ML19269E980
| ML19269E980 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1978 |
| From: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| References | |
| NUREG-0436, NUREG-436, NUDOCS 7911110201 | |
| Download: ML19269E980 (60) | |
Text
NUREG-0436 PLAN FOR REEVALUATION OF NRC POLICY ON DECOMMISSIONING OF NUCLEAR FACILITIES March 1978 2198 196 Office of Standards Development U. S. Nuclear Regulatory Commission 79111102p/
Available from National Technical Information Service Springfield, Virginia 22161 Price: Printed Copy $5.25 ; Microfiche $3.00 The price of this document for requesters outside of the North American Continent can be obtained from the National Technical Information Service.
2198 197
NUR EG-0436 PLAN FOR REEVALUATION OF NRC POLICY ON DECOMMISSIONING OF NUCLEAR FACILITIES Manuscript Completed: March 1978 Date Published: March 1978 Division of Engineering Standards Office of Standards Development 71OO 109 U. S. Nuclear Regulatory Commission CI/U i/e Washington, D. C. 20555
Foreword by Nuclear Regulatory Commission Staff While the Commission's regulatory guides and regulations embody the NRC's current approach to reactor decommissioning, initiatives are under-way to improve the Commission's future decommissioning practices for all nuclear facilities.
The present decommissioning regulations, originally promulgated by the Atomic Energy Commission, are contained in Sec-tions 50.33(t) and 50.82 of 10 CFR Part 50.
These regulations require applicants for power reactor operating licenses to furnish the Commission with sufficient information to demonstrate that they can obtain the funds needed to meet both operating costs as well as the estimated costs of permanently shutting down the facility and maintaining it in a safe condi-tion.
The development of detailed, specific decommissioning plans for nuclear puser plants is not currently required until the licensee seeks to terminate his operating license.
Should license termination be desired, Section 50.82 of 10 CFR Part 50 ree,uires that the licensee provide the Commission with information on the proposed procedures for disposal of the radioactive material, decontamination of i.he site and procedures to assure public safety.
Present policy, as ccstained in Regulatory Guide 1.86, considers four acceptable alternatives for retirement of nuclear reactors.
These include:
mothballing or protective storage; in place entombment; 2198 199
removal of radioactive components and dismantling; and conversion to a new nuclear or fossil fuel system.
In this regard five licer. sed nuclear power reactors, four demonstration reactors, six licensed test reactors and about fifty research reactors have been shut down using one or another of the techniques listed above.
Recognizing that the current generation of large commercial reactors and supporting nuclear facilities would substantially increase future decommissioning needs, the NRC staff began an in-depth review and re-evaluation of NRC's regulatory approach to decommissioning in 1975.
Major technical studies on decommissioning have been initiated at Battelle Pacific Northwest Laboratory in order to provide a firm information base on the engineering methodology, radiation risks, and estimated costs of decommissioning light water reactors and associated fuel cycle facilities.
The Nuclear Regulatory Commission is now considering development of a more explicit overall policy for nuclear facility decommissioning and amending its regulations in 10 CFR Parts 30, 40, 50, and 70 to include more specific guidance on decommissioning criteria for production and utilization facility licensees and byproduct, source, and special nuclear material licensees.
Attachment D of the following report contains a copy of an Advance Notice of Proposed Rulemaking which has been published in the Federal Register (FR 43 10370-10371, March 13, 1978; FR Doc. 78-6461).
The following report sets forth in detail the NRC staff plan for the development of an overall NRC policy on decommissioning of nuclear facili-ties.
The information in this report, including any comments, will be 2198 200
included in the record for consideration by the Commission in estab-lishing criteria and new standards for decommissioning.
Persons wishing to comment on this report should mail their comments to:
Chief Fuel Process Systems Standards Branch Division of Engineering Standards Office of Standards Development Washington, D.C.
20555 2198 201 iii
Plan for Reevaluation of NRC Policy on Decommissioning of Nuclear Facilities Table of Contents P,_agg Foreword............................................................
i 1.0 Introduction..................................................
1 1.1 Purpose of Plan...........................................
I 1.2 Implementation of P1an....................................
2 1.3 Current Regulations and Guidance......
3 1.3.1 Reactor Review Practice...........................
7 1.3.2 Fuel Cycle Facility Review Practice................
9 2.0 Occasion for Reevaluation......................................
10 2.1 History of Decommissioning................................
11 2.1.1 Reactors...........................................
11 2.1.2 Fuel Cycle Facilities..............................
11 2.2 Increased Interest........................................
16 3.0 Reevaluation of Policy.........................................
17 3.1 The Need for Foresight................
17 3.2 Apparent Differences in Current Policy....................
18 3.3 Policy Alternatives.......................................
19 2198 202
Table of Contents (Cont'd)'
Page 4.0 The Existing Reevaluation Program...............
20 4.1 Decommissioning Studies...................................
20 4.1.1 Technical Approach.................................
21 4.1.2 Planned Schedule............................
22 4.1.3 Facilitating Decommissioning.......................
23 4.2 Other Studies.............................................
24 5.0 Development of New Decommissioning Policy............
25 5.1 Schedule and Priorities of Existing Work..................
25 5.2 Timing and Mechanism for Developing a New Decommissioning Policy....................................
26 5.3 Principle Issues in Decommissioning Policy...............
27 5.3.1 Acceptability of Radioactive Residues.............
28 5.3.2 Financial Assurance.............................
31 5.3.3 Generic Applicability..............................
33 5.4 Publications and Reports............................
35
. Attachment A..................................
A-1 Attachment B........................................................
B-1 Attachment C.......................................
C-1 Attachment D.................................
D-1 2198 203 V
1.0 Introduction The nuclear field is reaching the degree of maturity that requires increased attention to the proper retirement or decommissioning of facilities.
With this maturity, more nuclear plants and equipment will be entering the terminal period of their useful lives.
Since most of these facilities have been involved in handling radioactive materials the emphasis must be upon the safety of the process of decommissioning and of the residue.
The environmental impacts of decommissioning may be high.
Special attention will be needed to minimize these impacts.
The important ele-ments of safety and cost can be assessed and controlled in a systematic manner through the development of decommissioning criteria.
This plan deals with the development of the background and the criteria required.
As an introduction to the details of the plan the purpose and imple-mentation are discussed first, followed by a review of current status.
1.1 Purpose of Plan The general purpose of this plan is to assure that the Nuclear Regulatory Commission (NRC):
(1) develops a general decommissioning policy, (2) develops the attendant changes for regulations, (3) develops the detailed information needed for use in licensing decisions for decom-missioning, and (4) establishes guidance for facilitation of decommissioning.
This plan is intended to develop a clear and definite policy on decommissioning.
Attendant changes in rules to implement the policy will also need to be developed.
Additional information will be required on a 1
2198 204
schedule to support the policy and rule change activities.
A variety of types of facilities will be involved and will include reactors, fuel cycle plants and sites, and waste disposal grounds.
Details will be needed on specific decommissioning operations such as decontamination, disassembly, and waste disposal.
This will involve methodology for both temporary and permanent decommissioning and the associated safety and costs.
The detailed information will allow the preparation and modification of regulations and guides as needed to assure the safety of decommissioning activities.
It is anticipated that this will involve the modification of existing regulations and the preparation of specific new ones dealing exclusively with the control of decommissioning.
Numerous regulatory guides may be required to cover the details on acceptable methodology.
Initial emphasis will deal with the decommissioning of facilities of contemporary design.
However, it is already clear that other designs may significantly facilitate.he decommissioning process.
Early attention will be given to the development of new design criteria for nuclear facil-ities which make the decommissioning process easier, safer and less costly, yet do not adversely impact the operational safety of the plant or its conformance to the concept of maintaining radiation exposures as low as is reasonably achievable.
1.2 Implementation of Plan The plan will be implemented by a combination of efforts utilizing the NRC staff and technical assistance from contractors.
Battelle, Pacific 2198 205 2
Northwest Laboratories were selected to prcside the greatest part of the technical assistance.
Studies were initiated, which are still underway, of the decommissioning safety and costs of nuclear fuel cycle facilities in FY 1975 and of light-water-cooled reactors in FY 1976.
As various parts of these studies are completed the results will be utilized by the NRC staff to upgrade and prepare regulations and guides.
1.3 Current Regulations and Guidance The regulations presently in effect cover the requirements and criteria for decommissioning in only a limited way.
Financial competence for major licensees is treated by 10 CFR Part 50, Section 50.33(f), which requires a determination of the applicant's financial qualifications to operate and to shut down and maintain in a safe condition a production or utilization facility.
The subject section states:
"(f) Information sufficient to demonstrate to the Commission the financial qualifications of the applicant to carry out, in accordance with the regulations in this chapter, the activities for which the permit or license is sought.
If the application is for a construction permit, such information shall show that the applicant possesses the funds necessary to cover estimated construction costs and related fuel cycle costs or that the applicant has reasonable assurance of obtaining the necessary funds, or a combination of the two.
If the application is for an operating license, such information shall show that the applicant possesses the funds necessary to cover estimated operating costs or that the applicant 2198 206 3
has reasonable assurance of obtaining the necessary funds, or a combina-tion of the two.
With respect to any production or utilization facility of a type described in 6 50.21(b) or 6 50.22, or a testing facility, the following specific requirements shall apply:
"If the application is for an operating license, such information shall show that the applicant possesses or has reasonable assurance of obtaining the funds necessary to cover the estimated costs of operation for the period of the license or for 5 years, whichever is greater, plus the estimated costs of permanently shutting the facility down and maintain-ing it in a safe condition. Without limitation on the generality of the foregoing requirerrt 1, each application for a construction permit or an operating lict.se submitted by an entity organized for the primary purpose of constructing or operating a facility shall include information showing the legal and financial relationships it has or proposes to have with its stockholders or owners, and their financial ability to meet any contractual obligation to such entity which they have incurreo or propose to incur, and any other information necessary to enable the Commission to determine the applicant's financial qualifications."
Note that 50.33(f) addresses the financial qualifications of prospec-tive licensees.
It does not speak directly to final disposition of the facility, but only of shutting down and maintaining it in a safe condition.
Also, as it is set in Part 50, it applies only to production and util:zation facilities, and not to the many types of facilities which are operated with Part 30, 40 and 70 material licenses.
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Application for termination of licenses for production and utiliza-tion facilities are covered in 10 CFR Part 50, Secti'on 50.82 which states:
"S 50.82 Applications for termination of licenses.
"(a) Any licensee may apply to the Commission for authority to sur-render a license 'luntarily and to dismantle the facility and dispose of its component parts.
The Commission may require information, including information as to proposed procedures for the disposal of radioactive material, decontamination of the site, and other procedures, to provide reasonable assurance that the dismantling of the facility and disposal of the component parts will be performed in accordance with the regulations in this chapter and will not be inimical to the common defense and secur-ity or to the health and safety of the public.
"(b) If the application demonstrates that the dismantling of the facility and disposal of the component parts will be performed in accord-ance with the regulations in this chapter and will not be inim' cal to the common defense and security or to the health and safety of the public, and after notice to interested persons, the Commission may issue an order authorizing such dismantling and disposal, and providing for the termina-tion of the license upon completion of such procedures in accordance with any conditions specified in the order."
Section 50.82 is notable for its end-of-life phraseology.
The detailed decommissioning plan need not be drawn up and reviewed until the licensee seeks to surrender the license.
Note also that Section 50.82 speaks of dismantling the facility and disposing of its component parts at 2198 208 5
the time of such surrender, a more specific definition of decommissioning than is found in Section 50.33.
Appendix F, paragraphs 4 and 5 of 10 CFR Part 50, deals with the decommissioning of fuel reprocessing plants and speaks still more specif-ically on decommissioning:
"4.
A design objective for fuel reprocessing plants shall be to facilitate decontamination and removal of all significant radioactive wastes at the time the facility is permanently decommissioned.
Criteria for the extent of decontamination to be required upon decomissioning and license termination will be developed in consultation with competent groups.
Opportunity will be afforded for public comment before such criteria are made effective.
"S.
Applicants proposing to operate fuel reprocessing plants, in submitting information concerning financial qualifications as required by 6 50.33(f), shall include information enabling the Commission to determine whether the applicant is financially qualified, among other things, to provide for the removal and disposal of radioactive wastes, during opera-tion and upon decommissioning of the facility, in accordance with the Commission's regulations, including the requirements set out in this appendix."
This part of the regulation makes facilitation of decommissioning a design objective.
It speaks directly to the question of removal and disposal of radioactive wastes.
It calls for the use of competent collec-tive judgement to decide on the extent of decontamination and provides for public comment before acting on such a decision.
Appendix F is perhaps 6
2198 209
the strongest regulation on the subject of decommissioning, but applies only to fuel reprocessing plants.
T'3 regulations for material licenses, Parts 30, 40 and 70, do not deal a decommissioning in any explicit way.
Regulatory guidance on decontamination and decommissioning has long been available to licensees.
Guidelines have been provided by the licens-ing staff since the early 1960's.
The November 1976 version of these guidelines entitled, " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source or Special Nuclear Material," is presented in Attach-ment A.
These guidelines led to the development of Regulatory Guide 1.86, Attachment B, " Termination of Operating Licenses for Nuclear Reactors."
It defines four methods for retirement of a facility which are acceptable to the regulatory staff:
mothballing, in place entombment, removal and dismantling, and conversion to a new [ power] system.
The guide offers detailed advice on how to proceed using either of the first two alterna-tives to obtain a possession-only license.
It also gives advice on decon-tamination for unrestricted release, including a table of acceptable surface contamination levels.
1.3.1 Reactor Review Practice The decommissioning of nuclear reactor facilities has been relatively well developed and is routinely considered in the licensing process.
To a limited extent, the staff presently examines various decommissioning 2198 210
plans, costs and environmental impacts prior to the issuance of an operating license for a reactor facility.
As stated in Regulatory Guide 1.86, decommissioning alternatives presently acceptable to the staff include mothballing, entombment, prompt removal / dismantling, or a combi-nation of any of the three.
Protective storage or mothballing involves removal of all fuel and source material, the disposal of all liquid and solid waste and placing the facility in a state of protective storage.
Entombment requires similar treatment and, additionally, the radioactive materials and components are encased (usually in concrete) and isolated until they decay to unrestricted levels.
Removal and dismantling require that all radioactive structures, components and systems be disposed of such that the site can be released for unrestricted use.
In each licensing case the staff must be satisfied that a feasible decommissioning method exists and that the applicant possesses or has the capability to provide the necessary funds to complete the task.
At termination of nuclear reactor operation it may be advantageous to the licensee to request a possession-only license to allow time for radio-activity remaining in components to decay.
This type of license permits possession of the facility and remaining radioactive materials but continues to impose requirements upon the licensee to ensure that proper surveillance and procedures are followed to maintain the non-operating facility in a safe condition.
The licensee remains responsible for the safe disposition of fuel, radioactive components, and other radioactive source material.
Radiation monitoring, environmental surveillance, and appropriate plant security procedures are required for an indefinite time into the future to ensure the public is not endangered.
8 2198 211
1.3.2 Fuel Cycle Facility Review Practice Nuclear fuel cycle plants that support reactors require some form of decommissioning before the facilities or the sites can be released for alternative uses.
The licensed fuel cycle facilities in question are uranium mills, UF conversion plants, fuel fabrication plants and fuel 6
reprocessing plants.
Because of the low hazards associated with uranium contamination of components and systems of the front end of the fuel cycle, the standard procedure for decommissioning is decontamination of the facility and disposal of equipment in accordance with the NRC staff's guidelines for release for unrestricted use.
(See Attachment A.)
The staff is currently preparing a Generic Environmental Impact Statement (GEIS) on uranium milling.
Management of mill tailings, after milling operations cease, involving about 600,000 tons /yr of low specific activity material, is the major consideration in decommissioning of these facilities.
The GEIS will assess the environmental impact of uranium milling operations, including management of uranium mill tailings, and provide an opportunity for public participation in decisions concerning any proposed changes in NRC regulations or regulatory authority based on this assessment.
The draft GEIS is scheduled to be issued in August 1978.
Until the GEIS is issued and new regulations implemented, the staff is taking a conservative approach with respect to renewing licenses and granting new licenses for uranium mills.
For new applications, the staff is requiring applicants to develop and commit to a tailings management plan as a license condition.
Regulatory Guide 3.5 (Rev. 1), " Standard Format and Content of License Applications for Uranium Mills,"
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describes the information needed and also sets interim criteria for tailings stabilization.
Implementation of the tailings management plan is intended to reduce the impact of the tailings to essentially the same impact as occurs at that site with the material in its natural state.
In addition, the staff is requiring that the applicant provide a financial surety arrangement to assure that the tailings management plan will be carried out.
With regard to existing licenses, the staff is requiring as a license condition that a tailings management plan, a mill decommissioning plan, and a financial surety arrangement be committed to before license renewal.
For fuel cycle facilities other than mills, the staff is requiring as a license condition that new majo,r fuel cycle applicants and applicants for license renewals provide decommissioning plans and financial arrange-ments for defraying these expenses.
Additionally, the staff is exploring what statutory or regulatory changes are needed to formalize these arrangements.
The staff does not plan to recommend the codification of financial arrangements for uranium mills at least until after a study on financial surety arrangements now being carried out as part of the GEIS on uranium milling is completed, since most of the considerations dealt with in that study will also be applicable to fuel cycle licenses.
2.0 Occasion for Reevaluation Interest in the decommiss.oning of nuclear facilities has been growing both within and without government circles.
Part of this interest relates to the history of decommissioning which is reviewed below:
2l90 10
2.1 History of Decommissioning 2.1.1 Reactors Since 1960, 5 licensed nuclear power reactors, 4 demonstration reactors and 6 licensed test reactors have been decommissioned, as shown in Table 1.
Additionally, about 50 research type reactors have been decommissioned mostly by the dismantling alternative.
The alternatives that have been employed for decommissioning are protective storage or mothballing, entombment or dismantling.
Typically, the choice of the alternative was based upon cost and environmental considerations.
Much of the experience generated from these decommissionings is directly applicable to current plant designs.
After termination of the license to operate a reactor, a license may be issued for the possession of any residual radioactive material in the reactor facility.
This type of license is termed a " possession-only" license.
2.1.2 Fuel Cycle Facilities
- 1. Uranium Mills With respect to uranium milling operations, the large volume of mill tailings (approximately 600,000 tons /yr) constitutes the major decom-missioning problem.
The concentration of radioactivity in the tailings is 220 low, about 0.0006 Ci of Ra per ton of ore.
However, quantities of tailings involved are large and the decay of Radium-226 results in the emission of Radon-222.
If tailings piles are not properly stabilized and controlled, small quantities of radioactivity can enter pathways to man.
2198 214 n
TABLE 1 Decommissioned Power, Demonstration, and Test Reactors Decommissioning Present Status Reactor Mode Selected of License Location Saxton Mothballed Pcssession Only Saxton, Pa.
SEFOR Mothballed Byproduct State Strickler, of Arkansas Arkansas Westinghouse Mothballed Possession Only Waltz Mill, Test Reactor Pa.
NASA Mothballed Possession Only Sandus ky, Plumbrook Ohio GE EVESR Mothballed Possession Only Alameda Co.,
Ca.
B&W Dismantled Byproduct NRC Lynchburg, except for Virginia some concrete structures Hallam Entombment Operating
- Hallam, Authorization Ne.
terminated Piqua Entombment Piqua, Ohio Elk River Dismantled Elk River, Mn.
Bonus Entombment Puerto Rico VBWR Mothballed Possession Only Alameda Co.,
Ca.
Fermi 1 Mothballed Possession Only Monroe Co.,
Mi.
CVTR Mothballed Byproduct State Parr, of South Carolina South Carolina Peach Bottom 1 Mothballed Possession Only York Co., Pa.
Pathfinder Conversion and Byproduct NRC Sioux Falls, Mothballing South Dakota 2198 215 12
The management of mill tailings has received increasing atten-tion and interest in recent years from Federal and State agencies and from environmental conservation groups and increased efforts are being made to reduce exposure to radioactivity.
However, the risk involved from uranium mill tailings, particularly with regard to the long-term considerations, has not yet been fully or adequately defined and is still subject to differing opinions among the scientific community and the public.
Stabili-zation and long-term control of these tailings is necessary, particularly with respect to the need for preventing the unauthorized use of tailings and to control the blowing of tailings from the impoundment area.
The need and extent of additional waste management practices other than stabilization and control still remains to be defined.
Current NRC staff requirements for cuntrol of uranium mill tailings and providing financial surety are given in Attachment C.
Decommissioning of a uranium mill itself involves decontaminat-ing the facility and associated systems of relatively low level contamina-tion from natural uranium and its daughters and/or removal and dismantle-ment of the facility as appropriate.
Decontamination of site soil from the results of blowing of ore piles is also involved.
2.
UF Conversion Plants 6
There are two (2) plants licensed by NRC to convert natural uranium oxides to uranium hexafluoride to be used as feed for the enrion-ment plants.
To date, no commercial UF6 ; nversion plants have been decommissioned; however, the NRC staff a. acipates no significant problems 13 2198 216
with decontaminating this type of facility, based upel the relatively low radiological hazard associated with natural uranium.
'he decommissioning task is normally one of removing surface contaminatior from facilities and equipment and disposal of excess components, before release for unrestricted use.
3.
Fuel Fabrication Plants There are currently nine uranium fuel fabrication plants licensed by NRC that have the capability of performing all or part of the fuel fabrication operations for light water reactors (LWR's).
Three of the plants use enriched UF as feed material and produce completed LWR 6
fuel elements.
Two of the facilities use enriched UF as starting mate-6 rial to produce uranium powder and/or pellets which are then shipped to two sister plants where the fuel assemblies are fabricated.
Two other producers of uranium dioxide fuel are currently shut down because of the lack of demand, and one of these is preparing decommissioning plans.
Although only one LWR fuel fabrication plant has been decom-missioned (Gulf United Nuclear's facility at New Haven, Connecticut), a number of other facilities have been decontaminated and released for unrestricted use, e.g., Gulf United Nuclear's mixed-oxide facility at Pawling, N.Y. and Union Carbide's fabrication plant at Lawrenceburg, Tennessee.
Because of the difference in size, type and age of LWR fuel fabrication facilities the cost estimate for decommissioning will vary considerably.
2198 217 y
Because of the low hazards associated with uranium oxide con-tamination of components and systems, the present procedure for decommis-sioning fuel fabrication plants is decontamination of the facility and disposal of unusable equipment in accordance with the staff's guidelines for release r unrestricted use.
(See Attachment A.)
4.
Fuel Reprocessing Plants Fuel reprocessing plants would be used to recover uranium and plutonium from fuel that has been used in the generation of electricity from nuclear power reactors.
Three commercial fuel reprocessing plants have been built
.'a the United States, but none of these plants is cur-rently reprocessing spent fuel.
The technology associated with the decontamination of reproc-essing plants is available today based upon experience obtained from numerous pilot plant programs at Oak Ridge and Hanford where systems involving the reprocessing of irradiated fuel have been decontaminated and equipment disassembled.
A substantial amount of this information is directly relatable to decontamination and dismantling of future fuel reprocessing plants.
The Nuclear Fuel Services (NFS) plant in West Valley, New York, is the only commercial reprocessing plant that has been operated in the United States.
The NFS situation has been cited as an example of the difficulty and high costs of decommissioning nuclear facilities.
The NFS situation is not directly translatable to the present or projected nuclear power industry.
A national policy (10 CFR 50, Appendix F) 15 2198 218
on a long-term management of high-level waste generated from spent fuel reprocessing plants was established in 1971 well after the plant began operation.
As a result, future renrecessing plants, if any are operated, will handle waste so that it is in a readily solidified form.
The task of converting the neutralized high-level liquid wastes in storage at NFS to a solid form suitable for final disposal is much more difficult and expensive than it would be for the acid type wastec of future reprocessing plants.
It would, therefore, be inappropriate to equate the NFS situation with the latest criteria and policies.
5.
Low Level Waste Burial Grounds Five of the six commercial burial grounds are regulated by Agreement States.
The sixth is regulated by NRC.
The operators contribute to the care funds for the sites at varying rates.
The States have commit-ments for the perpetual care of the decommissioned sites except for one (Hanford) located on Federal land.
- 2. 2 Increased Interest The interest in decommissioning of nuclear facilities has been increas-ing rapidly in both public and congressional sectors.
The NFS situation has produced an increased awareness of the problems in this area.
The General Accounting Office recently reported to the Congress on
" Cleaning Up the Remaining of Nuclear Facilities - A Multibillion Dollar Problem," EMD-77-46, June 16, 1977.
2198 219 16
The Environment and the Atmosphere Subcommittee of the House Com-mittee on Science and Technology held hearings in June of 1977, on decommissioning.
This was done in connection with proposed Bill H.R. 6181, April 6, 1977, which was intended to provide for a study of certain conse-quences of the decommissioning, disposal, and decontamination of elements involved in the utilization of nuclear energy.
Also, the Commission has received a petition for rule making from the Public Interest Research Group, et al.
The petitioners requested the Commission to initiate rule making which would require nuclear power plant operators to post bonds, to be held in escrow, prior to each plant's operation, to insure that funds will be available for proper and adequate isolation of radioactive material upon each plant's decommissioning.
3.0 Reevaluation of Policy 3.1 The Need for Foresight The requirements for acceptable decommissioning of a nuclear facility are established by a cost-benefit analysis of the cost of the v eious stages of decontamination, dismantling, or fixing the residual radioactivity and the attendant benefit to society of so reducing the risk from such residual radioactivity.
The most realistic analysis of decommissioning can be made at the time a facility is ready for it, when the final condi-tion of the facility, the current state-of-the-art, and the current 17 2198 220
criteria are most accurately known.
There is merit then in waiting until the end of a facility's useful life to set a specific decommissioning plan for it.
Waiting until that time leaves temporarily unanswered questions that have a significant bearing on decommissioning.
One question is whether responsibic parties will be able to and will pay for the work.
Perhaps the most notable lapse in both,thee.e respects is the case of the NFS-West Valley reprocessing complex wherc the uncertain financial status of the licensees and the uncertain technology of the high level liquid waste disposal stall the ent.fre decommissioning effort.
Foresight is needed also to assure that the final cost-benefit analysis of decommissioning the facility is not skewed by a facility design feature which makes certain aspects of the cleanup unnecessarily difficult or expensive.
Using the NFS example again, the storag. al high-level liquid waste in sludge-forming neutralized form has made removal and disposal of that liquid waste much more difficult and expensive.
Finally, it is necessary that radiological waste disposal technology and facilities be available to accommodate the wastes from the decommission-ing activities.
3.2 Apparent Differences in Current Policy A responsible decommissioning policy requires NRC to look ahead, before facilities are licensed, to see to both the financial and tech-nological assurance.
In the past, the licensing offices at NRC have 18
}l
looked to these assurances with gradually increasing intensity.
The present licensing practices described in Section 1.3 above indicate consideration of both needed assurances.
As time passes, licensing relicy
~
with respect to decommissioning seems to become substantially different between the two licensing offices, Nuclear Reactor Regulation (NRR) and Nuclear Material Safety and Safeguards (NMSS).
NRR, dealing for the most part with very large, publicly-regulated reactor owners, tends to rely on the protected position and relatively assured solvency of such an owner for financial assurance and past experience for technological assurance.
NMSS, on tile other hand, tends to deal more with material licenses for simple business ventures where the licensees' financial strength and commitment are less assured.
Consequently, NMSS is tending to require the selection of tentative detailed decommissioning plans to set a cost basis and to rer,uire a specific financial arrangement to assure t' _ cyallability of funds thus estimated to be needed for decommissionir.l.
This developing difference in policy may be justified, but in a general reevaluation of NRC decommissioning policy the difference should be carefully considered.
3.3 Policy Alternatives There are two basic policy alternatives available to NRC for decom-missioning, treating it on a case-by-case basis with licensing require-ments developed on and applied only to the specific case, or setting generic criteria and requirements for all or certain classes of facili-ties.
The present regulations have the effect of setting a case-by-case 2198 222 1,
policy.
Either policy can be or,J effectively provided that financial and technological judgements are carefully made before licensing and the bases for those judgements are sufficiently developed.
Therefore,tdefirst step in a major decommissioning policy reevaluation is the developnient of a comprehensive information base on the financial and technical alterna-tives.
4.0 The Existing Reevaluation Program A reevaluation program has actually been underway for about two years.
The Office of Standards Development (OSD) has been developing a data base for precaring criteria, standards and guidelines for the decommissioning of reference, current generation LWR's and their associated fuel cycle facilities.
To assist in this effort three contracts with Battelle PNL, one on reactors, one on fuel cycle facilities and one on the design facilitation of decommissioning are being utilized to obtain information on the impact on public and occupational safety, on the costs of decom-missioning, and on methods for improving decommissioning.
In addition, other studies are underway on waste risk criteria, residual radioactivity limits, and on the environmental impact of metal scrap recovery and uranium mills.
The various studies are reviewed below.
4.1 Decommissioning Studies Decommissioning studies are being made of a pressurized water reactor (PWR) and boiling water reactor (BWR).
In the area of fuel cycle facilities, t
2198 223 2
the existing program includes decommissioning studies of a fuel reprocessing plant, small mixed-oxide fuel fabrication plant, uranium mill, uranium fuel fabrication plant, uranium purification and UF c nversion plant, and 6
low level waste burial grounds.
4.1.1 Technical Approach For each reference reactor and facility the following activities are being carried out:
1.
Selection and description of the reference facility and its site, including radionuclide inventories; 2.
Performance of detailed engineering studies on acceptable dec~om-missto.7ing modes to estimate requirements in time, dollars, occupational exposure, and land usage of each mode; 3.
Evaluation of the potential impact of decommissioning work on public safety for each mode; 4.
Evaluation of costs and safety of acceptable combinations of decommissioning mooes and of methods of financing such costs; 5.
Identification of potential facility and equipment design changes which could facilitate decontamination and decommissioning work.
The decommissioning modes being studied for each facility generally parallel those that are outlined in Regulatory Guide 1.86 (Attachment B),
although Battelle has developed different terminology in some cases as follows:
2198 224 n
Relative Degree of Service Facility Relative Relative attelle R.G.
1.86 Remaining Initial Surveillance Mode Mode Operational Cost Required Layaway Mothballing Highest Lowest Highest Protective High Low High Storage Entombment Entombment Low High Low Dismantling Removal and None Highest None Dismantling Some of the modes are not always studied in detail for each facility and for others combined modes appear to offer the most effective solution.
For example:
Entombment of a fuel reprocessing facility is not considered acceptable uecause long lived nuclides would require the surveillance period to be extremely long.
In the case of LWR's, a combination of modes may be most effective, such as temporary protective storage, for about 100 years, followed by dismaritling.
This allows the radioactivity to decrease to the point that the work can be performed with a much lower occupational radiation exposure.
4.1.2 Planned Schedule Studies were initiated in FY 1975 on the fuel cycle tacilities and in FY 1976 on the reactors.
The plans for completion of the various parts of the studies are shown in MBr-i and M80-2.
The final report on the Fuel Reprocessir.g Plant was releued in October,1977.
It utilizes the Barnwell
, \\,
s 2198 225 22
N Nuclear Fuel Plant as the reference and includes the decommissioning of the waste solidificat. ion part of the plant.
The draft of the next report in the series on decommissioning, a reference, large pressurized water reactor, has been received from Battelle and is now under review by the NRC staff.
A final report on this subject is scheduled for May, 1978.
4.1.3 Facilitating Decommissioning An additional study is underway at Battelle PNL, starting in FY 1978.
This program will consist of the evaluation of provisions and design criteria for facilitating the decommissioning of nuclear facilities.
The purpose of this study is to provide information to assist in establishing regulations and guidelines to reduce public and occupational exposures associated with decommissioning activities.
The study will consider changes in design which will ease the dismantle-ment and decontamination procedures and improve the safety and/or reduce the cost.
It will include such things as the incorporation of holes to allow placement of explosives or of systems for heating to spall the concrete in large concrete structures to facilitate dismantling.
It will also provide information on improving the ease of decontamination of structures, storage tanks and equipment.
Electropolishing is an effective method of decontaminating metallic surfaces which receive detailed cleaning.
The schedule of this program is outlined in M80-3.
2198 226 23
4.2 Other Studies In addition to the Battelle contracts, other studies pertinent to decommissioning are underway.
These are summarized in MBO-4.
A waste risk criteria study is being conducted at Lawrence Livermore Laboratory to quantify acceptable risk for accidental releases from nuclear waste manage-ment operations.
The study uses a systems analysis approach which considers the various situations which could lead to potential releases of radioactive materials during the handling, storage, transportation and disposal of high-level solid wastes.
The study requires the use of calculational models to predict potential mechanisms and probabilities, radionuclide transport and dispersive mechanisms, and to evaluate pathways and doses to man.
A waste classification study is also being conducted to develop criteria to classify wastes according to the degree of confinement needed to assure safe decay.
As part of the study radioactive waste threshold levels will be established.
NMSS plans to publish proposed classification criteria and threshold levels for public comment in the spring of 1978.
Also, a Generic Environmental Impact Statement on Uranium Milling is being prepared at the Argonne National Laboratory under contract to NMSS (see Section 1.3.2).
This study will assess the environmental impacts of uranium milling and provide information on which to determine the need for additional regulatory requirements in the licensing of uranium mills with the emphasis on management of mill tailings.
In other programs, the impacts of metal scrap recovery from enrich-ment olants and decommissioned reactors are being studied.
In both cases, 4
2198 227
large quantities of valuable and very slightly contaminated metals, e.g.,
nickle, copper, and stainless steels, will be available for recycle if the impact from their recovery is sufficiently Tow.
The final item relates to the important area of establishment of residual radioactivity l!mits for surface contamination, induced activity and soil contamination.
The Environmental Protection Agency (EPA) has the lead responsibility for the establishment of generally applicable standards for the levels of radioactivity in the environment.
NRC continues to work with EPA in this activity.
5.0 Development of New Decommissioning Policy 5.1 Schedule and Priorities of Existing Work As the current decommissioning studies and related work are completed there will be an excellent opportunity to formulate and implement a new decommissioning ~ policy.
The studies already underway, which were described in Section 4.0, are already being rescheduled as allotted resources permit to make a useful base of information available as soon as possible.
A number of factors were considered in rescheduling the decommissioning studies at PNL as shown in HBO-1, MB0-2 and MB0-3.
The fuel reprocessing plant study, already so far along, because it was the first begun, was completed and serves as a useful first effort to provide insight for redirection of later efforts.
The reactor studies are pressed forward as rapidly as possible, working on the more prevalent PWR first and then the BWR.
The study of small mixed-oxide (M0X) fabrication plants is given 2198 228 25
next priority because a number of older plants of this type stand idle now and are in need of decommissioning.
In addition, some of the work on the small MOX plants, especially regarding cleanup of transuranic contamination, can be derived from the fuel reprocessing plant study.
Also, some of this may be useful for analysis of other small fuel fabrication plants which need decommissioning.
The low-level burial ground study merits prompt attention because of the current difficulties with low level burial grounds in this country.
The study of uranium mill decommissioning is set to coincide with the completion of the GEIS on uranium milling and will build on that base as necessary.
The analyses of decommissioning for large fuel fabrication and UF6 plants are scheduled last because they are expected to be the most straightforward and are the least urgently needed.
5.2 Timing and Mechanism for Developing a New Decommissioning Policy Examination of MBO-1 and MB0-2 shows that by mid-1979 the greatest part of the work on decommissioning studies will be completed.
This will also be the case for the related efforts listed in MB0-4.
At that time the staff will be in a position to use t e information for the whole range of nuclear facilities to consider the alternatives for treating decommis-sioning in licensing cases and to develop an overall general policy for all facilities.
Statement and implementation of this policy would be through change in and addition to the pertinent regulations.
An environ-mentai statement on decommissioning would be needed to state and compare these alternatives and to derive the necessary conclusions.
The draft environmental stateraent should be available in support of any proposed n
2}90 229 26
rule change.
M80-5 shows the earliest schedule for development of an environmental statement and subsequent rulemaking action.
By working closely in parallel with the existing studies, a draft statement and proposed rule change might be ready by December of 1979.
To produce these earlier would require proceeding without substantial portions of the information base (see M80-1 and MB0-2).
As shown, the schedule has policy development and adoption at about the same time as the last of the informa-tion reports are completed, M80-1 and MB0-2.
Such optimism is based on the assumption that the work in the information reports completed by then will have covered all of the fundamental aspects which would affect the choice of policy.
The later information reports would be developing facility specific information which is important to the application of policy.
5.3 Principal Issues in Decommissioning Policy The principal issues to be addressed in developing or reevaluating decommissioning policy are the acceptability of radioactive residues, the financial assurance, and the generic applicability of decommissioning analyses considering the range of facility designs and possible circum-stances.
Much of the information needed for our policy development can come from the work of contractors, but in these principal areas direct and particular attention by the NRC staff is very important.
27 2198 230
5.3.1 Acceptability of Radioactive Residues Residual contamination may be in or on structures, equipment and soils.
It is important to recognize that the acceptable residual level of any form of contamination ic not a simply set, predetermined value similar to the allowable concentration values from the tables in 10 CFR Part 20.
It is a matter of assessing the radiological impact of the residual con-tamination as it lies against the cost and advantages of removing it.
Constructing and using models to determine this radiological impact can be difficult.
Models have been used for some time to simulate the release of radionuclides from operating facilities, the environmental transport of the radionuclides, the exposure or ingestion by man of these radionuclides which leads to an estimate of the radiological impact (presented as a dose) to a hypothetical individual.
This dose assessment methodology has been utilized in making regula-tory decisions for some time in individual reactor I!-rusing actions and was used for the generic analysis for the use of recycle plutonium in mixed oxide fuel (GESM0).
The methodology used by the NRC staff is described in guides developed to implement Appendix I of 10 CFR Part 50.
These are Regulatory Guides 1.109, 1.110, 1.111, 1.112, and 1.113.
Studies conducted at Battelle (PNL) on generic facility decommis-sioning have demonstrated the utility of using the predictive methodolgoy in a partial inverse manner, i.e., back-calculating the concentration and/or areal radionuclide levels equivalent to a unit radiation dose to a hypothetical individual.
The exposure to a mixture of radionuclides with 2198 231 28
the involvement of different critical organs maKes it very difficult to perform a summation of impacts equivalent to a whole body dose limit.
The lack of any authoritative definition of a "de minimis" dose (i.e.,
low dose equivalent in risk to other activities that are generally accepted without special concern) also meant that a proposed acceptable level of residual radioactivity in soil was certain to be in jeopardy.
The recom-mendation of the International Commission on Radiological Protection adopted on January 17, 1977 (ICRP 26), provides the conceptual basis for construct-ing a methodology which can provide practical performance objectives for stipulating acceptable residual radioactivity levels in soil for purposes of regulation.
The conceptual approach in ICRP 26 makes it possible to sum impacts of groups of nuclides in terms of equivalent risk and to delineate soil concentrations which are correlated with a specified acceptable environ-mental risk to an individual.
Several quotes from ICRP 26 are appropriate:
(Sect 60) for uniform whole body irradiation, "...the mortality risk
-4 factor for radiation-induced concern is about 10 man-rem,"
(Sect 104) For stochastic effects the Commission's recommended dose limitation is based on the principle that the risk should be equal whether the whole body is irradiated uniformily or whether there is non-uniform irradiation.
This condition will be met if H
Il "T T $Hwb,L 2198 232 29
l l
where, w is a weighting factor representing the proportion of the T
stochastic risk resulting from tissue (T) to the total risk, when the whole boQy is irradiated uniformly.
H is the annual dose equivalent in T
tissue (T).
H is the recommended annual dose-equivalent limit for wb.L uniform irradiation of the whole body, namely 5 rem.
(Sect 118) " Acceptable level of risk for members of the general public may be inferred from consideration of risks that an individual can modify to only a small degree and which, like radiation safety, may be
-6 regulated by national ordinance."
...a risk in the range of 10 to
-5 10 per year would be likely to be acceptable to any individual member of the public."
The major tissues at risk presented in ICRP 26 are somewhat different than the critical organs published by ICRP 2 in 1959, resulting in a temporary impasse since organ dose factors are not now available for red bone marrow, bone surface and breast.
A research contract for NRC being conducted by ORNL for developing updated physical, metabolic and age specific dose factors will need to develop dose factors for the ICRP 26 tissues.
The Dose Assessment Modeling Symposium held in Gatlinburg, Tennessee, in September 1977,-had a workshop on Terrestrial Trant90rt which concluded that environmental transport para-sters are not well known for naturally occurring radionuclides.
This data base requires improvement for solving the soil concentration problem for the front end of tt.i iuel cycle.
.h 2198 233 30
Setting the acceptable residual levels of contamination will also require decision on what credit can be taken and for how long for isola-tion of the contamination by direct custody (guards, fences, etc.) or by confining media (paint, concrete, soil cover, etc.).
It is an underlying assumption that NRC will actively seek to prevent a proliferation of sites where the remains of nuclear facility operations stand guarded or entombed.
At the same time, the NRC recognizes that some sites, such as major power plant sites, are uniquely suited to that purpose for the foreseeable future, and it may not be reasonable for our society to expend great resources and increased doses to the workers to decommission an old nuclear facility site to a pristine condition if a new nuclear facility is to be built there.
5.3.2 Financial Assurance The cost of decommissioning a nuclear facility at the end of its useful life is obviously the responsibility of.the aners.
The span of the facility's useful life is not exactly known.
It may be shortened or lengthened by changing economic conditions.
It could be shortened by the occurrence of an accident or breakdown which makes repair not economically justified.
The owner's ability to pay for decommissioning is also somewhat uncertain.
Changing economic conditions over the 10- to 40 year life span of a facility can bring great changes in the financial integrity of companies.
Some nuclear facility owners, the regulated public utilities, are in a somewhat sheltered position.
As long as the society served needs electrical 2198 234
power, the utility company or its successor will be there.
It must continue to operate and its costs and obligations are transferred in a regulated way to its customers, the power users.
Other nuclear facility owners, such as mill ownars, fuel fabricators, etc., operate with no such shelter.
They are one of at least several enterprises serving the same need, and economic strength can vanish quickly.
If NRC is to be assured of proper decommissioning at the end of a facility's life, there must be some form of financial assurance at the beginning of that life.
The contractor can supply us with analysis of the relative merits of different financial assurance techniques such as bonding or escrow accounts, but the NRC staff itself must use its own insight to weigh and to judge tne financial assurance needed for the various classes of facilities and owners.
The considerations necessarily include the tentative cost estimated for decommissioning, the expected life of the facility, the impact of the cost or its assurance on the financial structure of the company and its customers, and the degree of financial assurance provided for the public as we act i' their behalf to license this facility.
In weighing the uncertainties in costs ara expected lives of power generating facilities, with respect to decommissioning the NRC staff should consider the wide range of public and private ownership and pro-cedurc, currently used in establishing power rates by States and public agencies.
Since most early reactors are not approaching the end of useful life, retirement schedules remain speculative.
The staff must also consider 32 2198 235
the local conditions and regional arrangements for pooling and pricing in order to reflect unique institutional arrangements and policies.
NRC staff should also consider the implications to the financial market in reaching any policy recommendation.
New Jersey has already acted on its own initiative to require its utilities to plan for creating decommissioning funds or other accumulations over prolonged periods.
This will certainly affect utility financing practices and may lead to subsequent re-examination of the need for pooling of obligations.
All of these issues must be considered by staff in looking for ways that a licensed facility can be decommissioned in a safe and cost effective manner.
5.3.3 Generic Applicability Consideration of nuclear facility decommissioning covers a broad range of facilities and posr'ble circumstances of decommissioning.
There are the different types of facilities:
reactors, fuel fabrication plants, uranium mills, etc. Within a facility type a second level of distinction can be made; pressurized water reactors, boiling water reactors, gas-cooled reactors, etc., based on 3 sign principle.
Alternate bases for distinction are possible; power reactors, research reactors, floating reactor plants, etc.
Even within the second level of distinction further distinction can be made which may be significant to the task of decommissioning.
Pressurized water power reactors include Westinghouse A-loop plants with U-tube steam generators, Babcock & Wilcox 2-loop plants with c:me-through steam generators, plants of greatly different sizes, and plants with many variations in containment design and other features which may affect decommissioning.
33 2198 236
=_
i i
In addition to design differences which can oe significant to decommis-sioning, there are circumstances which may be important to decommissioning.
Accidents, natural phenomena, or man-made events could c.,e damage to the plant to such an extent that the owners might decide to decommission rather than to repair.
Starting the job of decommissioning with a damaged plant may pose unique problems which significantly affect the alternatives available and their costs.
Notable examples which can be postulated include decommissioning after a major loss-of-coolant accident, after the sinking of a floating nuclear plant, or even after a core melt.
It is worth noting that there already is a fair body of experience in post-accident decommissioning; for examples, SL-1 after the excursion, and EBR-1 and Fermi-1 after core melting.
The technical studies by PNL are to be a principal information base for the development of decommissioning policy.
As a practical matter, they are being limited to a selected number of facilities, each to be type representative.
They are:
a large fuel reprocessing plant, a large pressurized water reactor, a large boiling water reactor, a small mixed-oxide fuel fabrication plant, a low-level waste burial ground, a uranium kill, a fuel fabrication plant, anu a UF conversion plant.
The c<m-6 ti une is performing a comprehensive analysis of decommissioning thes' s;N a facilities.
The NRC staff must determine the applicability of the information so generated to specific licensing cases and to decom-missioning policy in general.
The determination of general applicability will consider both design and circumstances being varied.
This determina-tion of applicability is important when drawing any policy conclusions 2198 237 34
=
based on the evaluated alternatives and costs of decommissioning.
This determination will be useful later in specific licensing cases when applicant generated decommissioning pla'ns and costs are being evaluated.
5.4 Publications and Comments This approach to the development of decommissioning policy and initial rule making provides a Draft Environmental Statement (DES) in support of that policy and rule decision, published at the same time the policy statement is made and the initial rule proposed.
Since decommissioning so involves the general public and the State authorities in particular, the program shown here provides for the early publication and discussion of important information and tentative conclusions well before publication of the DES.
The six PNL technical. reports on decommissioning are being published as NUREG reports and are being widely distributed.
The foreword of these reports gives a general description and schedule of the series of reports and solicits comments "for consideratiJn by the Commission in establishing criteria and new standards for decommissioning." The publication of these PNL technical reports started in September of 1977 and is expected to be completed with the sixth one in March of 1980.
A few months in advance of publication, each one is circulated in working draft form within the NRC staff for technical review.
This working draft is not normally distributed to outside reviewers.
2198 238 35
At least three NRC staff reports are also projected for publicar.i- "
as NUREG reports in May of 1979.
These interim reports on the three principal issues discussed in Section 5.3 would present preliminary evalu-ations and tentative conclusions, indicating the trend of staff thinking on these subjects.
These interim reports would, of course, be available for public comment.
The role of the States is so important that a formal dialogue with them is proposed.
The first step is a briefing on the plan at the State Radiation Control Program Directors' meeting in April of 1978.
Subse-quently, regional workshops with State officials are proposed in August or September of 1978, and in July of 1979.
The 1978 workshops will be based on the technical information then available and the approach of the plan itself.
The 1979 workshops will focus on the preliminary evaluations and tentative conclusions in the three NRC " principal issue" interim reports.
The DES and the proposed policy and rule will later undergc regular publi'_acion for comment.
~
2198 239 36 l
MBD-1
. OBJECTIVE: Develop information base and regulatory guide for decommissioning of light water reactors.
FY '78 FY '79 FY '80 I
MILESTONES O N D J F M A M J J A S O N D J F M A M J J A S O N D J F M A M J J AS
- 1. PWR
- a. Draft Report 4
- b. Final Report A
c:
- 2. B W R
- a. Draft Report O
- b. Final Report A
ca
- 3. Develop Guides for Decommissioning LWR's To Be Determined
- a. Draft
- b. Comments
- c. Final N
CD l
N A
A= Scheduled items ir.duded in the above reports:
O A= Complete
- a. Select and describe reference facilities sites, and radionuclide inventories.
- b. Perform detailed engineering studies on acceptable decommissioning modes estimating time requirements dollars, occupational exposure, and land usage.
- c. Determine the potential impact on public safety for each mode.
- d. Determine costs and safety of acceptable combinations of decommissioning modes and methods of financing such costs.
- e. Indentify possible design changes which would !acilitate decontamination.
~
OBJECTIVE: Develop information base on regulatory guides for decommissioning LWR fuel Cycle Facilities FY '78 FY '79 FY '80 f..:LES TONES O N D J F M A M'J J A S O N D J F M A M J J A S O N D J F M A M J J A S 1.' Fuel Reprocessing Plants
- a. Draft Technical Report
- b. Final Technical Report A
- 2. MOX Fabrication Plants
- a. Draft Technical Report 6
- b. Final Technical Report 6
- 3. LLW Burial Ground a
- a. Draft Technical Report
- b. Final Technical Report A
- 4. Uranium Mill
- a. Draft Technical Report 6
- b. Final Technical Report 6
- 5. Fuel Fabrication
- a. Draft Technical Report 6
- b. Final Technical Report A
- 6. UF Plant 6
- a. Draft Technical Report 6
- b. Final Technical Report A
- 7. Develop Regulatory Guides for Decommis-To Be Determined Nsioning LWR Fuel Cycle Facilities ha. Draft CCb. Comments items included in the above reports:
g Final
- a. Select and describe reference facilities sites, and radionuclide inventories.
- b. Perform detailed engineering studies on acceptable decommissioning modes estimating A
A= Scheduled time requirements dollars, occupational exposure, and land usage.
A= Complete
- c. Determine the potential impact on public safety for each mode.
- d. Determir:e costs and safety of acceptable combinations of decommissioning modes and methods of financing such costs.
- e. Identify possible riesign changes which would facilitate decontamination.
MBO-3 OBJECTIVE: Develop information base for facilitating decommissioning.
FY '78 FY '79 FY '80 MILESTONES O N D J F M S M J J A S O N D J F M A M J J A S O N D J F M A M J J A S
- 1. Evaluate Design Alternatives for improve-ment of Safety and Facilitation of Decommissioning of:
- a. Reactors (1) Draft Technical Report 6
(2) Final Technical Report 6
- b. Fuel Cycle Facilities (1) Draft Technical Report A
ae (2) Final Technical Report 6
- 2. Publish Guides for Facilitation of To Be Determined Decommissioning:
- a. Draft
- b. Comments N
- c. Final A= Scheduied A= Complete Nn N
MBO-4 OBJECTIVE: Develop bases for policy and regulations related to decommissioning.
FY '78 FY '79 FY '80 MILESTONES ONDJ F M A M'J J A S O N D J F M A M J J A S O '.' % J F M A M J J A S t
- 1. Waste Risk Criteria Study (NMSS)
Quantify Acceptable Risk for Accidental Releases from Waste Management Operations, (1) Final Report A
Assess Environmental Impacts and Provide Needed Information for Revising / Adding Regulatory Requirements.
(1) Draft Report d
(2) Final Report A
- 3. Metal Scrap Recovery (SD)
Determine Feasibility of Recycle of Metals 3o from Reactors and Enrichment Plants after Decommissioning.
(1) Draft Report A
(2) Final Report A
- 4. Residual Activity Limits (EPA /SD)
Define Acceptable Public Risks from Exposure to Residual Radioactivity.
- 5. Waste Classification Study (NMSS)
Develop Classification and Threshold Level Criteria.
(1) EIS (a) Draft Report A
g A
(b) Final Report (2) Regulation (a) Draft Report A
(b) Final Report d
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J 2198 245 42
ATTACHMENT A GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO RELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, OR SPECIAL NUCLEAR MATERIAL U.S. Nuclear Regulatory Commission Division of Fuel Cycle and Material Safety Washington, D.C.
20555 NOVEMBER 1976 2198 246 A-1 t ;-
- i
The instructions in this guide in conjunction with Table I specify the radioactivity a_nd radiation exposure rate limits which should be used in accomplishing the decontamination and survey of surfaces or premises and equipment prior to abandonment or release for unrestricted use.
The limits in Table I do not apply to premises, equipment, or scrap containing induced radioactivty for which the radiological considerations pertinent to their use may be different.
The release of such facilities or items from regulatory control will be considered on a case-by-case basis.
1.
The licensee shall make a reasonable effort to eliminate residual contaminatinn.
2.
Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other covering material unless contamination levels, as determined by a survey and documented, are below the limits specified i:' Table I prior to applying the covering.
A reasonable effort must be made to minimize the contamination prior to use of any covering.
3.
The radioactivty on the interior surfaces of pipes, drain lines, or ductwork shall be determined by making measurements at all traps, and other appropriate access points, provided that contamination at these locations is likely to be represer.tative of contamination on the interior of the pipes, drain lines, or ductwork.
Surfaces of premises, A-2 2198 247
i equipment, or scrap which are likely to be contaminated but are of l
such size, construction, or location as to make the surface inacces-sible for purposes of measurement shall be presumed to be contaminated in excess of the limits.
4.
Upon request, the Commission may authorize a licensee to relinquish possession or control of' premises, equipment, or scrap having surfaces contaminated with materials in excess of the limits specified.
This may include, but would not be limited to, special circumstances such as razing of buildings, transfer of premises to another organization continuing work with radioactive materials, or conversion of facili-ties to a long-term storage or standby status.
Such requests must:
a.
Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, extent, and degree of residual surface contamination.
b.
Provide a detailed health and safety analysis which reflects that the residual amounts of materials on surface areas, together with other considerations such as prospective use of the premises, equipment or scrap, are unlikely to renilt in an unreasonable risk to the health and safety of the public.
i
^~
2198 248
5.
Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiation survey which establishes that contam-ination is within the limits specified in Table I.
A copy of the survey report shall be filed with the Division of Fuel Cycle and Material Safety, USNRC, Washington, D.C.
20555, and also the Director of the Regional Office of the Office of Inspection and Enforcement, USNRC, having jurisdiction.
The report should be filed at least 30 days prior to the planned date of abandonment.
The survey report shall:
a.
Identify the premises.
b.
Show that reasonable effort has been made to eliminate residual contamination.
c.
Describe the scope of the survey and general procedures followed.
d.
State the findings of the survey in units specified in the instruction.
Following review of the report, the NRC will consider visiting the facili-ties to confirm the survey.
^"
2198 249
TABLE I ACCEPTABLE SURFACE CONTAMINATION LEVELS f
'~
NUCLIDES AVERAGE,c,f MAXIMUM,d,f ftEMOVABLE '**I a
b b
D 2
2 2
U-nat, U-236, U-238, and 5,000 dpm a/100.cm 15,000 dpm a/100 cm 1,000 dpm a/100 cm associated decay products Iransuranics, Ra-226' 2
2 2
Ra-228.
100 dpm/100 cm 300 dpm/100 cm 20 dpm/100 cm Th-E 0, Th-228, Pa-231, Ac-227, I-125, I-129 2
2 2
Th-nat, Th-232, Sr-90, 1,000 dpm/100 cm 3,000 dpm/100 cm 200 dpm/100 cm 2a-223, Ra-224, U-232, I-126,
?
I-131, I-133 m
2 2
2 e
Beta gamma emitters (nu-5,000 dpm py/100 cm 15,000 dpm py/100 cm 1,000 dpm py/100 cm clides with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above.
N aWhere surface contamination by both alpha-and beta gamma-emitting nuclides exists, the limits e
established for alpha-and beta-camma-emitting ntclides should apply independently.
bAs used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive N
material as determined by correcting the counts per minute observed by an appropriate director LD for background, efficienty, and geometric factors associated with the instrumentation.
O CMeasurements of average contaminant should not be averaged over more than 1 square meter.
For objects of less surface area, the average should be derived from each such object.
_=
TABLE I (Cont'd.)
5 2
dThe maximum contamination level applies to an area of not more than 100.cm,
2 "The amount of removable radioactive material per 100 cm of surface area shculd be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate instrument of known efficiency.
When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.
- The average and maximum radiation levels associated with surface contamination resulting from beta gamma emitters should not exceed 0.2 mrad /hr at 1 cm and 1.0 mrad /hr at I cm, respectively, measured through not more than 7 milligrams per square centimeter of
?"
total absorber.
N CD N
trl
[# '%
June 1974 U.S. ATOMIC ENERGY COMMISS3ON i REGULATORY GU;DE i
DIRECTORATE OF REGULATORY STANDARDS f
REGULATORY GUIDE 1.86 TERMINATION OF OPERATING LICENSES FOR NUCLEAR REACTORS A. INTRODUCTION A licensee having a possession-only license must retain, with the Part 50 license, authorization for special Section 50.51, " Duration of license, renewal," of 10 nuclear material (10 CFR Part 70, "Special Nuclear CFR Part 50, " Licensing of Production and Utilization Material"), byproduct material (10 CFR Part 30," Rules Facilities," requires that each license to operate a of General Applicability to Licensing of Byproduct production and utilization facility be issued for a jaterial"), and source material (10 CFR Part 40, specified duration. Upon expiration of the specified
" Licensing of Source Material"), until the fuel, radio-period, the license may be either renewed or terminated active components, and sources are removed from the by the Commission. Section 50.82, " Applications for facility. Appropriate administrative controls and facility termination oflicenses," specifies the requirements that requirements are imposed by the Part 50 license and the must be satisfied to terminate an operating license, technical specifications to assure that proper surveillance including the requirement that the dismantlement of the is performed,and that the reactor facility is maintained facility and disposal of the component parts not be in a safe condition and not operated.
inimical to the common defense and security or to the heahh and safety of the public. This guide describes A possession-only license permits various options and methods and procedures considered acceptable by the procedures for decommissioning, such as mothballing.
Regulatory staff for the termination of operating entombment, or dismantling. The requirements imposed licenses for nuclear reactors. The Advisory Committee depend on the option selected.
on Reactor Safeguards h.as been consulted concerning this guide and has concurred in the regulatory position.
Section 50.82 provides that the licensee may dis-mantle and dispose of the component parts of a nuclear B. DISCUSSION reactor in accordance with existing regulations. For research reactors and critical facilities, this has usually When a licensee decides to terminate his nuclear meant the disassembly of a reactor and its shipment reactor operating license, he may, as a first step in the of fsite, sometimes to another appropriately licensed process, request that his operating license be amended to organization for further use. The site from which a restrict him to possess but not operate the facility. The reactor has been removed must be decontaminated, as advantage to the licensee of converting to such a necessary, and inspected by the Commission to deter-possession-only license is reduced surveillance rquire-mine whether unrestricted access can be approved. In ments in that periodic surveillani., of equipment im-the case of nuclear power reactors, dismantling has portant to the safety of reactor operation is no longer usually been accomplished by shipping fuel offsite, required. Once this possession-only license is issued, making the reactor inoperable, and disposing of some of reactor operation is not permitted. Other activities the radioactive components.
related to sessation of operations such as unloading fuel from the reactor and placing it in storage (either onsite Radioactive components may be either shipped off-of offsite) nuy be continued.
site for burial at an authorized burial ground or secured USAEC RECULATORY GUIDES Cop n of pubhshed ou.dn may be obte.ned by requet.nd. cat.pg the d.v.s.ons des. red to the US. Aton=c E nergy Commineon, Wmhangton. Of. 20545 fisuguietsw y Guertes me suuAf to desrrabe and enehe sweelable to the public A tt ent eon : D rector of Regulatory Standards. Comewnts and suggestions for teethuds as swip***4 to the Af C Regulatory staf f of emplementing specific parts of emprovements in these guides are encouraged and should be sent to the Secretary the Conwneu.on's repletions. so detineate sechniques.neJ by the staf f en of the Commets on. U.S. Atomic Energy Commosson. Wo.hington. Dr. 20545 eveWeeng spectfsc problems or postuleted eccedents, or to provede guidance to Attention CNef.Public Proceeenge Staff.
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commer,ts and to reflect new spfore,tsten or empertence.
- s. Maters 443 end Plant Protecten
- 10. Generes B-1 2198 252
on the site.Those radioactive materials remaining on the fluids and waste should removed from the site.
site must be isolated from the public by physical barners Adequate radiation monitonnx. environmental surveil-or other means to prevent public access to hazardous lance, and appropriate security procedures shot.ld be levels of radiation. Surveillance is necessary to assure the established under a possession-only hcense to ensure that long term integrity of the barriers. The amount of the health and saf ty of the publicis not endangered.
surveillance required depends upon (1) the potential hazard to the health and safety of the public from
- b. In-Place Entombment. In place entombment con-radicactive material remaining on the site and (2) the sists of sealing all the remaining highly radioactive or integnty of the physical barriers. Before areas may be contaminated components (e.g., the pressure vessel and released for unrestricted use, they must have been reactor internals) within a structure integral with the decontaminated or the radioactivity must have decayed biological shield after hasing all fuel assemblies, radio-to less than prescribed limits (Table 1).
active fluids and wastes, and certain selected com-ponents shipped offsite. The structure should provide The hazard associated with the retired facility is integrity over 'he period cf time in which significant evaluated by considering the "nount and type of quantities (greater than Table I levds) of radioactivity remaining contamination, the degree of confmement of remain with the material in the entombment. An the remaining radioactive materials, the physical security appropriate and continuing surveillance program should provided by ihe confimement, the susceptibility to be established under a possession-only license.
release of radiation as a result of natural phenomena, and the duration of required surveillance.
- c. Removal of Radioactive Components and Dis-mantling. All fuel assemblies, radioactive fluids and C. REGULATORY POSITION waste, and other rr.aterials having activities above ao cepted unrestricted activity levels (Table 1) sh)uld be
- 1. APPLICATION FOR A LICENSE TO POSSESS BUT removed from the site. The facility owner may then have NOT OPERATE (POSSESSION.ONLY LICENSE) unrestricted use of the site with no requircment for a liceme. if the facility owner so desires, the remainder of A request to amend an operating license to a the reactor facility may be dismantled and all vestiges possefon<mly license :hould be made to the Director removed and disposed of.
of Licensmg, U.S. Atomic Energy Commission, Washing-ton, D.C. 20545. The request should ind:le the
- d. Conversion to a New Nuclear System or a Fossil following information:
Fuel System. This alternative, which applies only to nuclear power plants, utilizes the existing turbine system
- a. A description of the current status of the facility.
with a new steam supply system. The original nuclear steam supply system should be separated from the
- b. A desenption of measures that will be taken to electric generating system and disposed ofin accordance prevent criticality or reactivity changes and to minimize with one of the previous three retirement alternatives.
releases of radioactivity from the facil.t,.
- 3. SURVEILLANCE AND SECURITY FOR THE RE-
- c. Any proposed changes to the technical specifica-TIREMENT ALTERNATIVES WHOSE FINAL tions that reflect the possession only facihty status and STATUS R EQUIRES A POSSESSION.ONLY the necessary disassembly / retirement activities to be LICENSE performed.
A facility which has been licensed under a posses-
- d. A safety analysis of both the activities to be sion-only license may contain a significant amount of accomplished and the proposed changes to the technical radioactivity in the form of activated and contaminated specifications.
hardware and structural materials. Surveillance and commensurate security should be provided to assure that
- e. An inventory of activated materials and their the public health and safcty are not endangered.
location in the facihty.
- a. Physical security to prevent inadvertent exposure
- 2. ALTERNATIVES FOR REACTOR RETIREMENT of personnel should be provided by multiple locked barriers. The presence of these barriers should make h Four attematives for retirement of nuclear reactor extremely difficult for an unauthorized person to gain facilities are considered 3cceptable by the Regulatory access to areas where radiation or contamination levels staff. These are:
exceed those specified in Regulatory Position C.4. To prevent inadvertent exposure, radiation areas above 5
- a. Mothballing. Mothballing of a nuclear reactor mR/hr, such as near the activated primary system of a facility censists of putting the facility in a state of power plant, should be appropriately marked and should protective storage. In general, the facility may be left not be accessible except by cutting of welded c!csures or intact except that all fuel assemblies and the radioactive the disassembly and removal of substantial structures 2198 253 B-2
and/or shielding matertal. Means such as a remote-(1) Environmentalsurveys, readout intrusion alarm system should be provided to indicate to des! rated personnel when a physicalbarrier (2) FacDity radiation surveys.
is penetrated. Security personnel that provide access control to the facility may be used instead of the (3) Inspec@ns of the physica? barriers, and physical bamers and the intrusion alarm systems.
(4) Abnormaloccurrences.
- b. The physical barriers to unauthorized entrance into the faculty, e.g., fences, buildings, welded doors, and access openings, should be inspected.at least
- 4. DECONTAMINATION FOR RELEASE FOR UN-quarterly to assure that these barriers have not deterior.
RESTRICTED USE ated and that locks and locking apparatus are intact.
If it is desired to terminate a license and to eliminate
- c. A facility radiation survey should be performed at any further surveillance requirements, the facility should least quarterly to verify that no radioactive material is be sufficiently decontaminated to prevent risk to the esesping or being tramported through the containment public health and safety. After the decontamination is barriers in the facility. Sampling should be done along satisfactorily accomplished and the site inspected by the most probable path by which radioactive material the' Commission, the Commission may authorize the such as that stored in the inner containment regions license to be terminated and the facility abandoned or could be transported to the outer regions of the facility released for unrestricted use. The licensu should per-and ultimately to the environs.
form the decontamination using the following guide-lines:
d.An environmental rad:ation survey should be performed at least semiannually to verify that no
- a. The hcensee should make a reasonable effort to s:gnficant amounts of radiation have been released to the eliminate residual contamination.
environment from the facility. Samples such as soil, vegetation, and water should be taken at locations for
- b. No covering should be applied to radioactive which statistical data has been established during reactor surfaces of equipment or structures by paint, plating, or operations.
other covering material untilit is known that contamina-tion levels (determined by a survey and documented) are
- e. A site representative should be designated to be below the limits specified in Table I. In addition, a responsible for controlling authorized access into and reasonable effort should be made (and documented) to movement within the facility.
further minimize contamination prior to any such covering.
- f. Administrative procedures should be established for the notification and reporting of abnormal occur.
- c. The radioactivity of the interior surfaces of pipes, rences such as (1) the entrance of an unauthorized drain lines, or ductwork should be determined by person or persons into the facility and (2) a significant making measurements at all traps and other appropriate change in the radiation or contamination levels in the access points, provided contamination at these locations frdlity or the offsite environment, is likely to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces
- g. The following reports should be made:
of premises, equipment, or scrap which are likely to be contaminated but are of such sire, construction, or (1) An annual report to the Director of Licensing, location as to make the surface inaccessible for purposes U.S. Atomic Energy Commission, Washington, D.C.
of measurement should be assumed to be contaminated 20545, describing the results of the environmental and in excess of the permissable radiation limits.
facility radiation surveys, the status of the facility, and an evaluation of 113 performance of security and
- d. Upon request, the Commission may authorize a surveillance measures.
licensee to relinquish possessioa or control of premises, equipment, or scrap having surfaces contaminated in (2) An abnormal occurrence report to the Regula-excess of the limits specified. This may include, but is tory Operations Regional Office by telephone within 24 not limited to, special circumstances such as the transfer hours of discovery of an abnormal occurrence. The of premises to another licensed organization that will abr ormal occurrence will also be reported in the annual continue to work with radioactive materials. Requests report described in the preceding item.
for such authorization should provide:
- h. Records or logs relative to the following items (1) Detailed, specific information describing the should be kept and retained untd the license is termi.
premises, equipment, scrap, and radioactive contami-nated, after which they may be stored with other plant nants and the nature, extent, and degree of residual records: 3 surface contamination.
2198 254
i (2) A detailed health and safety analysis indi-or a change in the technical specifications should be I
cating that the residual amounts of materials on surface reviewed and approved in accordance with the ~ require-l areas, together with other considerations such as the ments of 10 CFR $50.59.
prospective use of tl s premises, equipment,or scrap,are unhkely to result in an unreasonable risk to the health if major structural changes to radioactive components and safe:y of the public.
of the facility are planned, such as removal of the pressure vessel or major components of the primary
- e. Prior to release of the premises for unrestricted system, a dismantlement plan incir2ing the information use, the licensee should make a comprehensive radiation required by g50.82 should be submitted to the Commi:-
survey establishing that contamination is within the sion. A dismantlement plan should be submitted far all limits specified in Table 1. A survey report should be the alternatives of Regulatory Position C.2 except filed with the Director of Licensing, U.S. Atomic Energy mothballing. However, minor diassembly tetivities may Commission, Washington, D.C. 20545, with a copy to still be performed in the absence of such a plan, the Director of the Regulatory Operations Regional provided they are permitted by existing operating and Office having jurisdiction. The report should be filed at maintenance procedures. A dirmantlement plan should least 30 days prior to the planned date of abandonment.
include the following:
The survey report should:
- a. A desc';juon of the ultimate status of the facility (1) Identify the premhes;
- b. A description of the dismantling activities and the (2) Show that reasonable effort has been made to precautions to be taken.
reduce residual contamination to as low as practicable levels;
- c. A safety analysis of the dismantling activities including any effluents which may be released.
(3) Describe the scope of the survey and the general procedures followed; and
- d. A safety analysis of the facility in its ultimate status.
(4) State the finding of the survey in units specified in Table 1.
Upon satisfactory review and approval of the dis.
mantling plan, a dismantling order is issued by the After review of the report, the Commission may Commission in accordance with Q50.82. When dis.
inspect the facilities to confirm the survey prior to mantling is completed and the Commission has been granting approval for abandonment.
notified by letter, the appropriate Regulatory Opera.
tions Regional Office inspects the facility and verifies
- 5. REACTOR RETIREMENT PROCEDURES completion in accordance with the dismantlement plar If residual radiation levels do not exceed the values in As indicated in Regulatory Position C.2, several Table I, the Commission may terminate the license. If alternatives are acceptable for reactor facility retirement.
these levels are exceeded, the licensee retains the if minor disassembly or "mothballing" is planned, this possession.only license under which the dismantling could be done by the existing operating and mainte.
activities have been conducted or, as an alternative, may nance procedures under the license in effect. Any make application to the State (if an A;;reement State) planned actions involving an unreviewed safety question for a byproduct materialslicense.
i 2198 255 B.4 e
- = =.
TABLE I 1
ACCEITABLE SURFACE CONTAMINATION LEVELS b
b NUCLIDEa AVERAGE c MAXIMUMbd REMOVABLE e U-nat, U-235, U-238, and 5,000 dpm al100 cm2 15,000 dpm a/100 cm2 1,000 dpm a/100 cm2 associated decay products Transuranics, Ra 226, Ra 228, 100 dpm/100 cm2 300 dpm/100 cm2 2
20 dpm/100 cm Th-230, Th 228, Pa-231, Ac-227,I 125,1 129 Th-nat, Th-232, Sr-90, 1000 dpm/100 cm2 2
3000 dpm/100 cm 200 dpm/100 cm2 Ra 223 Ra-224, U 232, I126,1131,1133 Beta-gamma emitters (nuclides 5000 dpm $9/100 cm2 15.000 dpm #9/100 cm2 2
1000 dpm Sq/100 cm with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above.
8%here surface contamination by both alpha-and beta-gamma-emitting nuclides exists, the limits established for alpha-and beta-gamma-emitting nuclides should apply independently, bAs used in this table, dpm (disintegrations per minute) means the rate of emission by radioactive material as determined by conecting the counts per minute observed by an appropriate detector for background, emciency, and geometric factors associated with the instrumentation.
CMeasurements of average contaminant should not be averaged over more than I square meter. For objects of less surface area, the average could be derived for each such object.
d 2
The maximum contamination level applies to an area of not more than 100 cm,
2
'TM amount of removable radioactive material per 100 cm of surface area should be determined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radioactive material on the wipe with an appropriate inst:1 ment of known emciency. When removable contamination on objects of less surface area is determined, the pertinent levels should be reduced proportionally and the entire surface should be wiped.
B-5
ATTACHMENT C NRC STAFF URANIUM MILL TAILINGS MANAGEMENT
Background
A major expansion in the uranium industry is taking place.
Many times more uranium will be extracted in the upcoming decades than has been extracted so far.
This requires that the NRC examine very closely the past problem c.reas encountered in the uranium industry and take action to assure that they are not repeated.
The first major portion of the industry within the licensing jurisdiction of the NRC is uranium milling.
The major problem encountered in past milling operations is the management of tailings generated by the milling process.
Although the concentration of radioactivity in the tailings is relatively low, control measures are necessary because of the large quantities involved and because of the long half-life of the parent radionuclides that are present.
The management of mill tailings has received increasing attation and interest in recent years from involved Federal and State agencies and from environmental conservation groups.
This interest has resulted from studies carried out during the last decade which have indicated that uranium miil 2198.257 C-1
tailings, if not properly managed and controlled, could present a potential public health hazard.
The most vivid example, of course, is the situation that occurred in Grand Junction.
The remedial actions determined neces-sary to correct the misuse of tailings in the construction of homes, schools, and other public structures are continuing at substantial cost to the Federal Government and the State of Colorado.
In addition, final technical resolution and financial responsibility for the disposition of tailings at the 22 " inactive" sites being evaluated by ERDA will further increase public, state, and local as well as congres-sional concern with prevention of similar problems in the future.
It is' incumbent on NRC and the uranium industry to assure that current and future licensed milling operations do not result in similar situations.
Towards this end, the NRC staff has developed performance objectives for an acceptable tailings management program based on the latest technology available.
\\
Position The staff is of the opinion that an acceptable tailings management program will vary depending on site or region specific parameters, such as geology, hydrology, and meteorology.
Viable methods of tailings management for a specific mill location may include classic impoundment behind a dam, deep c-2 2198 258
mine burial, open pit mine burial, specially excavated pit burial, or even elimination of radioactive waste by process variations.
Considering the many variables involved, the staff will use the following performance objectives to determine the adequacy of proposed site specific tailings management programs.
Siting and Design 1.
Locate the tailings isolation area remote from people such r. hat population exposures would be reduced to the maximum extent reason-ably achievable.
2.
Locate the tailings isolation area such that disruption and dispersion by natural forces is eliminated or reduced to the maximum extent reasonably achievable.
3.
Design the isolation area such that seepage of toxic materials into the groundwater system would be eliminated or reduced to the maximum extent reasrnably achievable.
During Operations 4.
Eliminate the blowing of tailings t; unrestricted areas during normal operating conditions.
2198 259 C-3
Post Reclamation 5.
Reduce direct gamma radiation from the impoundment area to essentially background.
6.
Reduce the radon emanation rate from the impoundment area to about twice the emanation rate in the surrounding environs.
7.
Eliminate the need for an ongoing monitoring and maintenance program following successful reclamation.
8.
Provide surety arrangements to assure tcat sufficient funds are available to complete the full reclamation plan.
Implementation All objectives will be considered and sat,sfied during the review of proposed tailings management programs for new milling operations.
Current licensee's tailings management programs will be reviewed to determine the best way to apply objectives 4 through 8 to the extent practicable.
During the course of license. renewal reviews, the locations of existing tailings areas will be reviewed considering objectives 1 through 3 to l
I determine if sufficient cause exists to require an alternate disposal i
(
C-4 2196 260
-m-
location for tailings gem rated by future milling operations and the relocation of existing tailings at the time of mill decommissioning.
2198 261 C-5
i i
ATTACHMENT D
[7590-01]
NUCLEAR REGULATORY maintain it in a safe condition. Sec tion. costa, and the environntental impact COMMI5510N 50.82 of Part 50 specifies requirert mts tboth occupational and public) related concerning termination of facilltf 11 to decommissioning. These studies
[10 CFR Ports 30,40,50, and 70]
censes. NRC Regulatory Guide 1.86 have led to a final report on decom-describes methods and procedures ac. missioning a fuel reprocessing plant in DECOMMI5510NING CRITERIA FOR ceptable to the NRC staff for the ter-October 1977. A final report on decom.
NUCLEAR FACILITIES mination of operating Ucenses for re-missioning a pressurized water reactor actors. The guide specifies limits is scheduled for May 1978. Other re-Advance Notice of Proposed which must be met before buildings, ports are scheduled over the next two Rulemaking structures, and equipment, etc., can be years to complete these studies.
AGENCY: U.S. Nuclear Regulato released on an unrestricted basis. The In a petition dated July 5,1977, as Commission.
guide also discusses alternatives for re-supplemented October 7,1977, the ON: Advance Notice of Proposed actor retirement,14., (1) mothballing, Public Interest Research Group, and emaking*
(2) in-place entombment (3) removal others, requested the Commission to of radioactive componenta and dis-initiate rulemaking to promulgate reg.
SUMMARY
- The U.S. Nuclear Regula. mantling, and (4) conversion to a new ulations for nuclear power plant de-tory Commission has underway exten. nuclear system or a fossil fuel system. commissioning. The regulations re-sive studies intended to provide a data Appendix F of Part 50 was amended quested by the petitioners would re-base for developing decommissioning in 1971 to require an applicant for cer. quire plant operators to post bonds to criteria for nuclear facilities. The tain licenses to provide information to be held in escrow, prior to each plant's Commission is considering amending enable the Commission to determine operations, to ensure that fundJ will its regulations to provide more specific whether the applicant is financially be available for proper and adequate guidance on decommisslaning criteria quallfled to provide for the removal isolation of radloactive material upon for production and utilisstion facility licensees and byproduct-source, and and disposal of radioactive waste. Ap.
each plant's decommissioning. The pe-special nuclear ma*erial 11'ensees. This pendix F also states that a design ob-titioners state that the regulatim.
notice is to invite advice and recom-jective of a fuel reprocessing plant should also require thst nuclear power mendations on several questions con-shall be to facilitate decontamination plants already in operation establish ing decommissioning nuclear fa.
and that the Commission will develop plans and immediately post bonds, to es.
criteria for the extent of decontamina-be held in escrow, to ensure proper de-tion to be required upon decommis-commissioning. The petitioners argue DATES: Comment period expires May sioning in consultation with compe, that this arrangement will ensure that 15,1978.
tent groups.
the cost of decommissioning is paid for ADDRESSES: Interested persons are Regulatory Guides dealing with the by current beneficiaries and not by invited to submit written conunents content and format of applications future generations.
and suggestions to the Secretary of and em'ironmental reports for urani.
Pte Commission is considering de-the Commission, U.S Nuclear Regula. um mill licenses presently request in.
Ve*
ment of a more explicit overall tory Commission. Washington, D.C.
formation on tallings stabilization and policy for deccmmissioning nuclear fa-20555. Attention: Docketing and Ser.
associated financial arrangements for cilities and amendir g its regulations in vice Branch. Copies of commenta re.
assuring that tallings are stabilized. 10 CFR Parta 30, 40, 50 and 70 to in-ceived by the Commission may be ex.
Also, a generic environmental impact clude more spet'fic guidance on de-amined in the Comt.!ssion's Public statement (EIS) on uranium milling is commlulor%g criteria for production Document Room at 1717 H Street, under preparation. One primary objec-and utill:
n facility licensees and 3
NW., Washington, D.C.
tive of the EIS is to provide an infor-byproduct, source, and special nuclear FOR FURTHER INFORMATION mation base for a rulemaking action material licensees. It is anticipated CONTACI' covering the decommissioning and that the issue raised in the PIRO pett-Mr. Robert M. Bernero, Office of long term disposition of mill tailings.
tion discussed above will be processed Standards Development. U.S. Nucle-Several enriched uranium fuel fabri-separately from the overall policy de-cation facilities have in the past velopment. Advice and recommenda-ar Regulatory Commission. Wash-ceased operations. The'se plants gener' tions on the matter of overall policy ington, D.C. 20555 (phone 301-443-3573).
ally have been decontaminated to cevelopment are invited from allinter.
besow limits essentially the same af ested persons. Specifically, comments SUPPLEMENTAFV INFORMATION: those specified in Regulatory Guide are requested on the following ques-Present requiremekJ and practices re-1.86. The same holds true for other lo.
tions.
lating to the decommissioning of nu-cations where byproduct, source, and
- 1. Is it desirable to develop more de-clear facilities are addressed in guides special nuclear material have been finitive decommissioning criteria for and regulations of the U.S. Nuclear used.
production and ytilization facility 11 Regulatory Commission.
Section In 1975, the NRC initiated studies at censees and byproduct, source, and 30.33(f) of Title 10. Code of Federal Battelle.PNL to provide an informa-special nuclear material licensees? If Regulations requires the Nuclear Reg.
tion base for developing decommis-so, sho' tid the criteria be in the form ufatory Commission (NRC) to deter-sioning criteria and guidelines for Of mine, prior to the issuance of a license, light water reactors and their fizel l that an applicant for an operating 11-cycle facilities. These studies will also cense is financially quallfled to perma. Include waste burial grounds. The nently shot down his facility and studies will evaluate the technology.
FEDERAL REGISTER, VOL 43, No. 49 -MONDAY, MARDI 13, Ifr8 D-1 4
A. Potential exposures to individ-uals; B. Numerical contamination limits; C. Other? (Specify)
- 2. Should detailed decommissioning plans be required prior to the lasuance of licenses?
- 3. Should funding or of her surety ar-rangements be required before the is-suance of licenses for all cases? If not, which cases?
- 4. What sre acceptable criteria for residual levels of radioactivity on ma-terials which can be released for un-restricted use?
- 5. Proposals have been made to maintain reactors, which have been closed, in protective storage for lengthy periods of time to allow for ra-dioactive decay prior to dismantle-ment. From the standpoint of deter-mining the impact to future genera-tions what is an acceptable length of time, if any, after a facility operation ceases before the facility should be de-commissioned?
- 6. Should decommissioning criteria extend to buildings, structures, and components which have not been con-taminated with radioactive matet!als?
The Commission has concluded that action to include specific decommis-sioning criteria and guidelines in its regulations for production and utiliza-tion f acility licensees and byproduct, source, and special nuclear material 11-censees would constitute a major Fed-eral action significantly affecting the quality of the human environment and as such will require the prepara-tion of an environmental impact state-ment pursuant to Section 102(2)(C) of the National Environmental Policy Act (NEPA). Accordingly, an impact statement (s) will be prepared should the Commission determine it is in the public interest to proceed to amend its regulations as described above.
Dated at W.shington, D.C., this 8th day of March,1978.
For the Nuclear Resu.atory Com-mission.
SAuurtJ.CurLx, Secretary of the Commission.
[FR Doc. 'l8-6461 Filed 3-10 '18; 8:45 aml e (f. S. GOVERNMENT FHINTING OFFICE : 8 76 - 120-387/66 D-2 2198 263
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