX:
Recordkeeping and Decommissioning fo
Disposals Authorized Un
10 CFR 20.304 and 20. 02.
cc: OGC
SECY
DISTRIBUTION: *w or *w/o att
Central File LLDP r/f JG eves MFederline JAustin
JHolonich NMSS r/f M t/f MBell LBell
RNelson TCJohnson PUBLIC
DOCUMENT NAME:s:\dwm\lidp\onsite em *See Previous concurrence -pi=1 OF LLDP lLD LLDP LLDP OGCll
NAM HAstwoood * EK s * PSobel * RNelson * RFonner
DATE 6/14/96 X/114196 6/14/96 6/14/96 -. / /96 FC 1 DWM [ NMSS I NMSS l 1DEDO EDO l
NAME j Weeder JGreeves kXftperiello hompson JMTaylor
DATE h ?/96 / /96 1 / /96 /96 OF ICIAL RECORD COP~Y
ACNW: YES _ NO
No
IG: YES = NO Delete file after distribution: Yes
LSS : YES _ NO
3 determine if they need to submit a decommissioning plan by the next deadline
(12 months after notification). In addition NRC staff will only have to
review on a case-by-case basis, the sites that do not pass the screening
method.
NRC does not currently have a list of sites which contain 10 CFR 20.304 burials. It would therefore be beneficial for licensees to notify the staff
that they are in possession of a burial site by the October 15, 1996 deadline
even though many of those sites will not need to be remediated. Once the
licensees have notified the NRC, they can then use the screening methodology
to determine if their burial site requires further action. If th burial site
passes the screening method, the licensee would notify NRC that the site
passed and would not need further action. If the site does n pass, then the
licensee would have to submit a decommissioning plan in acc dance with the
rule.
This Information notice is necessary to ensure licens s are aware of the
schedule contained in the rule so that they can comr y with the notification
requirements in a timely fashion." The staff inte s to issue this IN within
10 days of the date of this letter unless othe se directed by the
Commission.
Attachment: Information Notice
cc: OGC
SECY
DISTRIBUTION: *w or *w att
Central File LLDP r JGreeves MFederline JAustin
JHolonich NMSS /f DWM t/f WBell WBell
RNelson TCJ nson PUBLIC
DOCUMENT NAME:s:\dwm\ll \onsite.mem *See Previous concurrence
lOFCR LLDP I A LLDP I LLDP I l LLD 'I OGC
NAME HAstwoooo/* EKraus *f- Sobel * RFonner
DATE l 6/14/9e 4 l {//M/96 l ,6/14/96 l 6 //f 96 / /96 l
OFC DWM I NMSS I NMSS l DEDO lI
NAME MFederline JGreeves CPaperiello HLThompson JMTaylor
DATE I /96 l / /96 / /96 Ll
UltILIAL KtLUKU LUIr
ACNW: YES __NO
IG : YES - NO Delete file after distribution: Yes No
LSS : YES = NO
KJ
3 remediated. Once the licensees have notified the NRC, they can then use the
screening methodology to determine if their burial site requires further
action. If the burial site passes the screening method, the licensee would
notify NRC that the site passed and would not need further action. If the
site does not pass, then the licensee would have to submi a decommissioning
plan in accordance with the rule.
This Information Notice is necessary to ensure licensee are aware of the
schedule contained in the rule so that they can comply ith the notification
requirements in a timely fashion. The staff intends o issue this IN within
10 days of the date of this letter unless otherwise irected by the
Commission. /
Attachment: Information Notice
cc: OGC
SECY
DISTRIBUTION: *w or *w/o att
Central File LLDP r/f JGre es MFederline JAustin
JHolonich NMSS r/f DWM t/f MBell IBell
RNelson TCJohnson PU LIC
DOCUME T NAME:s.\dwm\lldp\hma\onsit .mm
OFC LLDP L LDP I LIIP OGC I
NAME HAstwoood tM EKraus / PSobel a I RNelson RFonner
DATE 16//Y/96 L I /
/ l C/0 /96 //96 / /96 l96 OFC DWM ISs NMSSI DEDO I
1EDO
NAME MFederline __ Greeves CPaperiElo HLThompson JMTaylor
DATE / /9& l / /96 l / /96 l / /96 1_ / /96 l
.e no-rvTa1 A l%11nhU
urOFlFlAL KLLUKU LtrT
ACNW: YES _ NO
IG : YES = NO Delete file after distribution: Yes No -
LSS : YES _ NO