ML19311C729
| ML19311C729 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/23/2014 |
| From: | Public Watchdogs |
| To: | Division of Decommissioning, Uranium Recovery and Waste Programs |
| Cruz Z | |
| Shared Package | |
| ML19311C699 | List:
|
| References | |
| Download: ML19311C729 (46) | |
Text
Appendix 0 0.1 Impacts 0.1.1 Onsite/Offsite Land Use Comment: Page 4-6, Section 4.3.1.2, Lines 15-16. This section defines a previously disturbed area as an area where land disturbance occurred "during construction or operation of the site.",
This definition may allow licensees to undertake decommissioning activities resulting in adverse environmental impacts without first performing a site-specific analysis of those impacts. For example, it might allow a licensee to disturb an area that was disturbed several decades ago during plant construction even if that area was not used during plant operation and has essentially returned to its original condition, i.e. native species have fully returned. The Supplement should define what constitutes a "previous" disturbance, e.g., by specifying a time frame, so such adverse impacts are not permitted to occur. (CL-16/23)
Comment: Page 4-6, Section 4.3.1.2, Lines 25-29. The following terms are too broad or too vague to provide licensees sufficient guidance about when a site-specific analysis is necessary with regard to SMALL impacts, "very little new development" and "minimal changes;" with regard to MODERATE impacts, "considerable new development" and "some changes;" and with regard to LARGE impacts, "large-scale new development" and "major change." Providing specific examples from decommissioning or decommissioned facilities would be very useful.
(CL-16/24)
Response: Section 4.3.1 was revised to clarify that offsite changes to land use can not be evaluated genericallyand would require a site-specific analysis. The concept of "previously disturbedland"' "very little new development," "minimalchanges," etc. no longer is the criteria for initiatinga site-specificanalysis.
Comment: Page 4-6, Section 4.3.1.3, Lines 33-41. Using NUREG-1437's estimate that -1 to
-4 ha (-2.5 to 10 ac) of land is needed for steam generator replacement activities, the document assumes that the land use impacts of major component removal during decommissioning "should be similar or less', and that the land used during major component removal "[g]enerally ... has been previously disturbed during construction of the facility." Does this mean that a licensee must perform a site-specific analysis of impacts if the land use' impacts of major component removal may or will be greater than the estimated impacts of steam generator replacement, or if the land used during major component removal has not been previously disturbed during construction of the facility? (CL-16/25)
November 2002 0-29 NUREG-0586 Supplement 1
Appendix 0 I Response: Section 4.1.3 was revised. A site-specific analysis of onsite land use is not I requiredbecause this level of impact has alreadybeen examined within the context of the I operatinglicense and is within the land use allowed by existing zoning. The estimate of land I needed for major component removal is for illustrationonly and does not constitute a limit.
I Comment: Page 4-7, Section 4.3.1.3, Lines 1-2. The Supplement notes that "almost all of the I sites" will use land previously disturbed during construction; should one assume that a facility I using land not previously disturbed will need to conduct a site-specific analysis? Similarly, I under "Conclusions" on that page, it states that impacts for "offsite land use" are considered I small unless "major transportation upgrades are necessary." The examples given are I establishing water, rail or road transportation links. Is one to assume that any establishment of I offsite transportation would require a site-specific analysis? Would impacts only be to off-site I land uses or to on-site as well? Specific examples would help here. (CL-16/26)
I Response: Section 4.3.1 was revised. The staff has revised Section 4.3.1 to state that offsite I changes in land use cannot be evaluatedgenerically. Onsite, no additionalanalysis is required I because no change in land use is required. A licensee should perform a site-specific analysis I for all new offsite land use including major transportationupgradesbecause of the potential for I MODERATE or LARGE impacts.
I Comment: Page 4-7, Section 4.3.1.3, Lines 10-12. Please explain the basis for the I assumption that where previously disturbed areas are not large enough to support I decommissioning activities, "it is likely" that the impact of disturbing previously undisturbed I areas would be "temporary and SMALL." (CL-1 6/27) 1 Response: Section 4.3.1 was revised. The largestland disturbancesassociatedwith I decommissioning appearto be about the same size or smallerthan those needed for steam I generatorreplacement, 1 to 4 ha (2.5 to 10 acres). This amount of land, even if previously I undisturbed,could be returned to a near-naturalstate in 1 to 5 years and represents only about 1 2.5% of even relativelysmall (400 ha) sites. While it is possible for disturbanceseven this I minor to cause adverse ecological consequences (disturbanceof a wetland, for example), it is I unlikely thatsuch ecologically valuable land would be disturbed. In addition, this amount of I land does not representan impact on overall land use.
I Comment: The Staff should visit TMI and then travel to Clinton Lake to examine how I perceptions and reality affect "off site land use." The GElS must acknowledge the potential for I adverse economic impacts on a community during decommissioning. (CL-02/47)
NUREG-0586 Supplement 1 0-30 November 2002
Appendix 0 Response: Land use and socioeconomics are addressedin Section 4.3.1 of this Supplement.
The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
0.1.2, Surface and Groundwater Quality and Use Comment: Page 3-11, Section 3.1.3, Lines 17-18. Please revise the document to clarify that Resource Conservation and Recovery Act hazardous waste disposal permits and Clean Water Act NPDES permits are administered either by EPA or, where EPA has authorized the state RCRA program or the state has assumed the NPDES program, by the state. (See NUREG 1628, Question 4.2.2) Also, the text should briefly discuss the management of PCBs and PCB-containing materials under the Toxic Substances Control Act. (CL-1 6/19)
Response: Section 3.1.3 was revised to clarify the regulationand administrationof the Resource Conservation and Recovery Act (RCRA) and NPDES permits.
Comment: Page 4-9, Section 4.3.2.2, Lines 12-14. The Supplement should briefly describe the "common engineering practices to limit water use impacts." When describing how water impacts were evaluated (Section 4.3.2.3.), it would be helpful to include the average and maximum water usage pre- and post-operation of those plants that have ceased operation.
(CL- 6/28)
Response: Section 4.3.2.2 was revised. The phrase "common engineeringpractice to limit water use impacts"was removed and estimates of the average andmaximum water usage were provided.
Comment: 'Section 4.3.3.3, p 4-12, line 23 - pH would not necessarily (normally) be measured per the LTP. Also, while considerable attention is placed on minimizing spills during decommissioning, hazardous spills have occurred at decommissioning sites. The same types I of activities as performed at operating units, which have resulted in spills at operating units, can lead to spills at decommissioning units. The likelihood is less since less water treatment and so I less bulk chemical handling is typically performed at decommissioning sites. (CL-09/17) I Response: Section 4.3.3.3 was revised eliminating the implication that non-radiological groundwaterparameters(such as pH) would be measured during LTP groundwatermonitoring. I Comment: Pages 4-10 through 4-12, Section 4.3.3. This section focuses primarily on the I water quality impacts of nonradiological discharges from point sources to surface water (and the regulation of such discharges under the NPDES program). It should more fully discuss the I water quality impacts of both nonradiological discharges to groundwater (and their possible I November 2002 0-31 NUREG-0586 Supplement 1
Appendix 0 I regulation under state programs) and non-point source pollution, and if necessary should I indicate that one or both of these types of impacts require site-specific analysis. All of these I types of discharges have potential water quality impacts that need to be evaluated. (CL-16/29)
I Comment: Pages 4-10 to 4-11, Section 4.3.3.1. This subsection on water quality regulations I should distinguish between "intentional" and "unintentional" nonradiological discharges to both I surface water and groundwater. As currently drafted, the section blurs these distinct types of I discharges and the regulatory schemes relevant to each. (CL-1 6/30)
I Comment: Page 4-10, Section 4.3.3.1, Line 42. The Supplement refers to a "permitting I authority" before it identifies what type of permit is at issue. As a result, the reader does not I know who the permitting authority is: It would be helpful to note that "intentional releases of I non-radiological discharges" to surface waters are regulated under EPA or state wastewater I discharge permitting programs, and such discharges to groundwater may be regulated under I state programs. (CL-16/31)
I Comment: Page 4-10, Section 4.3.3.1, Lines 41-44 and Page 4-11, Lines 1-2. This paragraph I is confusing in light of the statement on Page 4-12 "that the issue of surface or groundwater I quality for all decommissioning activities is generic and that the environmental impacts for these I activities will be SMALL." As currently written, it suggests that NRC will obtain a permitting I authority's "environmental assessment of aquatic impacts" and "consider the assessment in its I determination of the magnitude of the environmental impacts" of decommissioning activities at I individual sites. It also suggests that NRC will "establish its own impact determination[s]" on a I site-specific basis in the absence of such environmental assessments. Please clarify.
I (CL-1 6/32)
I Comment: Page 4-11, Section 4.3.3.1, Lines 4-5. Please revise the Supplement to indicate I that the NPDES program only regulates point source discharges to surface waters, not I discharges to groundwater or non-point source pollution. (See also Section 4.3.3.4.) As noted I above, the document should note that point source discharges to surface waters also may be I regulated under state wastewater discharge permitting programs, and discharges to I groundwater may be regulated under state programs. (CL-16/33)
I Comment: Page 4-11, Section 4.3.3.1, Lines 7-9 and Section 4.3.3.2, Line 16. The document I assumes that facilities' NPDES permit limits during decommissioning "are generally the same I limits that are enforced for an operating plant," that facilities' permits "may require a monitoring I program," and that "these monitoring programs are usually continued through the decom I missioning period." Should the reader assume that a licensee must perform a site-specific NUREG-0586 Supplement 1 0-32 November 2002
Appendix 0 analysis of water quality impacts if any one of these conditions is not met? If not, why not?
(See also Section 4.3.3.4: -is a site-specific analysis required where discharges to surface water may or will exceed the NPDES-permitted levels? Again, if not, why not?) (CL-16/34)
Comment: Page 4-11, Section 4.3.3.2, Lines 17-18, 21-23. This language could be interpreted erroneously to indicate that discharges to groundwater are monitored under NPDES permits. The Supplement should address the water quality impacts of decommissioning activities on groundwater separately from the impacts on surface water. In lines 34-35, the Supplement should describe the conditions in which nonradiological impacts to groundwater and from non-point source pollution may be considered SMALL, MODERATE or LARGE.
(CL-1 6/35)
Comment: Page 4.12, Section 4.3.3.4. As noted above, the NPDES program only regulates nonradiological discharges to surface waters from point sources, not discharges to groundwater. This subsection should also draw conclusions about the potential water quality impacts of nonradiological discharges to groundwater and non-point source pollution during decommissioning. (CL-16/38)
Comment: I cannot stress enough that the groundwater issues are not adequately addressed.
(CL-20/68)
Response: Section 4.3.3 was extensively revised and reorganizedto address the above comments.
Comment: The Supplement should provide a more robust discussion of ground water impacts.
Further detail on EPA's concerns is found in the enclosed "Detailed comments." (CL-1615)
Response: Section 4.3.3 was extensively revised and reorganizedto respond to the specific comments.
Comment: Pages 4-11 to 4-12, Section 4.3.3.3. The discussion in this section could support a requirement for licensees to perform site-specific analyses of the potential water quality impacts of their decommissioning activities under certain circumstances; notably,-language such as performing these activities in different orders can have a "significantly different impact on Water quality," that the'SAFSTOR option "may exacer&bate water quality issues,"-and that certain activities "may result in changes in local water chemistry" implies the potential need for site-specific analysis.
November 2002 0-33 NUREG-0586 Supplement 1
Appendix 0 I In particular, the statement that rubblization may affect groundwater pH and thereby "affect the I transport properties of radioactive and nonradioactive chemicals in the subsurface" appears to I require a site-specific analysis: The document notes in other places (e.g., Page 1-7, Lines 1 26-33) that the nonradiological impacts of rubblization, including concrete leaching into I groundwater, can be evaluated generically. Section 4.3.3.3 does not support this conclusion.
I (CL-1 6/36) 1 Response: Although the decommissioning activities themselves and the orderin which the I activities are performed control the impacts to water quality the staff concluded that the impacts I on the nonradioactiveaspects of waterquality are SMALL (neitherdetectableor destabilizing),
I easily mitigatedand could be evaluatedgenerically. The staff also concluded that if a licensee I chose to dispose of slightly contaminatedbuilding debris below ground in a manner that is I consistent with the radiologicalsite release criteriaand solid waste disposal requirements the I non-radiologicalimpacts on the groundwaterwould be easily mitigated, small, and could be I evaluatedgenerically. The staff agrees with the commentor with respect to the evaluation of I the radiologicalimpacts to groundwater. A site specific analysis would be required,see Section 1 4.3.3.3. The comment did not provide new information relevant to this Supplement and will not I be evaluated further. The comment did not result in a change to the Supplement.
I Comment: Page 4-12, Section 4.3.3.3, Lines 16-17. The Supplement states that unintentional I releases of hazardous substances historically have been infrequent at decommissioning I facilities, and that except for a few substances, hazardous substances spills are "localized, I quickly detected, and relatively easy to remediate." Does this mean that a licensee must I perform a site-specific analysis of potential water quality impacts if a hazardous substance is I spilled or otherwise released to the environment during decommissioning. How is "hazardous I substance" defined? Examples or a better definition of "localized," "quickly detected," and "I "ease of remediation" should also be provided. (CL-16/37)
I Response: As the commentor stated, unintentionalreleases of hazardoussubstances during, I decommissioning have been infrequent and when they have occurred the spills are localized, I quickly detected, and remediated. The expectation is that the occurrence of such events will I continue to be infrequent. A site specific evaluation of the significance and consequencesof I the event is appropriateat the time of the occurrenceof the spill. The results of that evaluation I dictate the response to the spill. Even a site specific evaluation in advance of decommissioning I would not evaluate the impact of all potential hazardous waste spills underall conditions.
I Rather than evaluating the impact of all potentialonsite hazardousspills, licensees should take I specific measures to reduce the likelihood and magnitude of the spill using administrative I procedures,best managementpractices,and training. Should a spill occur, the licensee has I emergency procedures in place to rapidly respond to the spill and assess its consequences.
I Therefore the staff concludes that a detailedsite specific assessment of potentialspills before NUREG-0586 Supplement 1 0-34 November 2002
Appendix 0 the commencement of decommissioning activities would be of little value in protecting the groundwater. Accidental spills are infrequent and the focus should continue to be on prevention. If a spill should occur then evaluation and remediation of the consequences of the spill are required.The comment did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comment did not result in a change to the Supplement.
Comment: Under Water Quality p.4-10, 4-11 the NRC must stop giving the impression that it is I sheer chance that nuclear reactors are located on water, when in fact they require millions of gallons of water a day to operate. NRC assumes compliance with NPDES discharge permits for non-radioactive contaminants (NPDES and the Clean Water Act do not cover most radioactive contaminants, this was purposeful, so industry and the armaments crowd could do I what they liked,) however, NPDES permits are often violated or bypassed. (CL-20/28) I Response: The Supplement does not intentionallymislead the readerin the requirements for I large quantities of water necessary for cooling. See the explanationin Section 3.1.3, "Cooling I and Auxiliary Water Systems"' for a detailedaccount of once-through and closed cycle cooling I systems and water requirements. Point source discharges to surface waters are regulatedby I the-NPDESpermit system. Licensees are requiredto comply with the requirementsof their permit. This Supplement does not evaluate the potentialimpacts associatedwith non compliance of the NPDES permit. Radiologicalreleases to surface waters are regulatedby 10 I CFR Part20.' Licensees are requiredto stay within the 10 CFR Part20 Appendix B guidelines I for the release of radioisotopes. Again this Supplement does not evaluate the potentialimpacts I associatedwith noncompliance with the regulations. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not I result in a change to the Supplement.
Comment:, On Page 4-9 the NUREG concludes (Section 4.3.2.4) that the environmental impact of water usage will be small. In the evaluation they consider the anticipated reduction in I water usage for cooling in the condenser. This conclusion appears reasonable, however the analysis should also consider the environmental effects of the loss of heat provided by cooling I water'discharged to a closed lake or pond systermi that is a habitat for aquatic animals and vegetation. Many nuclear facilities are on natural or man-made bodies of water making this I environmental effect generic in nature. (CL-3118)
Response: The impacts of loss heat are not within the scope of this Supplement because the I impacts are caused by the'cessationof operations,not by decommissioning activities."The decision to cease operationsis the decision of the licensee, not the NRC. The comment did not I provide new information relevant to this Supplement and will not be evaluatedfurther. The comment did not result in a change to the Supplement.
November 2002 0-35 NUREG-0586 Supplement 1
Appendix 0 I Comment: (4.3.2.4) ENVIRONMENTAL IMPACTS of DECOMMISSIONING PERMANENTLY I SHUTDOWN NUCLEAR POWER REACTORS; Water Use -
Conclusions:
(The discussion I 4.3.1.4 is also relevant)
I The GElS stated, "The overall water use of a nuclear facility will dramatically decrease once the I reactor has stopped operating and the demand for cooling and makeup water ceases."
1 (4.9-4.10) On the surface, this statement appears to be correct. However, at Three Mile Island, I a considerable amount of "cleanup water" was created after the plant was shut down:
I In 1980, the Susquehanna Valley Alliance, based in Lancaster, successfully prevented Met Ed I (GPU) from dumping 700,000 gallons of radioactive water into the Susquehanna River. Ten I years later (December, 1990), despite legal objections, GPU began evaporating 2.3 million I gallons of accident-generated radioactive water (AGW).
S.... Can anyone at the NRC point to an official document that classifies 700,000 gallons of I radioactive water (which later grew to 2.3 million gallons) as 'SMALL"?
I The people who live and work around TMI have found that the risks associated with additional I cleanup water are not "SMALL." (CL-02148)
I Comment: (4.3.3.4) ENVIRONMENTAL IMPACTS of DECOMMISSIONING PERMANENTLY I SHUTDOWN NUCLEAR POWER REACTORS; Water Quality -
Conclusions:
"I The staff concludes that the issue of surface or ground water quality for all decommissioning I activities is generic and that the environmental impacts for these activities will be SMALL" I (4-12). Persistent "water quality" problems continue to plague TMI, a prematurely shut down I reactor:
I On November 2, 1993, in a letter to the NRC, GPU Nuclear acknowledged: "During the TMI-2 I accident, the cork seam located in the Auxiliary Building Seal Injection Valve Room (SIVR) was I contaminated with radioactive water. Attempts to contain the contamination within the room I have been unsuccessful. During the past 14 years, radioactive material has spread along the I joint in one direction into the Annulus, and in the other direction into the Auxiliary Building, I Service Building and Control Building West (R. L. Long, GPU Nuclear, Director, Services I Division TMI-2)."
NUREG-0586 Supplement 1 0-36 November 2002
Appendix 0 On June 4, 1998, "GPUN found several pipes penetrating the wall between the turbine building basement and the control building in Unit-2 to be open on both sides of the wall. This condition was contrary to the Unit-2 post-defueling monitored storage safety analysis report (PDMS-SAR) which requires entrances to the control building area to be watertight or provided with flood panels and openings that are potential leak baths to be sealed." (NRC Inspection Report, 50-289/98-08.) Less than a month later, on July 2, 1998, an LER was necessary due to the breaching of flood barriers "between the turbine building and the control building area due to inadequate fieldwork documents."
As recently as January 9 and 19, 1999, elevated tritium levels and potential leaks from the waste evaporator condensate storage tank for the months of January, February and March 1999 were reported.
Based on the above documented water quality problems the staff should revisit the rating of "water quality." (CL-02/49)
Response: Table 1-1 of this Supplement lists activities at facilities that have been permanently shutdown by a major accidentas out of scope. In addition, the problems discussed by these comments are not relevant to a generic assessment. The comments did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comments did not result in a change to the Supplement.
Comment: The water quality (Section 4.3.3) discussion does not address the potential impact of dewatering on the quality of ground water. If, for example, the ground water is a source of potable water and the facility is located near an ocean; dewatering could impact the quality (salinity) of the potable water. The NRC should revise the Supplement to clarify that the NRC will rely on the licensee's compliance with the NPDES permit for dewatering to conclude that the impact is SMALL. (CL-01/4)
Response: Groundwaterwithdrawal,such as dewatering, is regulatedby the state and not through the NPDES Permit. Furthermore,any groundwaterdewateringrequiredduring decommissioning would be temporaryand experience to date has revealed that it is minimal in volume and impact. The comment did not provide new information relevant to this SupplementI and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: Discharges should never have been allowed without prior cleanup and should not be now. (CL-20/29)
November 2002 0-37 NUREG-0586 Supplement 1
Appendix 0 I Response: The staff agrees with the comment. Dischargesare only permitted within I regulatorylimits. The comment did not provide new information relevant to this Supplement I and will not be evaluated further. The comment did not result in a change to the Supplement.
I Comment: Additionally, a thorough analysis of groundwater impacts seems lacking. Given I Georgia's current concern over the Floridian aquifer, it is again hard to believe that something I fundamental to life, water, is being analyzed generically. (AT-A/36)
I Comment: Additionally, a thorough analysis of groundwater impacts seems lacking. Given I Georgia's current concern over the Floridan aquifer, we request that a site-specific assessment I of groundwater quality be conducted prior to decommissioning. Also, we request that a more I thorough analysis of groundwater issues be researched prior to issuing the final EIS. As an I example, the NRC should request the most recent data from State agencies, such as the I Georgia Environmental Protection Division, that are involved in negotiations regarding "water I wars" between states-as in the ongoing dispute facing Georgia, Florida, and Alabama.
I (CL-08/19)
I Response: The use of groundwateris reducedsignificantly once the plantpermanently ceases I operation andis not expected to detectably change or destabilize the aquiferat any NRC I licensed site. Thereiore, the staff concludes that the impact to groundwaterfor I decommissioningis SMALL and no further mitigation is required. NRC uses groundwaterdata I from States and other agencies where NRC licensed facilitiesare sited to determine if changes I in groundwateruse at decommissioning sites are detectable or its use might destabilize I groundwatersources. Furthermore,during the review of the LTP, the licensee has to I demonstrate, on a site-specific basis, that operation and decommissioning of the facility has not I revealedgroundvwatercontamination in excess of the regulatorylimits. The comments did not I provide new information relevant to this Supplement and will not be evaluatedfurther. The I comments did not result in a change to the Supplement.
I Comment: Page 1-7, Section 1.3, Lines 30-33. The document needs to explain the grounds I for the determination that the environmental impacts of concrete leaching into site groundwater I as the result of rubblization can be evaluated generically. See also groundwater comments I below. (CL-16113)
I Comment: THIS GROUNDWATER CONTAMINATION ISSUE IS ANOTHER REASON WHY "I 'RUBBLIZATION" MUST BE FORBIDDEN, THE CONTAMINATION IN WHAT THEY WANT I TO RUBBLIZE AND BURY WILL LEACH TO THE GROUNDWATER AND DIRECTLY I IRRADIATE SOIL AND MICROORGANISMS. (CL-20/19)
I Comment: Would a leachate collection system be required where the rubble is stored in order NUREG-0586 Supplement 1 0-38 November 2002
Appendix 0 to monitor for potential impacts on the groundwater? (CL-51/15)
Response: The staff has determined that long term radiologicalaspects of rubblization, or onsite disposal of slightly contaminatedmaterialwould require a site-specific analysis and would be addressedat the time the license terminationplan is submitted. The nonradiological impacts would be nondetectable (see Section 4.3.3.3). They are consideredto be generic for all sites. The NRC has neither considered orapproved rubblization for any plant nor provided guidance on rubblizationmethods or practicesincluding the requirementfor a leachate collection system. This Supplement evaluates potentialenvironmentalimpacts of decommissioning. It does not set requirements for decommissioning activities or methods. The I comments did not provide new information relevant to this Supplement and will not be evaluated further. The comments did not result in a change to the Supplement.
Comment: Groundwater is used by countless communities, groundwater is eventually released I to surface and other water bodies and, as groundwater onsite is usually radioactively contaminated, it is a SERIOUS issue that MUST be dealt with, groundwater that is contaminated MUST be pumped out etc. (CL-20/18)
Response: Groundwaterin the vicinity of the facility is monitored during operation and decommissioning. Any mitigation of groundwatercontaminationwill be evaluated at the time of I the license terminationplan review. The comment did not provide new information relevantto I this Supplement and will not be evaluatedfurther. The comment did not resultin a change to the Supplement.
Comment: As all landfills leak, it will go to the groundwater and migrate offsite. (CL-20176)
Comment: Furthermore, the way the environmental and water issues were looked at during the time of plant licensing were often equally awful.- It all needs reconsidering. (CL-20/15)
Response: The comments can not be evaluatedbecause they did not provide specific information. The comments did not provide new information relevant to this Supplement and will not be evaluated further. The comments did not result in a change to the Supplement.
0.1.3 Air Quality Comment: 4.3.4 Air Quality, (4.2.4.2) pg. 4-14, last para., last full sentence:, This statement indicates that in most cases the number of shipments of other materials (non-radioactive I materials) will be small compared to those for LLW. This is not necessarily the case for a plant I which is removing all above grade facilities. However, this fact should not affect the conclusion I that the air quality related environmental impacts for these activities will be small. (CL-04/3)
November 2002 0-39 NUREG-0586 Supplement 1
Appendix 0 I Response: The statement in the Supplement is correctgiven sizes and contents of reactor I building and other structures requiredfor plant operation. The Supplement only addressesthe I impacts of the removal of radioactivestructuresand structures that were required for operation I of the plant. It does not include removal of other structures,including trainingfacilities and I administrationbuildings. Table 1-1 provides a list of areas that were not consideredwithin the I scope of the Supplement. The comment did not provide new informationrelevant to this I Supplement and will not be evaluatedfurther. The comment did not result in a change to the I Supplement.
I Comment: Section 4.3.4.2, p 4-14, 2nd paragraph - not all decommissioning sites have or will I have building ventilation systems, especially those that are in SAFSTOR for many years.
I Temporary systems will be established, as needed, for gaseous effluents during I decommissioning if installed systems are no longer functional. Monitoring of air quality is not I necessarily performed during the storage period, depending on activities, storage period and I source term. (CL-05/11)
I Comment: Section 4.3.4.2, p 4-14, lines 11 Not all decommissioning sites have or will I have building ventilation systems, especially those are in SAFSTOR for many years.
I Temporary systems will be established, as needed, for gaseous and particulate effluents during I decommissioning if installed systems are no longer functional. (CL-09/19)
I Comment: Monitoring of air quality is not necessarily performed during the storage period, I depending on activities, storage period and source term (CL-09/20)
I Comment: Page 4-14, Section 4.3.4.2, Lines 10-24. The Supplement states that most I decommissioning activities are conducted in facility buildings with systems that are "typically I maintained and periodically operated" during decommissioning to minimize airborne I contamination. As a result, "materials released when systems are dismantled and equipment is I removed are not likely to be released to the environment in significant quantities." Again, does I the reader assume that a licensee must perform a site-specific analysis of potential air quality I impacts if a certain level (definition?) of decommissioning activity may or will not be conducted I in facility buildings, or if the systems used to minimize airborne contamination may or will not be I maintained and/or operated according to a certain level of effort? How is "significant quantity" I defined? (CL-16/40)
I Response: Section 4.3.4.2 was revised to addressthe above comments and to provide a I better explanation of the process and terminology. The staff has determinedthat potentialair I quality impacts are SMALL and generic and no site-specific analysisis needed.
NUREG-0586 Supplement 1 0-40 November 2002
Appendix 0 Comment: Section 4.3.4.3, p 4 other activities during decommissioning could result in release of particulate matter. This includes temporary suspension of particles during cutting activities and production of particulates from processing of sodium and NaK at an FBR. Such particulate matter is filtered, as necessary, prior to release, to avoid or minimize adverse air quality impacts. While this is recognized on p 4-14, it should also be included in the section on "Results of Evaluation." (CL-09121)
Response: Section 4.3.4.3 was revised to address this comment.
Comment: Section 4.3.4.4, p 4-16, line 11 -add the following sentence to the end of the paragraph: "Particulates produced by decommissioning activities within buildings will be filtered as needed so that air quality impacts will be minimal (CL-09/22)
Response: Section 4.3.4.4 was revised to address this comment Comment: Page 4-14, Section 4.3.4.2, Lines 6-8. The Supplement states thatemissions from workers' vehicles "should be lower" during decommissioning than during plant construction or0 outages and are "usually lower" than during planrt-op'eration. Is there any data from decommissioned plants to support these statements? Also, does one assume that a site-specific analysis of potential air quality impacts is required if such emissions may or will be' higher than during plant construction, outages or operation? (CL-1 6/39)
Response: Assuming that the mix of vehicles driven by the decommissioning work force is the same as the mix of vehicles driven by the onsite work force duringplant constructionand "
operation, the staff concludes that total emissions from all workers' vehicles should decrease due to the decreasein the work force following cessation of plant operations,and should not be a problem during decommissioning of any plant. Section 4.3.4 was changed to address this comment.
Comment: Page 4-14, Section 4.3.4.2, Lines 26-33. The Supplement states that fugitive dust emissions during movement of equipment outside of facility buildings are "likely ... to be confined to the immediate vicinity of the equipment," "in general ... limited to a small number of events" and "of relatively short duration." Again, is the reader to assume that a licensee must perform a site-specific analysis of potential air quality impacts where one of these conditions is not met? Also, how are "immediate", "small number of events" and "relatively short duration" defined? Further, must the facility employ mitigation'measures to minimize dust; if so, where are these specified?' (CL-16/41)
Comment: Page 4-14, Section 4.3.4.2, Lines 40-43 -and Page 4-15, Section 4.3.4.2, Lines 1-2.
November 2002 0-41 NUREG-0586 Supplement 1
Appendix 0 I The Supplement states that there is an average of less than one shipment per day of low-level I waste (LLW) from a decommissioning plant; that, "in most cases, the number of shipments of I other materials to and from a decommissioning facility will be less than that for LLW;" and that I therefore emissions associated with the transportation of materials from such a plant "are not I expected to have a significant impact on air quality." Again, is the reader to assume that a I licensee must perform a site-specific analysis of potential air quality impacts if the number of I shipments of materials to or from its decommissioning facility will exceed the level of less than I one shipment per day? (CL-16/42)
I Response: Section 4.3.4 was revised to addressthe above comments and to provide a better I explanation of the processand the terminology. The experience to date at plants undergoing I decommissioninghas not resultedin air quality issues relatedto fugitive dust. Furthermore,the I licensee must evaluate impacts resultingfrom decommissioning activities againstpreviously I issued environment assessments (10 CFR 50.82 (a)(b)(ii). If the evaluation determines that the I impacts are greaterthat previously assessed then the impact is outside the envelope I establishedby this GELS.
I Comment: Page 4-15, Section 4.3.4.2, Lines 4-7. The definition of what constitutes SMALL, I MODERATE and LARGE air quality impacts would be helped by providing specific examples I from decommissioning or decommissioned facilities. (CL-16143)
I Response: Section 4.3.4 was revised to address this comment. The criteria for defining I destabilizationand detectibility was clarified in Section 4.3.4.2.
I Comment: Page 4-15, Section 4.3.4.3, Lines 21-23. This section states that "(n]o anticipated I new methods of conducting decommissioning and no peculiarities of operating plant sites are I anticipated to affect this pattern" of managing fugitive dust. Is the reader to assume that a I licensee who proposes using a new decommissioning method must perform a site-specific I analysis of potential impacts? (CL-16/44) 1 Response: The staff expects licensees to continue to use dust control measures appropriate I for the activity being performed and the site. The staff assumes that if a new method of I decommissioning is contemplatedby a licensee then the licensee would evaluate the impact of I the new methodology on all the environmental issues including fugitive dust. If the evaluation I concludes that the amount of fugitive dust releasedby the new activity is significantly greater I than what would be expected using the current technology and the impact would not be I SMALL, then the licensee would be outside the envelope of impacts given in this Supplement.
I The comment did not provide new information relevant to the supplement and will not be I evaluated further. The comment did not resultin a change to the supplement.
I Comment: Air quality issues, Page 4-12, etc., do not address the fact the HEPA filters are NUREG-0586 Supplement 1 0-42 November 2002
Appendix 0 about as good as useless for radioactive particulate holdup and sand filters should be added as well. (CL-20/31)
Response: Well establishedtechnology exists for filtering airborne radionuclides. Airborne releases are requiredto be within regulatorylimits given in 10 CFR Part20. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not resultin a change to the Supplement.
Comment: On Page 4-16 the NUREG concludes (Section 4.3.4.4) the environmental impact of air emissions will be small. In the evaluation they did not consider that many sites use extraction steam to provide plant heat in the winter months. The shutdown of the reactor means that Aux Boilers will be operated for longer periods to provide heating steam: This needs to be considered in the NUREG or many facilities will need to address this issue in the PSDAR. (CL-31/9)
Response: The staff has concluded that impacts on airquality, including the increaseduse of auxiliaryboilers for heating, could be evaluatedgenericallyand is considered to be SMALL and will not require a site-specific analysis. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to I the Supplement.
Comment: This is of special significance if explosives are to be used for demolition, which will I generate radioactive fugitive dust. (CL-5119)
Response: Controlmeasures will be requiredduring demolition to keep releases, including those associatedwith fugitive dust, within regulatory limits regardlessof the methods used during demolition. The NRC license will not be terminated until the residualradioactivityat the I site is below regulatorylimits. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not resultin a change to the Supplement. .
Comment: (4.3.1.4) ENVIRONMENTAL IMPACTS of DECOMMISSIONING PERMANENTLY I SHUTDOWN NUCLEAR POWER REACTORS; Air Quality -
Conclusions:
"Fugitive-dust from those activities performed outside of the building is temporary, can be I controlled mitigative measures, and will generally not be noticeable off site." Once again the I experience of TMI-2 is instructive:
In June-July, 1980, for 11 days, Met Ed vented 43,000 curies of radioactive Krypton-85 I November 2002 0-43 NUREG-0586 Supplement 1
Appendix 0 (10-year half-life; beta and gamma) and other radioactive gasses into the environment without having scrubbers in place. Yet in November 1980, the U.S. Court of Appeals for the District of Columbia ruled that the krypton venting was illegal.
From July 24-27, 1984, during the reactor head lift, which was delayed to brake failure on the polar crane, GPU vented radioactive gasses into the environment.
On September 25, 1989, two cleanup workers received radiation exposures while handling a "small piece of reactor core debris" in the decontamination area.
After ten years of defueling activities, 5,000 TMI workers had received "measurable doses" of radiation exposure. The NRC staff should reconsider the placement and value of the terms "temporary" and "fugitive", and rethink the adverse affects of "air quality" on workers.
(CL-02/50)
I Response: Table 1-1 of this Supplement lists activities at facilities that have been permanently I shutdown by a major accident as being out of scope. Venting of radioactivegas related to a I serious accident or accidentalhandling of core debris are activities that would not occur at a I facility that is undergoing decommissioning. The term "fugitive dust' refers to particles that are I resuspendedfrom surfaces, such as the ground as a result of wind or mechanicalaction. The I term does not imply contamination. Constructionactivities of any sort have the potential to I impact airquality by releasingfugitive dust. As a result,mitigation measures have been I developed and are routinely used to control fugitive dust at constructionsites. When used I properly, fugitive dust mitigation measures are effective. The comment did not provide new I information relevant to this Supplement and will not be evaluated further. The comment did not I result in a change to the Supplement.
1 0.1.4 Ecology I Comment: Section 4.3.5, Page 4-19, 1st paragraph - This conclusion would result in I site-specific analyses for the use of areas beyond the previously disturbed areas if a potential to I impact the aquatic environment exists. The vagueness of the condition "potential to impact" I could result in a site-specific analysis for any potential no matter how remotely possible. The I NRC should consider rewording the condition to say 'there is expected to be or likely to be an I impact" Also on the previous page (Page 4-18 last paragraph in Section 4.3.5.2,) it appears I that a site-specific assessment would be required merely if the aquatic environment has not I been characterized. NRC should clarify that a site-specific EIS is not necessary just because I the lack aquatic environment characterization, but rather, if an area beyond the previously I disturbed area is to be used and no associated characterization of the aquatic environment, if I applicable, exists, then such a characterization should be conducted. Then as stated above, if I there is expected to be or likely to be an impact to the aquatic environment, then a site-specific NUREG-0586 Supplement 1 0-44 November 2002
Appendix 0 analysis should be conducted. (CL-05/14)
Comment: 'Section 4.3.6, p. 4-23, last paragraph - This section should be reworded as in section 4.3.5.4, as modified by the comment above. (CL-05/15)
Comment: 4.3.5 Aquatic Ecology (4.3.5.4) pg. 4-19, 1st para., last sentence. This conclusion would result in site-specific analyses for the use of areas beyond the previously disturbed areas if there is a potential to impact the aquatic environment. The vagueness of the condition "potential to impact" could result in a site-specific analysis for any potential no matter how remotely possible. The NRC should consider rewording the condition to say "there is expected to be or likely to be an impact." Also on the previous page (pg. 4-18 last para. in Section 4.3.5.2,) it appears that a site-specific assessment would be required merely if the aquatic environment has not been characterized. NRC should clarify that a site-specific EIS is not necessary just because the lack of environment characterization, but rather, if an area beyond the previously disturbed area is to be used and no associated characterization of the aquatic environment, if applicable, exists, then such a characterization should be conducted. Then, as stated above, if there is expected to be or likely to be an impact to the aquatic environment, then a site-specific analysis should be conducted. (CL-04/4)
Comment: 4.3.6 Terrestrial Ecology (4.3.6.4), pg. 4-23, last para. in Section 4.3.6.4, last sentence. This should be reworded to be the same as Section 4.3.5.4 as modified in the comment above. (CL-04/5)
Comment: Page 4-17, Section 4.3.5.2, Line 38 and page 4-18, Section 4.3.5.2, Lines 4 and
- 14. The term "previously disturbed" needs definition. (CL-1 6/46)
Comment: Page 4-18, Section 4.3.5.2, Lines 14-17. The Supplement should provide specific I guidance on how to weigh the primary factors to be considered in evaluating the adverse impacts of decommissioning activities in "previously disturbed" areas. How much habitat can be disturbed before a site-specific analysis is required? How much time can have passed since I the initial disturbance? How is a licensee to evaluate the successional patterns of the aquatic communities? (CL-16/47)
Comment: Page 4-21, Section 4.3.6.2, Lines 15-17. The Supplement should provide specific guidance on how to-weigh the primary factors to be considered in evaluating the adverse impacts of decommissioning activities in "previously disturbed" areas. How much habitat can be disturbed before a site-specific analysis is required? How much time can have passed since I the initial disturbance? How is a licensee to evaluate'the successional patterns of the native communities?_ (CL-16/53) I November 2002 0-45 NUREG-0586 Supplement 1
Appendix 0 I Comment: Page 4-19, Section 4.3.5.4, Lines 4-6. This subsection appears to define a "I "previously disturbed area" as "within the security fences or surrounding paved, graveled, or I otherwise developed areas without removal of near-shore or in-water structures." Does this I definition also apply to land use activities on page 4-6, Section 4.3.1.2, Lines 15-16? Does the I definition mean that a licensee who plans to remove near-shore or in-water structures in "I "previously disturbed areas" must perform a site-specific analysis of the potential aquatic I ecology impacts? (CL-16/49)
I Comment: Page 4-19, Section 4.3.5.2, Lines 8-11. How is "previous" defined? What is the I relationship between these "previous ecological surveys that indicate a low probability of I adversely affecting ecological resources" and the aquatic environment characterizations I referred to on Page 4-18, Lines 17-23? This subsection suggests that the aquatic ecology I impacts of decommissioning activities conducted in areas that were not "previously disturbed" I will be SMALL if a previous survey has demonstrated a low probability of adverse effects on the I ecosystem, while Section 4.3.4.2 suggests that the aquatic ecology impacts of I decommissioning activities in such areas will be SMALL if a characterization has demonstrated I the possibility of some adverse effects to "sensitive resources," but the facility will manage I those resources for their protection during decommissioning activities. (CL-1 6/50) 1 Comment: Page 4-19, Section 4.3.5.2, Lines 11-16. The Supplement should define more I precisely the circumstances under which a site-specific analysis of potential aquatic ecology I impacts in previously undisturbed areas is required. How is the licensee to determine whether I an activity has the potential to impact the environment? How should the magnitude of potential I impacts be determined? Also, can a licensee avoid doing a site-specific analysis by I implementing a protection plan to protect the aquatic environment? (CL-16/51)
I Comment: Page 4-21, Section 4.3.6.2, Lines 1, 15 and 24. The term "previously disturbed" I should be defined or examples provided. (CL-16/52)
I Comment: Page 4-22, Section 4.3.6.2, Line 43 and Page 4-23, Section 4.3.6.2, Lines 1-5.
1 The Supplement should better define or provide examples of circumstances under which a I site-specific analysis of potential terrestrial ecology impacts in previously undisturbed areas is I required. What constitutes a "potential of adverse impact to important terrestrial resources"?
I What is an "important" terrestrial resource? The document should provide criteria by which a I licensee can determine whether an activity has this "potential," as opposed to merely a "low I probability of adversely affecting ecological resources." The Supplement should also clarify I whether a licensee can avoid doing a site-specific analysis by implementing a protection plan to I protect the terrestrial environment. (CL-16/60)
NUREG-0586 Supplement 1 0-46 November 2002
Appendix 0 Comment: Page 4-21, Section 4.3.6.2, Lines 25-29. The document states that the potential impact of disturbing areas beyond the original construction area is SMALL and can be characterized generically if "the terrestrial environment has been characterized." Moreover, a site-specific analysis is needed if "decommissioning activities occur in terrestrial environments that have not been characterized." What must this characterization consist of, and when/how recently must it have been performed, to allow a licensee to conclude that it is sufficient and can properly support the conclusion that potential impacts are SMALL? (CL-1 6/55)
Comment: Page 4-22, Section 4.3.6.4, Lines 37-39. This subsection appears to define a "previously disturbed area" as "within the security fences or surrounding paved, graveled, or otherwise developed areas." How does this definition relate to the definition provided on Page 4-6, Section 4.3.1.2, lines 15-16? (CL-16158)
Comment: Page 4-22, Section 4.3.6.4, Lines 40-43. This subsection suggests that the terrestrial ecology impacts of decommissioning activities conducted in areas that were not previously disturbed will be SMALL if a "previous" survey has demonstrated a low probability of I adverse effects on the ecosystem. How recent must the "previous" survey have been? ' I (CL-i 6159)
Comment: My question is with regard to the site-specific issues. One of the site-specific issues is threatened, I'm sorry, aquatic and terrestrial ecology. And it says, the rationale,.
activities occurring beyond previously disturbed areas., And I'm wondering what the definition of I a previously disturbed area is. Is there a time frame, or how that is defined? (CH-BI1)
Response: Section 4.3.5 Aquatic Ecology, and Section 4.3.6, TerrestrialEcology, have been I extensively revised to address the above comments and the concept of "previouslydisturbed 1 land"no longer is the criteriafor initiatinga site-specific analysis. The concept of relying on a I previous ecologicalsurvey and an environment protectionplan to determine whether a site- I specific analysis is needed has also been eliminated.
Comment: 4.3.5 Aquatic Ecology (4.3.5.2) pg. 4-17, 1st para. in Section 4.3.5.2, 4th sentence, I "Aquatic environment s" should be corrected. (CL-04/18)
Response: Section 4.3.5.2 was changed to eliminate the typographicalerror.
Comment: Page 4-16, Section 4.3.5, Lines 25-29. This section's discussion of impacts to I aquatic resources following plant shutdown seems to contradict the example given on page 1-5, I lines 6-7, of plant discharges post-shutdown being outside the scope of this document. - I Similarly, the discussion at Page 4-19, Section 4.3.6, Lines 26-29 seems to contradict page 1-5. I November 2002 0-47, NUREG-0586 Supplement 1
Appendix 0 I Note also the comment above on the page 1-5 language. (CL-16/45)
I Response: Section 4.3.5 was changed to eliminate the contradiction.
I Comment: Page 4-18, Section 4.3.5.2, Lines 17-23. The Supplement states that the potential I impact of disturbing areas beyond the original construction area is SMALL and can be I characterized generically if 'the aquatic environment has been characterized," and that a I site-specific analysis is needed if "decommissioning activities occur in aquatic environments I have not been characterized." What must this characterization consist of, and when and how I recently must it have been performed, to allow a licensee to conclude that it is sufficient and I can properly support the conclusion that potential impacts are SMALL? (CL-1 6/48) 1 Response: Section 4.3.5, Aquatic Ecology, has been revised to eliminate the use of an I environmental characterizationto determine whether a site-specific analysis needs to be I performed.
I Comment: Page 4-21, Section 4.3.6.2, Lines 23-25. What is a "significant" terrestrial I resource? What does "potentially" affected mean? These terms need to be defined or I examples provided so that licensees understand when they are required to perform a I site-specific analysis. (CL-16/54)
I Response: Section 4.3.6.2 has been extensively revised and the phrase "significantterrestial I resource"is not used in this section in the FinalSupplement. The comment is no longer I relevant. The comment did not provide new information relevant to this supplement and will not I be evaluated further. The comment did not result in a change to the Supplement.
I Comment: Pages 4-21 to 4-22, Section 4.3.6.3. The document assumes that "[i]n most cases, I the amount of land required to support the decommissioning process is relatively small and is I normally a very small portion of the overall plant site." It also states that "licensees typically I anticipate utilizing an area of between 0.4 ha (1 ac) to approximately 10.5 ha (26 ac) to support I the decommissioning process." EPA assumes this means that a licensee must perform a I site-specific analysis of impacts if the terrestrial ecology impacts of decommissioning activities I may or will be greater than 10.5 ha (26 ac). If this assumption is incorrect, when is a I site-specific analysis required and why? (CL-1 6/56) 1 Response: The estimates of the typical area used to support decommissioning are based on I the decommissioning experience to date. They are not criteria. The licensee must evaluate I impacts resulting from decommissioning activities againstpreviously issued environmental I assessments (10 CFR 50.82(a)(b)(ii)). If the evaluation determines that the impacts are greater I than previously assessed then the impact is not SMALL and the impact is outside the envelope NUREG-0586 Supplement I 0-48 November 2002
Appendix 0 establishedby this Supplement. The comment did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comment did not result in a change to the Supplement.
Comment: Page 4-22, Section 4.3.6.3, Lines 27-29. The document assumes that the "activity of rubblization of construction material should not have significant nonradiological impacts beyond other decommissioning activities except for potential short-term noise and dust effects."
However, on Page 4-12, the document states that rubblization may affect groundwater pH and thereby "affect the transport properties of radioactive and nonradioactive chemicals in the subsurface." Any radioactive or nonradioactive chemicals in the subsurface that are mobilized as a result of concrete leaching from rubblized material could have an adverse effect on the terrestrial ecology of a facility. For this reason, EPA recommends that the Supplement require a site-specific analysis of all of the potential environmental impacts of rubblization, both nonradiological and radiological. (CL-16157)
Response: The staff, based on the available literature and experience has determined that the impacts associatedwith concrete leachingfrom subsurface burial of uncontaminateddemolition debris are SMALL, localized and can be evaluatedgenerically. Evaluation of the long-term radiologicalaspects of rubblization(or onsite disposalof slightly contaminatedmaterial)would require a site specific analysis and would be addressedat the time the LTP is submitted. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: (4.3.6.4) ENVIRONMENTAL IMPACTS of DECOMMISSIONING PERMANENTLY SHUTDOWN NUCLEAR POWER REACTORS: Conclusion - Terrestrial Ecological Resources:
The NRC staff aptly stated,"...the magnitude, (i.e., SMALL, MODERATE, LARGE) of potential impacts will be determined through a site-specific study ... " These flexible barometers should be I applied to all the above mentioned Conclusions. (CL-02/53) I Response: The NRC establishedan envelope of environmentalimpacts resulting from I decommissioningactivities, identified those activities that can be boundedby a generic I evaluation, and identified those that requirea site-specificanalysis. The NRC concentratedthe I environmentalanalysis on those activities with the greatestlikelihood of having an environmentalimpact. The staff determinedfor onsite t6rrestrialissues, that the impacts of decommissioningactivities are SMALL and the analysis need not be site-specific analysis. For I those impacts that have been determined to be generic, a licensee is requiredto evaluate impacts resulting from decommissioning activities againstthis Supplement or previously issued I environmentalassessments (10 CFR 50.82 (a)(6)(ii). If the evaluation determines that the impacts are greaterthan previously assessed,then a site-specific analysis is required. The comment did not provide new information relevant to this Supplement and will not be evaluated I November 2002 0-49 NUREG-0586 Supplement 1
Appendix 0 I further. The comment did not result in a change to the Supplement.
m ent: Regarding aquatic ecology p.4-16, as touched on earlier, the environm ental im pact I statements originally written for the plants were often very poor, and did not mention that the I discharge water would be radioactively contaminated nor that sediment would be contaminated I for miles etc. (CL-20/36)
I Response: The originalEnvironmentalImpact Statements for power reactorsacknowledged I that there would be routine releases of radionuclidesto the aquatic environment that would be I controlled to meet regulatoryrequiremnents. The comment did not provide new information I relevant to this Supplement and will not be evaluatedfurther. The comment did not result in a I change to the Supplement.
I Comment: Other aquatic environmental impacts also merit site-specific review. (CL- 1/5)
I Response: The comment can not be evaluatedbecause it did not provide specific information.
I The comment did not provide new information relevant to this Supplement and will not be I evaluated further. The comment did not result in a change to the Supplement.
I Comment: (4.3.5.2) ENVIRONMENTAL IMPACTS OF DECOMMISSIONING PERMANENTLY I SHUTDOWN NUCLEAR POWER REACTORS; Aquatic Ecological Resources-
Conclusions:
I The staff found that*....the impact to aquatic ecology for all decommissioning activities is I generic and that the environmental impact for these activities is SMALL." Unfortunately, the I staff biologists are unfamiliar with the unique water chemistry of the Susquehanna River and I historic infestations that have afflicted Three Mile Island. In February 1986, one celled I organisms believed to be fungus, bacteria and algae-like creatures were discovered. These I creatures obscured the view of the reactor core. And impeded the cleanup of Three Mile I lsland-2.
I On June 23, 1999, Three Mile Island, trying to rid itself of clams, recently released too much of I a potentially hazardous chemical into the Susquehanna River. State regulations allow TMI to I release 0.3 parts per million of Clamtrol back into the Susquehanna River. For about an hour, I the plant was releasing 10,500 gallons per minute containing twice the amount. (CL-02/51)
I Response: Table 1-1 of this Supplement lists activities at facilities that have been permanently I shutdown by a major accidentas out of scope. The microorganismsdiscussed in the comment I were found inside the reactorvessel, and were not a result of an impact on the Susquehanna NUREG-0586 Supplement 1 0-50 November 2002
Appendix 0 River. The operating unit, TMI-1, rather than TMI-2 was involved in the release of Clamtrol to control clams. Dischargeof chemicals to control molluscs occurs at operatingfacilities and is regulatedby the NPDES permit issued by the state or EPA. The comment did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comment did not result in a change to the Supplement.
Comment: It is a proven fact - proven by the old Atomic Energy Commission and its contractors, - that migratory birds become contaminated eating seeds, drinking water~and so on at radioactively contaminated sites, wetlands areas etc. and the birds carry this contamination in their bodies worldwide. NRC, DOE and licensees violate the MBT by not protecting birds from such contamination, and by spewing radioactive noble gases out that impact passing birds.
This is one of the reasons I suggest that netting or similar should be placed over the sites in question, fine wire mesh set at an angle that can have leaves and other debris hosed off it, it must be small enough to keep birds out down to the size of hummingbirds. Enclosed, such an,,
obscene site poses slightly less of a threat to birds and other wildlife, the utilities can pay for it all, it can come out the salaries of the top management and company owners. And on the endangered bird subject, let me address the Migratory Bird Treaty Act of 1918,- (p.4-20).
(CL-20/40)
Response: Licensees are required to take measures necessary to control the spreadof contamination through the animal pathway. Studies to date have not shown that the spreadof, contaminationby this route is in any way significant,but ratheris very minor. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: (4.3.1.4) ENVIRONMENTAL IMPACTS of DECOMMISSIONING PERMANENTLY SHUTDOWN NUCLEAR POWER REACTORS; On site/Off site Land Use -
Conclusions:
The GElS stated, "It is rare for decommissioning activities to affect off-site land use ..." This statement fails to recognize that most nuclear generating stations are located in close proximity to substantial water resources. The Susquehanna Steam Electric Station, Three Mile Island and Peach Bottom are located on or adjacent to the Susquehanna River which feeds the most productive estuary in America, i.e., the Chesapeake Bay. (CL-02/45)
Response: Table F-2 identifies each of the licensed nuclearpowerplants and the cooling watersource.- The comment cannot be evaluatedbecause it did not provide specific information.-The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: The Draft GElS does not adequately consider the effects on aquatic ecology caused by an accidental, radioactive release. (CL-11/4)
November 2002 0-51 NUREG-0586 Supplement 1
Appendix 0 I Comment: NRC saying that it has not established standards to biota other than humans on the I basis that limits established (by the aforementioned) for the public would provide adequate I protection for other species is outrageous and contrary to what has been established for I decades. (CL-20/9)
I Comment: When thinking about exposure to plants and animals and fish, one needs to take I the effects to an infant and to a child in the womb to better approximate the effects to wildlife, I the smaller the non-human entity (e.g. a bird, a frog) the child in utero down to embryonic level I would be appropriate. We all know what happens when an embryo is exposed - namely death I or severe damage. The same happens to birds eggs. (CL-20/10)
I Response: The NRC establishedstandards for radiologicalexposures to humans on the basis I that limits establishedfor the exposed members of the public would provide adequate I protection for otherspecies. No standards were establishedfor radiologicalexposure to biota I other than humans. The validity of the assumption that radiationguidelines, which are I protective of the public, Would also provide adequateprotection to plants and animals has been I upheld by nationaland internationalbodies that have examined the issue, including the National I Council on Radiation Protectionand Measurement (NCRP Report No. 109, Effects of Ionizing I Radiation on Aquatic Organisms, 1991) and the InternationalAtomic Energy Agency (IAEA I Technical Report Series No. 332,- Effects of Ionizing Radiation on PlantsandAnimals at Levels I Implied by CurrentRadiation ProtectionStandards, 1992). Both of those studies were I conducted in part to evaluate the originalassumptionpresented in 1977 by the International I Commission on RadiologicalProtection (ICRP Publication26, 1977). In all of these cases, it I has been emphasized that such radiationlevels may adversely affect non-human species, but I effects at the population level are not detectable. The comments did not provide new I information relevant to this Supplement and will not be evaluated further. The comments did I not result in a change to the Supplement.
I Comment: Removal of intake/outfall structures may be the most beneficial action to the I aquatic ecology, but it should not go forward without site-specific study of the environmental I impacts. (CL-11/8)
I Response: The removal of the intake/outfall structuresand other SSCs after operation of the I facility is discontinuedis not expected to detectably change or destabilize the aquaticenviron I ment. The removal process is expected to be conducted in a mannerand at a time that will I have minimal impact to the aquatic environment. In addition, it is anticipatedthat best I management practices would be employed and the necessarypermits obtained. All impacts I would be, at most, a short-term impact. Therefore, the staff concluded that the impact to the I aquaticenvironment for these decommissioningactivities is SMALL and no further mitigationis I required. The comment did not provide new information relevant to this Supplement and will NUREG-0586 Supplement 1 0-52 November 2002
Appendix 0 not be evaluated further. The comment did not result in a change to the Supplement.
Comment: The aquatic ecology issue should also be site-specific (CL-20/38)
Response: The analysis in the Supplement shows that the impacts on aquatic ecology will not be detectable. Therefore, the staff concluded that the impact to the aquatic environmental to these decommissioningactivities is SMALL. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
0.1.5 Threatened and Endangered Species Comment:- 4.3.7 Threatened and Endangered Species (4.3.7.4), pg. 4-25, last para., last sentence. This conclusion indicates that the NRC will meet its responsibilities on a site-specific I basis during any decommissioning process, but it does not specify how the NRC will meet its 1 responsibilities or what information it will need from licensees. (CL-04/6)
Response: The responsibilitiesunder ESA will be met through interactionsamong the licensee, the NRC, and the appropriateresource agency either the U.S. Fish and Wildlife Service (FWS) or the NationalMarine FisheriesService (NMFS). Information requiredof the licensee will likely depend on the activity and the species potentiallypresent. This process is.
describedin Section 1.5. The staff has determined that it will conduct informal consultations after the licensee'announcespermanent cessation of operations. The comment did not provide I new information relevant to this Supplement and will not be evaluated further.' The comment did not result in a change to the Supplement.
Comment: Page 4-23, Section 4.3.7, Lines 10-12. The supplement should elaborate on the I basis for the statement that "the potential impacts of nuclear power facility decommissioning efforts on threatened or endangered species will normally be no greater and likely less than the I effects of plant operations." (CL-16/61)
Response: There are one or more threatenedand endangeredspecies in the general vicinity I of virtually all licensed commercial nuclearfacilities: Very few of these facilities have had documented adverse impacts on the local threatenedand endangeredspecies, andin those rare instances when there is an effect, the species that are affected are almost all aquatic species. An operating reactorcan affect threatened or endangeredaquaticspecies via water I intake through the cooling system resultingin impingement or entrainment, through the heated I dischargefrom the cooling system, or through the purposeful or inadvertentaddition of 'I chemicals or contaminants to the cooling water stream. When the plant is shut down for I decommissioning the reactorcooling system is shut down, and therefore the impact on aquatic I environment is much lower than the impacts of an operatingreactor. Therefore, the potential- I November 2002 0-53 NUREG-0586 Supplement 1
Appendix 0 I effects on the threatenedand endangeredspecies will likely be less during decommissioning I than during operations. For terrestrialspecies, the most common potentialimpacts from I operatingplants are due to transmissionline rights-of-way maintenance activities. Most I transmissionlines (beyond the switchyard)are expected to remain energized even after a I commercial nuclearpower facility ceases operationand the right-of-way maintenanceactivities I are expected to continue. Therefore, the potential impacts of decommissioning on terrestrial I species will normally be no greaterthan the potential impacts of plant operation. Section 4.3.7 1 was revised.
I Comment: Page 4-25, Section 4.3.7.2, Lines 3-7. The Supplement should provide guidance I on determining the amount of habitat that can be disturbed beyond previously disturbed areas.
I (CL-16/62)
I Response: The evaluation of impacts on threatenedand endangeredspecies will be I conducted on a site-specific basis. Guidance on the amount of habitatdisturbedis irrelevant.
I The comment did not provide new information relevant to this Supplement and will not be I evaluated further. The comment did not result in a change to the Supplement.
1 0.1.6 Radiological I Comment: Section 3.1.4 Formation and Location of Radioactive Contamination and Activation I in an Operating Plant, pg. 3-15. This description should include the activation of corrosion I products as a contributor to radioactive contamination. (CL-04/16)
I Response: Radioactive corrosionproducts are the result of activationand can be considered I activation products. The comment did not provide new information relevant to this Supplement I and will not be evaluated further. The comment did not result in a change to the Supplement.
I Comment: Section 3.1.4, Pg 3-15, last paragraph - clarify whether the last sentence is I referring to radiation exposure during decommissioning or operation. In context, the inference I is that the activation products provide the main source of radiation exposure to plant personnel I in an operating plant, but typically contaminated materials provide more exposure to plant I personnel during operation. (CL-05/8)
I Response: The sentence refers to the decommissioningprocess. Section 3.1.4 was revised I for clarification.
I Comment: It also is not clear how, why, and how many plants were selected for Tables G-1 1 I and G-12. Additionally, the first sentence of the fourth paragraph should indicate that the data NUREG-0586 Supplement 1 0-54 November 2002
Appendix 0 is estimated worker dose for major types of decommissioning activities. Actual data appeared to be listed for only one plant in the tables. (CL-09/41)
Comment: Section G.2.2,-p G while the conclusion appears correct, it is strange that information was only available for a small sample of facilities. This data is reported to the NRC annually by licensees. (CL-09/45)
Comment: Table G the basis of this table should be better explained. How were the plants selected? What years are covered? (CL-09/46)
Comment: Table G how were the plants listed in this table selected? It appears to be a strange non-representative sample. (CL-09147)
Response: Data were used to be representativeof operatingplants aroundthe country including an operatingBWR and two PWRs, two different vendors, and two different location types (coastaland interior). Two shutdown power reactor facilities were also included. Data on permanentlyshutdown plants were used as provided by the licensee or found in references.
Tables G-11 and G-12 have been revised.
Comment: In Appendix G, Iwas very surprised to-read of excess malignancies that have been experienced at doses of 10 REM. This is contrary to the health physics and radiological health I handbook and other material that I've read over-the more than 25 years I've spent in this industry. And Ithink that needs to be addressed and reevaluated. (CH-D/11)
Response: The statement made in Appendix G relatedto the health effects of doses of I approximately 10 rem is correct and is taken from the'BEIR V report. However, the I commentor's statement that the excess maljnawncies'were "experienced"isincorrect.--They were calculaatedbased on the extrapolation'ofanrassumedlinearrelationshipbetween dose I and malignancies.. The comment did not provide-new information relevant to this Supplement I and will not be evaluatedfurther. The comment did not result in a change to the Supplement:
Comment: 4.3.8 Radiological (4.3.8.3), pg. 4-29, 4th full para. last sentence. Maine Yankee agrees that it is not necessary to update the estimates for exposure found in the 1988 GELS.
(CL-0417)
Response: The staff agrees with this comment. The comment did not provide new information I relevant to this Supplement and will not be evaluatedfurther. The comment did not result in a I change to the Supplement.
November 2002 0-55 NUREG-0586 Supplement 1
Appendix 0 I Comment: Section 3.1.4, page 3-15, does not reflect that alpha-emitting Transuranic I radioactivity is significant at some plants. This radioactivity is formed after failed fuel releases I small amounts of Uranium (as well as fission products) to the reactor coolant. Subsequent I activation of the Uranium results in the formation of Transuranic isotopes of Plutonium, I Americium and Curium, most of which decay with alpha radiations. For the plants where this I issue is significant, the production of airborne alpha radioactivity during decommissioning I activities must be carefully controlled to avoid radiation exposure from inhaled alpha I radioactivity. (CL-15/6)
I Response: The NRC staff acknowledge that failed fuel can result in alpha contamination within I the facility. However, the standardsfor protection of workers found in 10 CFR Part20, "1 "Standardsfor ProtectionAgainst Radiation"provide adequate protection for workers. The I comment did not provide new informationrelevant to this Supplement and will not be evaluated I further. The comment did not result in a change to the Supplement.
I Comment: Page 3-16, Section 3.1.4, Line 1. This line notes that spent fuel comprises the I largest amount of radioactive material at a shutdown facility. It would be informative to include I here a summary of or reference to the data in Appendix G on the amount of radioactive material I at various types of power plants. (CL-1 6/20) 1 Response: The amount of radioactivematerialvaries between facilities and is dependent on I factors such as the type of facility, the size of the facility, the length of time the facility is I operatedand other variables. Because of the number of factors affecting the amount of I radioactivematerial,the staff does not believe this information will be useful. The comment I did not provide new information relevant to this Supplement and will not be evaluated further.
I The comment did not resultin a change to the Supplement.
I Comment: FOR THE NRC TO HAVE USED DATA FOR SOUTHERN COMPANY'S PLANT I HATCH IS SICKENING - WHEN HATCH HAD THEIR DISASTROUS SPENT FUEL POOL I SPILL, DID ANYONE ADD THE EXTRA DOSES AND CONTAMINATION IN ? THIS IS THE I SAME HATCH WITH OVER 1200 WORKER CONTAMINATION EVENTS IN ONE YEAR.
I (CL-20/96)
I Response: The comment cannot be evaluatedbecause it did not provide specific information.
I The only place in the document where occupationaldose information from the Hatch plant was I included was in Table G-9, which summarized occupationaldose as a total at all light water I reactorsfor a given year. The comment did not provide new information relevant to this I Supplement and will not be evaluated further. The comment did not resultin a change to the I Supplement.
I Comment: Pg. G-21, Table G-15, Summary of Effluent Releases Comparison of Operating NUREG-0586 Supplement 1 0-56 November 2002
Appendix 0 Facilities and Decommissioning Facilities. The values associated with the maximum, minimum and average gaseous effluents for the Decommissioning Reactors do not add up. The Fission and Activation Gases for gaseous effluents are incorrectly all the same for the maximum, I minimum and average in each category (PWR & BWR). It appears that the minimum category for Decommissioning PWR's is Maine Yankee. If so, the minimum value for Fission and Activation Gasses for gaseous effluents should be "none detected." Making this correction appears to make the table add up assuming a PWR population of two. (CL-04/12)
Response: -The average, maximum, and minimum values for this radionuclidecategory are identicalbecause the licensees of only one reactorof each type reportedemissions. Others eitherdid not report or were reportedas below detection limits and therefore could not be included in the calculation. A footnote was added to Table G. 15 for clarification.
Comment: Pg. G-22, Table G-16, Summary of Public Doses from Operating and Decommissioning Facilities. This table is not well formatted and difficult to interpret. The table mixes the collective dose in person-rem with the individual dose in mrem. The years of concern are assorted. We suggest that the table be simplified and either further discussed in Section G.2.2. Text or eliminated. The following is Maine Yankee's data on individual public doses from Maine Yankee's effluents for 1998, 1999 & 2000. (chart followed). (CL-04/13)
Response: Table G-16 was deleted and general information was added to the text.
Comment: In order to ensure that the radiological aspects of this activity are assessed consistently, NEI recommends that standard dose modeling assumptions be documented directly through the Q&A process associated with the NRC guidance consolidation project.
(CL-05/2)
Response: Dose modeling assumptions are not within the scope of this Supplement.
Information related to dose modeling assumptions, that are currently in NUREG- 1727, will be documented with the NRC guidance consolidationsproject.- In addition, and to the extent possible, the results of NEI's quality and assuranceeffort will also be included in the consolidationproject. The comment did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comment did not result in a change to the Supplement.'
Comment: Table 4-1 provides estimates of cumulative occupational dose for decommissioning reactors (comparisons of the 1988 GElS to new estimates compiled for draft Supplement 1). -In order to reflect the conclusions of Section 4.3.8, it is recommended that a note be added to Table 4-1 to clarify that these estimates of cumulative occupational dose are generic and are not intended to be site-specific limits. (CL-06/1)
November 2002 0-57 NUREG-0586 Supplement 1
Appendix 0 I Response: While these are not site-specific limits, this document is providing an envelope that I licensees can use in the future to compare impacts from their decommissioningactivities. If the I licensee is within the values listed for cumulative occupationaldose in this Supplement then the I impact is expected to be SMALL. As stated in Section 1.5, licensees must make sure they are I within the envelope or must perform a site-specific analysis. The comment did not provide new I information relevant to this Supplement and will not be evaluated further. The comment did not I result in a change to the Supplement.
I Comment: After the meeting in Atlanta, we are increasingly concerned about the safety of the I workers that will be involved in decommissioning. Will a more specific analysis of worker I effects be dealt with in the final EIS or is there a separate report that will research health I impacts? Georgians for Clean Energy requests that all worker exposures that have occurred at I nuclear power plants that are currently being decommissioned be made available to the public I and listed in the final GELS. (CL-08/25)
I Response: NRC licensees, including permanentlyshutdown reactors,are requiredto provide I reports as specified in 10 CFR Part20, Subpart M. These reports are publicly available. The I potentialhealth impacts to workers are discussedin Section 4.3.8 and Appendix G of the I Supplement. A more specific analysis of worker health impacts will not be provided in I Section 4.3.8. The comment did not provide new information relevant to this Supplement and I will not be evaluatedfurther. The comment did not result in a change to the Supplement.
I Comment: Section G.1.1.4.1, Pg. G delete or revise fourth bullet. Conditions typically I encountered in exposures from normal facility operations result in external dose, rather than I internal dose. Internal deposition of particles can occur, but this is less common than external I dose. Also, clarify last bullet. (CL-09/37)
I Response: Occupationaldoses are typically from external exposure; however, environmental I exposures to members of the public would be a result of an internaldose largely from I radionuclideintake. Section G. 1.1:4.1 was revised and the last bullet referenced above has I been deleted.
I Comment: Section G 1.1.4.3, p G-8, lines 13 this somewhat explains selection of the I occupational nominal probability coefficient in Table G-4 for fatal cancers, but does not explain I selection of hereditary coefficient. (CL-09/38)
I Response: Section G. 1.1.4.3 was revised and provides a source for the hereditarycoefficient I used in Table G-4.
I Comment: Table G-6, p G-1 1 - the table per its title covers dose limits for an individual I member of the public under 10 CFR 20. The ALARA air emission dose constraint listed in the NUREG-0586 Supplement 1 0-58 November 2002
Appendix 0 table is not a 10 CFR 20 limit. (CL-09/39)
Response: Table G-6 was revised and a footnote added stating that the value is not a 10 CFR Part20 dose limit but is given to ensure consistency with air emission standardsfor Federal facilities in 40 CFR Part61.
Comment: Section G.2.1, Pg. G-13, lines 26 the conclusion in the first sentence of the third paragraph is misleading. The main reason that the occupational doses at reactors undergoing decommissioning are a small fraction of dose accumulated at operating facilities, as shown in Table G-9, -is that there are many more operating plants than decommissioning plants. I The average for decommissioning plants shown in the table is less than the operating plant, but I not only a small fraction. (CL-09/40)
Comment: Table G-12, Page G the two numbers listed for San Onofre should be explained. (CL-09/42)
Response: Table G-12 is revised. The estimate of Bequerel's has been correctedand the extraneouspersonnel exposure estimate was removed.
Comment: Table G-14 it appears strange that only 26-34 operating plants were listed as reporting dose from gaseous effluents each year, since all plants are required to report. Also, the selection of the years 1985-1987 appears strange for an update report. (CL-09/44)
Response: The information cited was taken from a pub/ished report,and is'limited to I information'conhtainedin that report. More recent information from operatingfacilities is also includedin Appendix G. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: Page 3-10, Section 3.1.3, Lines'34-37. -The supplement states'that "the amount of I liquid and'gaseous radioactive waste generated is'usually lower for decommissioning plants.- :I Must the plant's waste remain within the limits established during operations tobe bounded by I this GELS? (CL-16/18)
Response:- Liquid and gaseous waste releasesmust meet the requirementsin 10 CFR Part20, Appendix B, Table 2. The comment did not provide new information'relevantto this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
November 2002 0-59 NUREG-0586 Supplement 1
Appendix 0 I Comment: Section 4.3.8.2, Potential Radiological Impacts from Decommissioning Activities, I fails to adequately consider the potential for decommissioning activities to spread or hide I radiological contamination. The presumption is that accidents or mistakes will not take place, I when experience at decommissioning plants shows that they do. The report fails to draw from I this experience. For example, early in the decommissioning of one site and prior to complete I radiological survey, a trench was dug across an impacted area to lay an electrical cable to I power equipment no longer serviced through the plant. The trench was left open to the weather I for a few days, then backfilled with loose material and thus could permit rainwater to carry I contamination deeper and spread it further. Individually, such activities may not provide what I are termed significant doses, but they have the potential to add incremental to the dose of I future site occupants and overall risk and may violate ALARA principles. The potential I environmental impacts of such activities should be evaluated. Incidents have occurred in which I workers left the site with contaminated clothing and in which train car loads of class A waste I were permitted to languish for weeks on a siding in a residential community. Although radiation I levels in these instances were extremely low, the potential for greater exposures existed. Such I scenarios should be considered, worst case, in preparing the GELS. (CL-13/14)
I Response: Decommissioningexperience related to characterizationof radiological I contaminationand decontaminationwas obtainedfrom many of the permanently shutdown I reactors currentlyin decommissioning. This experience is summarized in Section 4.3.8 and I Appendix G of the Supplement. Potentialradiologicalaccidents for all permanently shutdown I plants were characterizedandpresented in Section 4.3.9 and Appendix / of the Supplement.
I The scenarios consideredin Appendix I are considered appropriatefor evaluating the I environmentalimpacts from decommissioning. Furthermore,accidentalreleases of radioactive I contaminationare investigatedon a site-specificbasis. Such investigationsfocus on the I potential andactual exposure of workers and the public. The comment did not provide new I information relevant to this Supplement and will not be evaluated further. The comment did not I result in a change to the Supplement.
I Comment: Page 4-28, Section 4.3.8.3. This discussion in this section indicates that public and I occupational dose comparisons were made with the facility's EIS for normal operations and with I the 1988 GElS. This statement appears to contradict earlier statements about the assessment I of impacts being based on NRC regulatory limits for worker protection. Please clarify how the I comparisons were made. (CL-16/64) 1 Response: The comparisons of public and occupationaldoses were made to identify whether I the envelope for radiologicalimpacts to workers and the public needs to be adjusted from the I 1988 GELS. The level of significance was determined using the regulatorylimits in 10 CFR Part 1 20, "Standardsfor ProtectionAgainst Radiation." The comment did not provide new information I relevant to this Supplement and will not be evaluated further. The comment did not result in a I change to the Supplement.
NUREG-0586 Supplement 1 0-60 November 2002
Appendix 0 Comment: Page 4-29, Section 4.3.8.3. Line,14 indicates that the data used in the evaluation.
are those presented in Appendix G. Appendix G uses units of collective dose equivalent; however, as also outlined in the appendix, the radiation protection standards are in units of annual individual dose. The Supplement should use consistent units and provide data on population densities for nuclear power plants. I Appendix G.2 (page G-19) provides the average public dose within a 50 miles radius of a facility. The Supplement should clarify if facilities which fall outside this analysis (e.g., have denser populations yielding more person-rem than indicated in the appendix) must complete a site-specific analysis. (CL-16/65)
Response: Appendix G provides a general discussion on radiationprotection to assist the readerin understandingthe basis for the analysis and conclusions in Chapter4. The information in Appendix G is abstractedfrom a variety of published documents making consistency in units difficult. The staff chose to report the units as given in the referenced document.
The discussion in 4.3.8.3, Evaluation, addressespublic dose and states that both the average individual dose and the collective doses attributableto decommissioning activities are not substantiallydifferent from those experiencedby the public during operationand are much, lower than from naturalbackground radiation.The NRC regulationsdo not establishcollective, dose limits to the population surroundinga nuclearplant but ratheraddresslimits to individual dose: The individualdose limits were establishedto assure that the radiologicalimpact to the public from the nuclearfacility would be SMALL. Even if the anticipatedcollective public dose attributableto a specific facility decommissioningexceeded the collective dose values given in Table G-13 of the Supplement no site-specific analysis would be required. A site specific assessment would not be requiredfor decommissioning activitiesas long as the highest dose to I an individualmember of the public from sources under the licensee's does not exceed the limit I in 10 CFR Part20 of 1 mSv/yr (0.1 remlyr) and effluent concentrationsdo not exceed the levels I specified in 10 CFR Part20,Appendix B, Table 2,-at the unrestrictedboundary. In addition, the I dose from externalsources in an unrestrictedarea should not exceed 0.02 mSv(0.002 rem) in any given hour or 0.5 mSv (0.05 rem) in 1 year:If these limits are not exceeded, the radiologicalimpacts, regardlessof the collective dose to the population within the 50 mile radius,are inconsequential. The comment did not provide new information related to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: Page 4-31, Section 4.3.8.4. While the overall worker health impact is SMALL, November 2002 0-61 NUREG-0586 Supplement 1
Appendix 0 I Appendix G shows data from some decommissioning facilities where worker exposure is higher I during decommissioning than during operations. The Supplement should clarify how these I higher exposure levels compare with the radiation protection standards. Also, this section I should clarify whether an analysis was done of the normal wastewater streams produced during I decommissioning that are contaminated with radiation. (CL-1 6/66) 1 Response: Annual collective doses at decommissioning facilities vary widely with time I depending on the nature of the activities taking place during the year and the number of I workers involved in those activities. Similar variationscan also occur at operating facilities I duringperiods of major maintenance. Although the annualaverage collective dose for I decommissioning facilities is generally lower over the long-term than during active operationsat I the same facility, the maximum collective dose during any given year may be comparableto, or I higher than, the annualdose during a typicalyear of operation. No individual workers at I decommissioning (or operating)facilities have exceeded the regulatorydose limit of 0.05 Sv/y I (5 rem/y) since the late 1980s.
I Decommissioning activitiesare typically planned to minimize generationof liquid waste, which I is ultimately solidified and managed with other solid radioactivewaste. Because the facility I cooling systems are shut down during decommissioning, these activities would not generate I large volumes of liquid effluents to which members of the public might be exposed.
I Nevertheless the licensee is required to submit an effluent release reportto the NRC on an I annualbasis that summarizes radioactivereleases over the previous 12 months. The I proceduresand results of the monitoringprograms are inspectedand reviewed by the NRC I staff to ensure requirementsare being met. The wastewaterstreams do contain measurable I amounts of radiologicalcontaminants,however they have consistently been within regulatory I limits. The comment did not provide new informationrelevant to this Supplement and will not be I evaluated further. The comment did not result in a change to the Supplement.
I Comment: On Page M-2 it says, under the glossary, under Background Radiation, that "the I typically quoted United States average individual exposure from background radiation is 360 1 mrem per year." It may be typically quoted, but it is a blatant LIE. For example, typical I background radiation in Georgia is 42 mrem year according to the state (which recently upped it I a notch probably due to the radioactive fallout on the state from nuclear power plants and the I Savannah River Nuclear Site on its borders.) (CL-20/103)
I Response: Background radiationfrom various sources differs depending on the location within I the United States. The value quoted in this document is an average for the United States, I including cosmic radiation,terrestrialsources, naturalradon, and artificialexposures (largely for I medicalpurposes). The value was taken from the National Council on RadiationProtectionand I Measurements (NCRP's)Report No. 94 issued December 30, 1987. The dose quoted for NUREG-0586 Supplement 1 0-62 Novembe r 2002
Appendix 0 Georgiaprobably did not include the component from radon, which is the largest contributor overall. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: On Page 4-29 the NUREG (Section 4.3.8.3) concludes that it is not necessary to update estimates for collective dose due to decommissioning activities. This is an important conclusion that is supported by the current range in collective dose that decommissioning plants have experienced. Any change to this conclusion needs to be well supported by actual data and needs to be thoroughly studied to identify all potential impacts. (CL-31/1 0)
Response:, The staff agrees with this comment. The comment did not provide new information I relevant to this Supplement and will not be evaluated further. The comment did not result in a I change to the Supplement.
Comment: Table 4-1 on page 4-30 is misleading. The totals given include 100 rem of transportation dose that is not tracked by the facility undergoing decommissioning. It also does I not include dose incurred during construction of a Spent Fuel Pool Island or in support of a dry I cask storage campaign. A footnote should be added explaining these differences. (CL-31111) I Response: Section 4.3.8 of the Supplement indicates that the estimates in the table do not represent dose estimates for the same activities. Some of the estimates include doses from transportationof radioactivematerial, while others do not. -Table 4-1 only provides a comparison of occupationaldose estimates. Section 4.3.17 provides information on transportationimpacts from decommissioning.
Comment: The Draft even says during licensing the applicants commit to implement ALARA programs. The combination of ICRP, NRC, NCRP, and ALARA standards is, and has been a I recipe for premeditated murder and/or illness, genetic damage and great suffering as it is.
(CL-20/8)
Comment: R.M. Sievert (after whom the unit the Sievert is named) pointed out that there was:
no level below which radiation did not cause damage; no threshold that must be exceeded for damage to occur, yet NRC says a threshold must be exceeded for effect to occur, I believe Sievert. The ICRP standard of 5 rem per year is based on a principle called risk/benefit that I allows a one in five thousand chance of contracting cancer. In other words, the death or cancer I risk is the workers and the publics', the benefits are the dollars flowing to the industry and the I NRC (from the industry in return for NRC services and licenses etc.). (CL-20/7)
Comment: The exposure allowed by regulation is, in fact, slow death, and furthermore, worker I doses can't always be trusted because of faulty measuring equipment, horror stories of workers I being told not to wear their dosimeters periodically, and so on. The dose received also has a I November 2002 0-63 NUREG-0586 Supplement 1
Appendix 0 I different effect on each person depending on age, sex, current and past health status and I many other factors, plus each organ is affected differently. (CL-20/55)
I Comment: Regarding Occupational Dose and nuclear power plant exposure data (Page. G 12, 1 etc.). The regulatory limits for exposure were not set based on medical reasons but were set in I order to enable the industry to operate - that is historic FACT because what people are being I exposed to is either not found in nature (i.e., it is man-made) or found in nature at far, far lower I levels. (CL-20/54)
I Comment: To add to these levels by deliberately ignoring the dangers of radiation exposure is I wantonly criminal. Those who do so will go down in history as villains of the worst sort: smug, I obtuse, shrivel-hearted, deceiving, opportunistic, self-serving, cowardly, corrupt people who I really ought to know better. (CL-33/4)
I Comment: Environmental and health risks from improper decommissioning are very high, I particularly to neighboring communities. (CL-45/2)
I Comment: Health problems in the community must be determined and taken into I consideration when decommissioning plans are being established since continued exposure to I radiation through routine decommissioning releases and the inadvertent release of hot particles I can jeopardize the health and safety of the public. (CL-50110)
I Comment: The direct gamma radiation coming off the plants to the public is the equivalent of a I continuous x-ray emanating from their midst. No x-ray is "negligible." (CL-20/94)
I Comment: That no one asked to be exposed to ANY dose of radiation, and most people in I surrounding communities don't even know they are being exposed, or if they know, they think I they are being protected because they think there is a safe level of radiation. (CL-20/98)
I Comment: There are no "acceptable levels" - the public does not accept any level of I radioactive contamination - plutonium, cobalt-60, Strontium-90, etc. or tritium, radioactive iodine I and so on and on - (CL-20/105)
I Comment: Most of us also realize that the immune systems of every living thing on this planet
- human systems included - are becoming intolerably stressed by mounting (and synergistically I interacting) levels of pollution of all sorts. (CL-3313)
I Comment: You are insuring the further deterioration of health for innocent civilians and this I planet. (CL-34/2)
NUREG-0586 Supplement 1 0-64 November 2002 I
Appendix 0 Comment: Underlying these failures of the agency's responsibility for the facilities and activities that it had sanctioned by granting an operating license and through its regulatory actions and inactions is the failure of the NRC - and of EPA - to set radiation protection standards that recognize the great varieties of adverse effects of low-level radiation on human I beings. (CL-52112)
Comment: But it is also increasingly important to incorporate into radiation protection standards low-dose effects. (CL-52/20)
Comment: One problem here is that the only non-stochastic effects considered in the GIS-GEIS are those related to above threshold doses which cause such things as cataracts or I other high dose morbidities. This is unacceptable. .There are many morbidities which are associated with low dose radiation which do not rise to the level of effects on cataracts, such as I the effect on the human immune system and many other non-cancer effects. This is missing from the generic statement. (AT-F/6)
Comment: Even the NRC admitted back in the late '70's that there was no safe level. I (CL-20199)
Response: The NRC's primarymission is to protect the public health and safety, and the I environment from the effects of radiationfrom nuclearreactors,materials,and waste facilities. A The NRC's regulatorylimits for radiologicalprotectionare set to protect workers and the public I from'the harmful health effects of radiationon humans. The limits are based on the ,
recommendations of standards-settingorganizations. Radiation standardsreflect extensive I scientificstudy by nationaland internationalorganizations(InternationalCommission on 'I RadiologicalProtection[ICRP],National Council on Radiation Protectionand Measurements
[NCRP], and the NationalAcademy of Sciences [NAS]) and are conservative to ensure that the I public and workers at nuclearpower plants are protected. The NRC radiationexposure ;I standardsare presentedin 10 CFR Part20, !Standardsfor ProtectionAgainst Radiation,"and I are based on the recommendationsin ICRP 26 and 30. The comments did not provide new I information relevant to this Supplement and will not be evaluated further. The comments did not result in a change to the Supplement. ,
Comment: In addition to onsite worker doses, decommissioning exposure calculations must capture and include doses incurred by workers involved in offsite reactor decommissioning activities i.e. shipping, decontamination, smelting, recycling etc., of all radioactive materials and I components. (CL-50/16)
November 2002 0-65 NUREG-0586 Supplement 1
Appendix 0 I Comment: The NRC must incorporate offsite contamination in all evaluations of environmental I impacts. (CL-25/8)
I Comment: I utterly oppose [that] NRC should incorporate offsite contamination into all I evaluations of environmental impacts. (CL-33/12)
I Comment: I ask that the NRC incorporate offsite contamination into all evaluations of I environmental impacts. (CL-26/9)
I Comment: The contamination of soil, land and property beyond the station boundary line must I be included in the decommissioning analysis and plan. Offsite migration of radioactive I materials has occurred through both deliberate and inadvertent removal of materials originally I contaminated onsite (tools, concrete construction blocks, etc.). For example, concrete I cinderblocks used to construct a shield wall at the Connecticut Yankee's Haddam Neck nuclear I power station were inappropriately distributed to affected communities as construction materials I for buildings including a children's daycare facility. We believe the Connecticut Yankee incident I is not an isolated case. The scope of the current definition does not provide for the I investigation, analysis and mitigation of radioactive materials, equipment and components I originating from a nuclear facility that have been deliberately or inadvertently released to I affected communities. (CL-48114)
I Comment: NRC ignores radiation offsite and permits utilities to ignore it in decommissioning I planning. NIRS calls on the NRC to incorporate offsite contamination into all evaluations of I environmental impacts. (CL-48/41)
I Comment: One does not want radioactive and chemical particulate matter getting offsite if I possible. (CL-20/34)
I Comment: I am opposed to the following proposal(s) in the EIS: NRC ignores radiation offsite.
I (CL-26/7)
I Comment: I am opposed to the following proposal(s) in the EIS: NRC permits utilities to I ignore it [radiation offsite] in decommissioning planning. (CL-26/8)
I Comment: I utterly oppose ignoring offsite radiation and permitting utilities to ignore it in I decommission planning. (CL-33/11)
I Comment: I am opposed to the following change to NUREG-0586: In Supplement 1 to the I Generic Environmental Impact Statement on Decommissioning: NRC ignores radiation offsite I and permits utilities to ignore it in decommissioning planning. NIRS calls on the NRC to NUREG-0586 Supplement 1 0-66 November 2002
Appendix 0 incorporate offsite contamination into all evaluations of environmental impacts. (CL-43/6) permitted to be Comment: The extent to which radioactive corntaminatio-n levels that are in the release of radioactive released frrom 'regulatory control for decommissioning 'would result materials routinely. (CL-38/5) which would Comment: I am opposed to NRC regulations pertaining to Decommissioning it in decorfimissioning allow offsite radiation to'be ignored, and permits utilities to ignore planning.' It is imperative to include offsite contamination into all aspects of decommissioning planning and evaluation of environmental impacts. (CL-44/7)
& listen to the concerns of Comment: I am hopeful that you will act in the interest of the public, nuclear'energy. Offsite all of the communities that will be affected by the'by-products of radiation is something that must not be ignored. (CL-49/2) radioactive contaminants Comment: There are right now already elevated levels of some (AT-N33) nearly 100 miles downstream of Plant Hatch and Plant Vogtle.
with the expectation that Response: All nuclearpower plants were reviewed and licensed the environment through there would be routine very low-level releasesof radioactivityto would be detectable offsite.
airborneand liquid releases from the facility and that these releases and meet the requirements Gaseous and liquid releases to the environment must be monitored may be presentand of 10 CFR Part20, Appendix B, Table 2. Therefore, contaminants and proven to be protective detectable offsite, however the release limits have been designed comments did not provide new of the health and safety of the public and environment. The The comments did information relevant to this Supplement and will not b6e 'evaluatedfurther.
not result in a change to the Supplement.
biological systems improves, it Comment: As techniques of research and analysis in complex and regulators that it is imperative to is becoming more apparent to thoughtful, careful scientists forms of living beings, not merely on include the impacts of low-level radiation exposures on all humans. (CL-52/19) should clarify the Comment: Page 4-27, Section 4.3.8, lines 17-21. The Supplement to radiation." Is this statement abýout the "relatively lower sensitivity of non-human species not known? Why were statement based on scientific studies or is theimpact to rion-humans defined as outside the scope of decommissioning's radiological impacts on ecological receptors the Supplement? (CL-16/63) 0-67 NUREG-0586 Supplement 1 November 2002
Appendix 0 I Response: The effects of ionizing radiationon non-human biota have been studied since at I least the 1940s. Radiologicalimpacts on ecologicalreceptors are not within the scope of this I Supplement because the NRC does not maintain radiationprotection guidelines for non-human I organismsbecause they are assumed to be protected by the radiationprotection standardsfor I humans. The validity of the assumption that radiationguidelines, which areprotective of the I public, would also provide adequateprotection to plants and animals has been upheld by I nationaland internationalbodies that have examined the issue, including the National Council I on Radiation Protectionand Measurement (NCRP Report No. 109, Effects of Ionizing Radiation I on Aquatic Organisms, 1991) and the InternationalAtomic EnergyAgency (IAEA Technical I Report Series No. 332, Effects of Ionizing Radiationon Plantsand Animals at Levels Implied by I Current Radiation Protection Standards, 1992). In both of those studies, it was emphasized I that non-human species may be adversely affected by such radiationlevels, but effects at the I population level are not detectable. The comments did not provide new information relevant to I this Supplement and will not be evaluated further. The comments did not result in a change to I the Supplement.
I Comment: Contamination means: that some thing/someone etc., has been brought into I contact with something that defiles or pollutes it etc., - go look the word up - NRC must stop I redefining words and lying about their meaning. (CL-20/106)
I Comment: The definition of CONTAMINATION is also a LIE, in that it states that something is I contaminated if its in excess of "acceptable levels." (CL-20/104)
I Response: The definition for contaminationused in the Supplement is "undesiredradioactive I material or residualradioactivitythatis deposited on the surface of or inside structures,areas, I objects or people in excess of acceptablelevels (e.g., for a release of a site or facility for I unrestricteduse)." This word is defined in Appendix M for clarification as used in this I Supplement and is generallyaccepted by radiationprotection experts. The comments did not I provide new informationrelevant to this Supplement and will not be evaluatedfurther. The I comments did not result in a change to the Supplement.
I Comment: The radioactive material releases is not released in stringently controlled I conditions, technical specifications are often violated, monitoring is only done at select locations I and frequently monitors don't work. (CL-20/91)
I Response: The NRC sets limits on radiologicaleffluents, requiresmonitoringof effluents and I foodstuffs to ensure those limits are met, and has set dose limits to regulate the release of I radioactive materialfrom nuclearpower facilities. The regulationsare intentionallyconservative I and provide adequateprotection for the public, including the most radiosensitivemembers of I the population. All reactorlicensees monitortheir effluent and calculate offsite doses caused by I radioactiveliquid and gaseous effluents. These calculationsare performed to demonstrate the NUREG-0586 Supplement 1 0-68 November 2002
Appendix 0 licensee's compliance with its technical specificationsand NRC regulations. Requirements for redundancy in monitoringas well as the monitoring of variouspathways that could result in the release of radiationto the environment ensure that unmonitoredand unplannedreleasesare avoided. The licensee's Offsite Dose Calculation Manual (ODCM)provides for collection and analysis of a variety of samples such as soil, water, plants, and animals. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: NRC ignores radiation exposures to children and other vulnerable members of the population and creates a fictitious highest exposed "critical group" based on unsubstantiated assumptions. (CL-48/40)
Comment: I am very concerned that children, who are much more susceptible to the effects of radiation, may not be being looked at in the Environmental Impact Statement. This is a very serious issue, & if left unaddressed, would not only be morally wrong, but could lead to a horrible name in history for the NRC, & possibly legal action. (CL-4911)
Comment: I utterly oppose ignoring radiation exposures to children and other vulnerable members of the population and creating a fictitious highest exposed "critical group" based on unsubstantiated assumptions. (CL-33/10)
Comment: All decommissioning activities need to consider the impacts of radiation exposure to workers'and the public. Radiation exposures to children and other vulnerable members of the population should be separately and realistically addressed with all pathways' to exposure closely examined. Assumptions about off-site'exposure should be substantiated with full peer-review from neutral parties, i.e. not employees of the nuclear utilities. 'The risk to public health cannot be minimized or discounted.- (CL-4012) :
Comment: Affected populations are composed'of many individuals who are not close to being that "standard man" in wihom the NRC places so much faith. (CL-52/13)
Comment: I am opposed to the following change to NUREG-0586: In Supplement 1 to the Generic Environmental Impact Statement on Dec6mimissio-ning: NRC ignores radiation exposures to children and other vulnerable members of the population and creates a fictitious highest exposed "critical group" based on unsubstantiated assumptions. (CL-4315)
Comment: Using an adult male as the average member of the critical population for dose calculations in site r'elease criteria does not establish effective cleanup standards. The adult male assumptions address workers during'reactor'operation; however"when reactor sites are released for unrestricted use the "average member" of the critical population requires the inclusion of children since they bear the greatest bu-rden of the effects of ionizing radiation as' November 2002 0-69 NUREG-0586 Supplement 1
Appendix 0 I described in the Biological Effects of Ionizing Radiation (BEIR) V report. (CL-50/17)
Response: The NRC's primarymission is to protect the public health andsafety, and the I environment from the effects of radiationfrom nuclearreactors, materials,and waste facilities.
I The NRC's regulatorylimits for radiologicalprotection are set to protect workers and the public I from the harmful health effects of radiationon humans. The limits are based on the I recommendationsof standards-settingorganizations. Radiation standardsreflect extensive I scientific study by nationaland internationalorganizations(the InternationalCommission on I RadiologicalProtection[ICRP], the National Council on Radiation Protectionand I Measurements[NCRP], and the NationalAcademy of Sciences [NAS]) and are conservative to I ensure that the public and workers at nuclearpower plants are protected. The NRC radiation I exposure standardsare presentedin 10 CFR Part20, "Standardsfor ProtectionAgainst I Radiation,"and are based on the recommendations in ICRP 26 and 30. The assumptions used*
I for the criticalgroup are not fictitious or unsubstantiated. The "criticalgroup" means the group I of individualsreasonablyexpected to receive the highest exposure to residualradioactivity I within the assumptions of a particularscenario. The average dose to a member of the critical I group is representedby the average of the doses for all members of the critical group, which in I turn is assumed to representthe most likely exposure situation. Forexample, when I consideringwhether it is appropriateto "release"a building (allowpeople to work in the building I without restrictions)that has been decontaminated,the criticalgroup would be the group of I regularemployees that would work in the building. If radiationin the soil is the concern, then I the scenario used to represent the maximally exposed individual is that of a resident farmer.
I The assumptions used for this scenario are "prudentlyconservative" and tend to overestimate I the potential doses. The added sensitivity of certain members of the population, such as I pregnant women, infants, and children, are accountedfor in the analysis. However, the most I sensitive member may not always be the member of the population that receives the highest I dose. This is especially true if the most sensitive member (for example, an infant) does not I participatein specific activities that may provide the greatestdose or if he/she does not eat I specific foods that cause the greatestdose. These comments did not provide new information I relevant to this Supplement and will not be evaluated further. The comments did not result in a I change to the Supplement.
I Comment: ALARA is not a sufficient basis for judging proper methods. (CL-10/11)
I Comment: NRC ignores radiation dangers after decommissioning is done and utility is relieved I of liability. (CL-48/39)
I Response: The Commission has establisheda dose of 0.25 mSv (25mrem) peryear total I effective dose equivalent to an averagemember of the criticalgroup as an acceptable criterion I for release of any site for unrestricteduse. The licensee will be requiredto demonstrate that I the site can meet this criterionbefore the license will be terminated for unrestricteduse. In NUREG-0586 Supplement 1 0-70 November 2002
Appendix 0 addition to the dose criteria,the regulationsstate that the licensee must show that residual radioactivityleft on the site have been reduced to levels that are as low as is reasonably achievable (ALARA). The concept of ALARA means that doses must be reduced to the lowest possible level considering economic and societalfactors. -The comments did not provide new information relevant to this Supplement and will not be evaluated further. The comments did not result in a change to the Supplement.
Comment: All sites should have audible (sirens) alarms that are triggered during decommissioning, and after decommissioning, when monitors exceed the EPA levels EPA allows, but reduced below what EPA allows to give an advance warning. Such audible alarm systems are absolutely vital also during the time radioactive spent fuel is still on the site, these I alarms should be at various locations onsite, including next to the spent fuel pool and one above it, and next to an ISFSI/cask area and suspended on a wire or pole above it. The alarms should be audible miles of site via relay loudspeakers. (CL-20/89)
Response: Requirements for emergency response at nuclearfacilities are provided in 10 CFR Part50 and theirapplicationto decommissioning facilities is stated. This Supplement does not (1) establish orrevise regulations,(2)impose,requirements,or (3) provide relief from require ments. The comment did not provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.
Comment: Clear methodologies should be established for the clean up of transuranics and hot particles. Yankee Rowe failed to include transuranic measurements in its LTP and currentlfy Connecticut Yankee intends to avoid doing direct alpha measurements (and beta measurements) through less expensive surrogate measurements of easier-to-detect radionuclides...Surrogate measurements must not be allowed at sites where consistent ratios of radionuclides do not exist. (CL-50/20) ,
Response: The purpose of this Supplement does not include establishingmethodologies for decommissioning or measurement of radionuclides. The information that should be presented in the LTP is not included as part of this GELS. The comment did not provide new information relevant to thisSupplementand will not be evaluatedfurther. The comment did not result in a change to the Supplement.
Comment:. DOESN'T NRC UNDERSTAND THAT ONE CANNOT DECONTAMINATE.
SOMETHING RADIOACTIVELY CONTAMINATED INTHE TRADITIONALSENSE, UNLIKE ,
WITH A CHEMICAL OR OTHER CONTAMINANT, WHATEVER IS DONE TO SOMETHING RADIOACTIVE DOES NOT CHANGE THE CHARACTER OF THE RADIATION, IT CONTINUES TO EMIT'ITS DEADLY ALPHA, BETA, GAMMA, NEUTRON . ET. RADIATION, I THROUGH THE FULL RADIOACTIVE HAZARDOUS LIFE. (CL-20170) -
November 2002 0-71 NUREG-0586 Supplement 1
Appendix 0 I Response: The definition of decontaminationis the removal andappropriatedisposal of I radioactivematerials to ALARA levels. The NRC has prescribedspecific radiologicalcriteria for I license termination. Radioactive materialsremoved during decontaminationare appropriately I disposed of just as any other chemical material would be. SubpartK of 10 CFR Part20 1 provides the requirements for the disposalof licensed material,includinglow-level waste. The I comment did not provide new informationrelevant to this Supplement and will not be evaluated I further. The comment did not result in a change to the Supplement.
I Comment: And to ignore radiation concerns to the unsuspecting public health is criminal. It is I outrageous to allow the reactors to be liability-free. (CL-32/3)
I Response: NRC's actions do not in any way eliminate the liabilityof licensees of nuclearpower I reactors. The comment did not provide new information relevant to this Supplement and will I not be evaluatedfurther. The comment did not result in a change to the Supplement.
I Comment: An EIS must also consider the effects of the synergies between and among I ionizing radiation and the multitude of hazardous materials also released into the environment.
I (CL-52/21)
I Response: The levels of radiationand amounts of radioactivematerialthat are releasedoffsite I as consideredin this document, are so low that synergies between radiationand hazardous I materialsare not an issue. This document does not look at the synergies between ionizing I radiationand hazardousmaterials releasedinto the environment. At the levels of radioactive I releases from decommissioningplants there has been no documented cases of harmful I synergistic interactionswith hazardous waste that could pose a public health and safety I concern. The comment did not provide new informationrelevant to this Supplement and will not I be evaluated further. The comment did not result in a change to the Supplement.
I Comment: I do not think it's outside of the scope of this particular document to have some I regulations about the speed, let's say, of how the total amount of radiation on a given site was I reduced. I think that would be perfectly within the scope of this document. (SF-C/7)
I Response: The mission of the NRC includes ensuring that decommissioning of all nuclear I reactorfacilities will be accoi-plishedin a safe and timely manner. NRC regulationscurrently I require that all decommissioning activitiesbe completed within 60 years after a nuclearpower I plant permanently ceases operations, unless exemptions are grantedon a case-by-case basis.
I The Supplement does not (1)-establishor revise regulations, (2)impose requirements, (3) 1 provide relieffrorn requirements,or (4) provide guidance on the decommissioningprocess. The I comment did not provide new information relevant to this Supplement and will not be evaluated I further. The comment did not result in a change to the Supplement.
NUREG-0586 Supplement 1 0-72 November 2002
Appendix 0 Comment: -The potential threat of a release'along the shoreline or into the lake of radioactive I material during decommissioning or storage of spent fuel requires special consideration. I (CL-i 1/3)
Response: The licensee is allowed to releasegaseous and liquid effluents to the environment, I but the releases must be monitoredand meet the requirementsof 10 CFR Part20, Appendix B, Table 2; therefore, contaminants may be present and detectable offsite. However, the release limits have been designed and proven to be protective of the health and safety of the public and I environment. Although long-term storage of spent fuel is not within the scope of the Supplement, as describedin Section 1.3, "Scope of This Supplement," NRC is committed to ensuring that both spent fuel and low-level wastes are managed to prevent detrimentalhealth impacts to the public. The NRC has stated in its regulationsthat "The Commission has made a I generic determinationthat, if necessary,spent fuel generatedin any reactorcan be stored safely and without significant environmentalimpact of at least 30 years beyond the licensed life :1 for operation (which may include the term of renewed license) of that reactorat its spent fuel storage basin or at either onsite or offsite independent fuel-storage installations." Further,the I Commission believes there is reasonableassurancethat at least one mined geological repositorywill be available in the first quarterof the 21st century, and sufficient repository capacitywill be available within 30 years beyond the licensed life for operation of any reactorto I dispose of the commercial high-level waste and spent fuel originatingin such a reactor and generatedup to that time. The comment did not provide new information relevant to this-Supplement and will not be evaluatedfurther. The comment did not result in a change to the Supplement.
Comment: Third, the Draft GElS does not explain at what point in time radioactive decay of the I material will make it sufficiently safe to proceed with any further dismantling. NRC should shorten the acceptable time period for SAFSTOR and link it to the timeframe that would make I1 the material safer. NRC should encourage licensees to go forward with dismantling the facility I under DECON as soon as appropriate, even if they start with placing the facility in SAFSTOR. 1 (CL-11/11) I Response: NRC regulations currently requirethat all decommissioning activities be completed I within 60 years aftera nuclearpower plant permanently ceases operations,unless exemptions I are grantedon a case-by-case basis. The purpose of the Supplement is not to discuss acceptable time periods for decommissioning activities or provide or suggest to licensees when I they should undergo decommissioningactivities---The Supplement describes the potential __ I environmentalimpacts from decommissioningactivities and provides an envelope of the, impacts that the licensee can compare to priorto undertaking a decommissioning activity. The I purpose of the Supplement is describedin Section 1.1, "Purposeand Need for This Supplement." The comment did not provide new information relevant to this Supplement and I will not be evaluatedfurther. The comment did not result in a change to theSupplement.
November 2002 0-73 NUREG-0586 Supplement 1
Appendix 0 I Comment: The area being worked in should be covered to contain dust if it means covering I the whole site with a tent with an adhesive inner surface to capture particulates. (CL-20/33)
I Response: The use of enclosures (such as plastic "tents")during decommissioning to contain I airbornecontaminationis a common practice. However, the enclosures are limited in size to I the area that is being worked on in orderto contain contaminationand not allow it to drift to I areas that are not contaminated. Covering the whole site with a tent would not be an I appropriateor realisticallyfeasible method of containing contamination. In addition, the I specification of methods to use during decommissioning is not within the scope of this I Supplement. The comment did not provide new information relevant to this Supplement and I will not be evaluated further. The comment did not result in a change to the Supplement.
I Comment: For the Draft to take the attitude of "well, the doses at plants being I decommissioned are generally only a small fraction of doses at operating plants," p. G 13 is no I comfort, and all the charts show, concerning Occupational doses (P. G 14 and on), is I thousands upon thousands of contaminated workers. (CL-20/56)
I Response: The connection between occupationaldoses and contaminatedworkers is I incorrect. Although some occupationaldose is associatedwith contamination,most is from I direct radiation(radioactivesources in piping or other components, including activation I products). The NRC's regulatorylimits for radiologicalprotection are set to protect workers and I the public from the harmful health effects of radiationon humans. The limits are based on the I recommendations of standards-settingorganizations. Radiationstandardsreflect extensive I scientific study by nationaland internationalorganizations(the InternationalCommission on I RadiologicalProtection[ICRP],the NationalCouncil on Radiation'Protectionand I Measurements [NCRP], and the NationalAcademy of Sciences [NAS]) and are conservative to I ensure that the public and workers at nuclearpower plants are protected. The NRC radiation I exposure standardsare presentedin 10 CFR Part20, "Standardsfor ProtectionAgainst I Radiation,"and are based on the recommendationsin ICRP 26 and 30. The comment did not I provide new information relevant to this Supplement and will not be evaluated further. The I comment did not result in a change to the Supplement.
I Comment: "Dose to members of the public" Pg. G-19, and following pages, the doses to the I public are listed in the usual deceptive and inaccurate manner. (CL-20/90)
I Response: The comment cannot be evaluated because it did not provide specific information.
I The comment did not provide new information relevant to this Supplement and will not be I evaluatedfurther. The comment did not result in a change to the Supplement.
I Comment: WHEN YOU CALCULATED THE RADIO-IODINES, DID YOU ADD IN THE HUGE I RADIO-IODINE RELEASE OFF PLANT FARLEY THAT WENT OVER GEORGIA? (CL-20/97)
NUREG-0586 Supplement 1 0-74 November 2002