ML14143A037

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Overview of Nrc'S License Termination Rule
ML14143A037
Person / Time
Site: West Valley Demonstration Project, P00M-032
Issue date: 05/28/2014
From: Rachel Johnson
NRC/FSME/DWMEP/DURLD/SPB
To:
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ML14143A059 List:
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Download: ML14143A037 (14)
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Text

OVERVIEW OF NRCS LICENSE TERMINATION RULE Presentation at the West Valley Quarterly Public Meeting May 28, 2014 Robert L. Johnson 1

REGULATIONS AND GUIDANCE

  • Regulations:

g 10 CFR 20 Subpart p E ((License Termination Rule (LTR))

  • Statements of Consideration (SOC) for LTR
  • Guidance: Consolidated Decommissioning Guidance, NUREG-1757, Vol. 1, 2, and 3
  • Commission Commissions s West Valley Policy Statement (WVPS)

LTR STATEMENT OF CONSIDERATIONS (SOC)

  • Source of extensive informationrationale for provisions, responses tot comments t
  • Commission preference for unrestricted release
  • Recognition that there may be cases where achieving unrestricted release would not be reasonable (e (e.g.,

g where cost would be excessive)

  • Flexibility

- Consistent set of criteria for the range of facilities and site conditions

- License termination approaches available: unrestricted release, restricted release, alternate criteria

- Licensee Li proposes decommissioning d i i i methodsth d ffor meeting ti ddose criteria

- NUREG-1757, Vol. 2, Rev.1, Section 2 3

GENERAL PROVISIONS, UNRESTRICTED RELEASE

  • General provisions p

- 10 CFR 20.1401

- 1000 year compliance period

- DOE/NYSERDA EIS should analyze beyond 1000 yr (WVPS SOC)

  • Unrestricted release license termination

- 10 CFR 20 20.1402 1402

- 25 mrem/yr and ALARA

  • Licensee could p propose p both unrestricted and restricted release for different portions of the site 4

RESTRICTED RELEASE ELIGIBILITY

  • Purpose

- Initial eligibility for restricted releasenot approval

- Screen out sites that should be removing contamination to achieve unrestricted release

  • A site would be eligible if further reductions in residual radioactivity necessary to comply with the provisions of 20.1402

- would result in net public or environmental harm or

- were not being made because the residual levels associated with restricted conditions are ALARA.

5

RESTRICTED RELEASE ELIGIBILITY (CONT.) (CONT )

  • Commissions Orders regarding Shieldalloy

- Series of Shieldalloy lawsuits with associated Court and Commission actions

- Explain original meaning of provision and clarifies the analysis is limited to further removal of residual radioactivity

- Not a comparison of individual doses of restricted and unrestricted release and selection of the lowest dose

- Cost benefit analyses following NUREG-1757, Appendix N

  • Costs/benefits of further removal of residual radioactive material from levels proposed to remain onsite to the unrestricted release level
  • Net public harm analysis (costs of harm to people and environment compared to benefits, e.g., collective dose averted dollar value)
  • ALARA (total costs compared to benefits, benefits e e.g.,

g collecti collective e dose averted a erted dollar value) 6

RESTRICTED RELEASE INSTITUTIONAL CONTROLS (ICs)

  • Legally enforceable ICs to restrict future site use

- For higher risk sites (100-500 mrem/yr or > 100 yr half life

- State or Federal government ownership/control

  • Five-year reviews
  • Independent p third pparty/government yg entityy backup p
  • NRC retains authority to take action if ICs fail (SOC) 7

RESTRICTED RELEASE ENGINEERED BARRIERS (EBs)

  • EBs to mitigate

- Human intrusion

- Adverse natural p processes ((e.g.,

g erosion))

- Release and transport of radionuclides

  • Contribute to meeting dose criteria; no prescriptive LTR requirements
  • EBs are not ICs and are assumed to degrade rather than immediately and totally fail for the IC fail dose criteria 8

RESTRICED RELEASE FINANCIAL ASSURANCE

- 10 CFR 20.1403(c)

- NUREG-1757, Vol. 3

Purpose:

enables independent third party party, including a government custodian, to assume and carryout y responsibilities p for controls and maintenance

- Requirements for amounts and mechanisms (e.g., government entity statement of intent) 9

RESTRICTED RELEASE ADVICE FROM AFFECTED PARTIES

  • NUREG- 1757 Vol. 1
  • Seek advice from affected parties on specific questions
  • incorporate incorporate as appropriate appropriate ,
  • Provide a publicly available summary of discussions, d scuss o s, a and d docu document e t ad advice ce in tthe e

decommissioning plan 10

RESTRICTED RELEASE DOSE CRITERIA

  • If ICs no longer in effect ((dosedose caps) caps )

o Assumption of immediate and total failure o ALARA o 100 mrem/yr or o 500 mrem/yr Further reductions in residual radioactivity necessary to comply with 100 mrem/yry are not technicallyy achievable,, prohibitively p y expensive, or would result in net public or environmental harm o If ICs fail NRC retains authority to take action (SOC) 11

RESTRICTED RELEASE ALTERNATE CRITERIA

  • Alternate criteria license termination

- 10 CFR 20.1404

- NUREG-1757, Vol. 1; Rev. 2

- Alleviates the need for exemptions for exceeding doses listed below (SOC)

- Exceed 25 mrem/yr (1402, 1403(b), 1403(d)(1)(i)(A))

- Not to exceed 100 mrem/yr from all man-made sources

- Restrictions required per 1403; reduce doses to ALARA

- Commission approval after considering public and EPA comments

  • Exemptions

- Consider granting exemptions

- WVPS: if LTR compliance is technically impractical or prohibitively expensive, but maintain protection 12

NO LICENSE TERMINATION

  • Keepp under license

- SOC: Alternative to license termination if requirements cannot be met

- WVPS: longlong-term term or perpetual license where LTR requirements are technical impractical or prohibitively expensive

- NUREG-1757, NUREG 1757 Vol Vol. 1; Rev Rev. 2 2, Section 17 17.77 and Appendix M

  • Possession only license for long-term control approved by Commission
  • Last resort (e.g., if independent third party requirement is not met) 13

RESTRICTED RELEASE CONCLUSION

  • A system of controls to ensure safety

- 25 mrem/yr with restrictions

- Legally enforceable and durable ICs

- EBs designed for site

- Monitoring and maintenance; 5-year rechecks

- Independent third party/government backup to site owner/custodian

- Financial assurance for third party

- Dose caps if ICs fail: safety net

- Remain licensed, if needed 14

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