ML19311C732

Public Watchdogs - NRC 2.206 Petition Exhibits 1-38 - Part 32

ML19311C732
Person / Time
Site:	San Onofre
Issue date:	09/23/2014
From:	Public Watchdogs
To:	Division of Decommissioning, Uranium Recovery and Waste Programs
Cruz Z
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Appendix 0 I submitted on July 7, 2000: Concrete from contaminated structures will be remediated to a level I meeting the radiological criteria for unrestricted release of the site. After completion of final I status surveys and absent any findings during NRC inspections, concrete building debris from I decontaminated structures may be used as backfill and placed into the remaining subsurface I building foundations. (CL-30/4)

I Comment: The burial of radioactively contaminated material as a means of site remediation is I unacceptable for property that is to be released for unrestricted use. Rubblization (the burial of I contaminated rubble) must not be permitted under any circumstances. The permission to build I nuclear reactors hinged upon the utilities' commitments to regulators and the community to I restore the site to "green fields." Rubblization is a blatant default on cleanup commitments, is a I gross injustice to reactor communities and is a regulatory cave-in to utilities' desires and I financial needs. In response to rubblization CAN also incorporates by reference Contention's 1 5.2 and 5.3 submitted by the organizations to the Commission on March 12, 2001 regarding I Haddam Neck Reactor's License Termination Plan (Docket No. 50-213-OLA). (CL-50/21)

I Comment: "Rubblization", to me reflects a sense that NRC is looking for ways to make it I easier to finish the decommissioning process rather than thinking about ways to make it safer I or more environmentally sound. And that concerns me. It seems to be driven by how we can I facilitate the process, making it happen more quickly or with less cost as opposed to I considering the safety issues. All of those issues relate to doing it more quickly and less costly.

I (CH-N11)

I Comment: The fact that the Staff and the Commission have even considered rubblization I shows an utter disregard for the health and welfare and safety of the public and the ecosystem I upon which life depends. (CL-20/20)

I Comment: I oppose the concept of rubblization as it is very dangerous. (CL-29/2)

I Comment: There should be no allowance for the industry to hurriedly raze structures, sweep I the radioactive mess under a porous and permeable carpet (or disperse the remains and I cleanup materials in many unregulated forms far from the reactor site), cut corners and add I risks and contamination to an already precarious cleanup operation. The public must be I protected. (CL-47/9)

I Response: The NRC staff has decided to retain the discussion of Rubblization in the Final I Supplement. Rubblization (the process of onsite disposalof slightly contaminatedmaterialin a I manner to meet the site-release criteriaof 10 CFR Part20, Subpart E) is considereda viable NUREG-0586 Supplement 1 0-164 November 2002

Appendix 0 decommissioningprocess that is consistent with the requirements of the LTP and is not I consideredlow-level waste under 10 CFR Part61. Thecomments did not provide new information relevant to this Supplement and will not be evaluated further. The comments did 1 not result in a change to the Supplement.

Comment: Rubblization (p. 4-14), the breaking of contaminated concrete structures into gravels and blocks cannot be considered an option where: A. the leachate plume could contaminate'potable water, B. the leachate plume could contaminate water used for food production such as farming, fishing, seafood harvest, or dairy, C. the leachate plume could contaminate closed bodies of water such as cooling canals or cooling ponds, or D. airborne particles could contaminate food crops, fishing waters, seafood harvesting waters, or dairy areas. All contaminated building materials must be removed from the nuclear plant site. (CL- I 14/4),

Comment: We concur with the GAO findings as reported in GAO-02-48 "NRC's Assurances of Decommissioning Funding During Utility Restructuring Could be Improved" dated December 2001. GAO reported the following conclusions: 'Water intrusion is also a major concern for, rubblized or entombed sites, and the fact that most nuclear power plants are situated in shallow water table' or flood plan locations may limit the viability of these options." (CL-48134)

Comment: Essentially, the agency and industry are proposing that a so-called "low-level" radioactive waste dump can now be grandfathered on a reactor site without a formal permitting and licensing hearing process. The decommissioning utilities will provide an analysis that can "assure"that no ground water movement will occur through the radioactive burial site providing a potential transport mechanism and potential radioactive exposure to the public and environment. The utilities are to provide a "dose model" to "assure" the affected communities that the radioactive site will pose no health risks to present and future public health and the environment. These "assurances" cannot be bona fide by generic treatment and therefore require the availability of site-specific proceedings. (CL-48130) 1 Response: Rubblization (the process of onsite disposalof slightly contaminatedmaterialin a manner to meet the site-releasecriteriaof 10 CFR Part20, Subpart E) would require a site specific analysis during the LTP review. Such a site-specific review would consider the potential I for groundwatercontamination. The comments did not provide new information relevant to this I Supplement and will not be evaluated further. The comments did not result in a change to the I Supplement.

Comment: The Supplement improperly addresses rubblization by stating it will require a site specific analysis at the time the license termination plan is submitted. Rubblization should be addressed generically as a part of the decommissioning process. The NRC should continue to I November 2002 0-165 NUREG-0586 Supplement I

Appendix 0 I maintain that to the extent that 10 CFR Part 20, Subpart E dose performance criteria are met I and that decommissioning has been performed using the ALARA principle, rubblization has a I SMALL environmental impact. (CL-31/4)

I Comment: Some of my concerns about NUREG-0586 include: the generic approval of I rubblization of reactor buildings and leaving them on site. (CL-38/3)

I Comment: I oppose rubblization but support its designation as site-specific. (CL-2414)

I Response: Both site-specific factors and the licensee's preparationof the demolished I demolition debris prior to onsite 'disposal can significantly affect the dose assessment I calculationsthat are necessary to demonstrate compliance with the licensee termination I criteria. As such, a generic analysis cannot be made that would envelop rubblization. The I comments did not provide new information relevant to this Supplement and will not be I evaluated further. The comments did not result in a change to the Supplement.

I Comment: Now, with Supplement 1 to NUREG-0586, the NRC would appear to be paving the I way for the very rubblization and possible release into the environment of slightly contaminated I material that the AEP rep said could not happen. The vehicle to allow this (rubblization) would I appear to be the declaration of more decommissioning issues "Generic" rather than "Site I Specific," thus preempting the right of local residents to raise concerns during the License I Termination Plan review. (CL-38/1)

I Comment: NRC's proposal to allow "rubblization" (defined as: "the demolition of onsite I concrete structures. Rubblizing these structures could result in material ranging from gravels to I large concrete blocks, or a mixture of both.") of concrete structures at the reactor site to take I place without opportunity for public intervention until after the action is completed is outrageous.

I (CL-47/14)

I Comment: NRC allows "rubblization" (crumbling the concrete reactor building) of nuclear I reactors, without opportunity for public intervention until the action is completed. (CL-48/36)

I Comment: We adamantly disagree with the possibility of rubblization as a method of I decommissioning. Chopping up a plant and storing it on site not only sounds ridiculous, but I also is grossly negligent of the fact that there are facilities designed, built and licensed to I handle radioactive materials. Plant owners never told communities near nuclear plants that I they were also accepting a permanent nuclear waste dump. Rubblization is an egregious I assault on the public participation process and a devious example of corporations casting aside I those communities that supported them over the years. (AT-N37)

NUREG-0586 Supplement 1 0-166 November 2002

Appendix 0 Comment:, I am opposed to the following proposal(s) in the EIS: NRC allows "rubblization" (crumbling the concrete reactor building) of nuclear reactors, without opportunity for public intervention until the action is completed. (CL-26/2)

Comment: '[Georgians for Clean Energy] recognizes that nuclear plant owners and the NRC never told communities near nuclear plants that they were also accepting a permanent nuclear waste dump. Rubblization is an egregious assault on the public participation process and a devious example of corporations casting aside those communities that supported them over the years. (CL-08/22).

Comment: I am opposed to the following change to NUREG-0586: In Supplement 1 to the Generic Environmental Impact Statement on'Decommissioning: NRC allows rubblization (crumbling the concrete reactor building) of nuclear reactors, without opportunity for public intervention until the action is completed. (CL-43/1)

Comment: I am opposed to NRC regulations pertaining to Decommissioning which would allow rubblization (crumbling the concrete reactor building) of nuclear reactors, without opportunity for public intervention until the action is completed. (CL-44/5)

Comment: Rubblization poses some specific risks to the surrounding communities and the site workers, as the rubblized material could contaminate via air, soil, and water pathways. Thus,-

Public Citizen insists that it is only appropriate that the affected communities surrounding the reactor site be given opportunities to review rubblizing plans and procedures, and that this issue I be addressed orn a site-specific basis. (CL-47/15)

Comment: However, the rubblization process must account for the permeation of porous concrete structures (containment dome, basemat, and walls) with radioactivity much deeper than surface contamination that would be sand blasted during a decontamination process. I Activated concrete would be rubblized and woUld thus constitute' so-called "low-level" 1 radioactive waste. Long-lasting radioactive elements such as cesium-135 and strontium-90 are I present with many other fission products and radioisotopes in the concrete and should not be ignored or defined away. -No data are provided in this Supplement to justify rubblization and.

onsite or offsite disposition. Thus, local communities have every right to participate legally (in adjudicatory proceedings) and be provided with information - full disclosure of such planning.

(CL-48/29)

Comment:_-I utterly oppose "rubblization" with no opportunities for meaningful public intervention ahead of time. '(CL-33!7)

Comment: It is extremely important for the NRC to level with the public about the potential hazards of the concrete debris and related rubble from the dismantled plants. (CL-51/7) I November 2002 0-167 NUREG-0586 Supplement 1

Appendix 0 I Response: Rubblization (the process of onsite disposalof slightly contaminatedmaterialin a I manner to meet the site release criteriaof 10 CFR Part20, Subpart E) is considereda site I specific issue and would be addressedduring the LTP review. Since the LTP is approvedby I amendment to the facility license, the public will have the opportunity to participatein the I review. The comments did not provide new informationrelevant to this Supplement and will not I be evaluated further. The comments did not result in a change to the Supplement.

I Comment: If rubblization were technologically achievable, where on a plant site could the I wastes be stored in perpetuity? Would that be above grade or below? (CL-51/14)

I Response: An explanation of rubblizationand the location of the demolition debris is given in I Section 1.3. The comment did not provide new informationrelevant to this Supplement and will I not be evaluated further. The comment did not resultin a change to the Supplement.

I Comment: The question goes to the issue of the rubblization and the language in the GElS I that puts part of it out of scope and part of it is discussed as being covered under the generic I environmental impact statement supporting the license termination rule. The heart of the I comment and question really gets at the issue that from our perspective is not yet covered in I that license termination rule and the assumptions embedded in that GELS. And that has to do I with the scenario of what happens and what are the assessments for the radiological materials I post license termination., The rubblization is one angle that begs that question...The question is I do you need to assume some refurbishment scenario post-license termination?...The question I the industry asks is how do we address that? Do we come up with some scenario and I refurbishment that would account for that? What would that scenario look like? We need that I information so that we can do those assessments ....Again, the issue is post-license termination.

I How do you assess a potential risk to a member of the public from that material?...The question I is, is there some unique pathway that needs to be assessed for this material, such as an I intruder pathway?...Our understanding was this GElS would sort of beef that up because of this I new idea; however, it appears that was sort of left out of scope and appropriately maybe so.

I Perhaps that is in the scope of the license termination rule. (AT-E/l)

I Response: The License Termination Rule does not contemplate post-license termination I assessments for radiologicalhazards. The staff finds that the site-release criteria are I sufficiently conservative to protectpublic health and safety and the environment for any I reasonablepost-license termination use of the site. The expectation is that any potential I pathway would be addressedduring the site-specific review of rubblizationthat occurs during I the LTP review. 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.

NUREG-0586 Supplement 1 0-168 November 2002

Appendix 0 Comment: We concur with the GAO findings as reported in GAO-02-48 "NRC's Assurances of Decommissioning Funding During Utility Restructuring Could be Improved" dated December 2001. GAO reported the following conclusions: "rubblization represents a departure from NRC's past licensing practice, which emphasized shipping low-level radioactive wastes from decommissioning sites to disposal sites. Although NRC has estimated that rubblization could save a licensee from $10 million to $16 million in waste disposal costs during decommissioning, its Advisory Committee on Nuclear Waste has concluded that technical factors,-such as the depth of radioactive contamination and the volume of rubblized waste, could significantly diminish the potential cost savings. The Advisory Committee also believes that evaluating radioactive material content and doses from rubblization, both at the site and in local groundwater, may prove difficult and expensive." (CL-48/31)

Response: Rubblization requires a site-specificanalysis, as noted in Section 1.3 of the Supplement. ýThe staff acknowledges that technicalfactors related to the site and the licensee's I actions could significantly influence the cost savings. Additionally, the staff acknowledges that I it may be difficult to demonstrate that the materialcan be safely disposed of in the below ground structureson site.I These and other factors have led the staff to conclude that the radiologicaleffects of rubblization would necessarilyhave to be considered on a site-specific basis. 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: I find it hard to believe that the massive structures of concrete and steel reinforcing I bars found in a typical commercial power plant could be rubblized. The complexity and size of I the task seem overwhelming. What technologies could be used to dismantle the base mat of the Callaway reactor building, for example: 13,400 tons of concrete plus 1,470 tons of intertwined #18 reinforcing steel bars? Do most 1,000-megawatt pressurized water reactor containment building have similar base mats? (CL-51/12)

Response: The'staff believes that if a licensee chose to rubblize a portion of their facility and, I dispose of the slightly contaminatedrubble onsite they would only rubblize above-ground structures. Rubblizing a base mat for a reactorwould not be necessary or required. The deconstruction industry is very effective in rubblizingreinforced concrete and it is done quite frequently. San Onofre recently rubblized severaluncontaminatedstructures onsite, separating the reinforcing 'steelfrom the concrete. The effort was accomplished without incident. The 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.

November 2002 0-169 NUREG-0586 Supplement 1

Appendix 0 1 0.2.4 Safety of Decommissioning 0.2.4.1 Issues Related to Terrorist Events I Comment: Getting onto a brief comment on security, as many things are being reviewed in I light of September 11, the decommissioning of nuclear reactors should be no exception. From I what I've heard today, it sounds like there will be some sort of analysis of security issues and I I hope that's directly relating to this decommissioning document. As we know, the draft EIS is I grossly deficient in ensuring that security measures are taken to protect our homeland security I from threats of sabotage at a nuclear plant. Georgians for Clean Energy request that a I thorough amended review of necessary security measures be compiled by the NRC and added I to the supplement. (AT-N12) 1 Comment: If there is the possibility of release during decommissioning, then that should be I something that should be accounted for especially in light of concerns of attack. (CH-A19)

I Comment: The terrorist attacks of September 11, 2001 have raised many issues concerning I the currently, inadequate security of our nation's nuclear reactors. Because decommissioning I creates opportunities for release 6f spent fuel and structures contaminated with radioactive I material, the Final GElS should revisit the appropriate security needed during I decommissioning. (CL-11/12)

I Comment: While EPA did not identify security issues during the GElS scoping process, the I events of Sept. 11 have brought them to the forefront of public concern. EPA suggests that I NRC include in the final Supplement agene'ral discussion on how the Commission is I addressing security from terrorism at plants undergoing decommissioning. (CL-16/9)

I Comment: I do want to talk about the physical protections and the existing regulations under I 10 CFR 73.55. I guess I could state this as more or less of a question. For example, what I measures will the Commission employ during decommissioning to protect against radiological I sabotage? (AT-F/2)

I Comment: Even 10 CFR 73.55 falls short in our estimation in the preparations for such a I scenario. 73.55 considers only primary physical security barriers for vehicles, for isolation I zones, for access to the plant, for detection of intrusion and what not. For example, it mentions I that there [would] be bullet resistant walls, floors and doors in'reactor control rooms. Well I plainly this 10 CFR 73.55 needs to be updated because this is woefully inadequate to consider I anything which is now possible after September the 11h. (AT-F/4)

NUREG-0586 Supplement 1 0-170 November 2002

Appendix 0 Comment: Security must be upgraded, not downgraded. (CL-20/74)

Comment: EVERY SITE, OPERATING OR NOT OPERATING, IS A PRIME TERRORIST TARGET AS I HAVE SAID FOR DECADES. (CL-20179)

Comment: It ought to be equally obvious that a serious accident or terrorist act in this industry I could be catastrophic, leaving immense fatalities, injuries, future cancer victims and vast areas I uninhabitable for years. (CL-42/3) I Comment: 'A reduced security force at a decommissioned nuclear plant increases the threat of I terrorism. A thorough amended review of necessary security measures during decommission- I ing of nuclear facilities [due to 9/11] must be compiled by the NRC and added to the supplement. (CL-5312)

Comment: The danger to the public from a terrorist act is a function of the total level of radiation that exists on one given site. We cannot do'anything about the total level of radiation in a global sense, but through government regulations we could do something about the amount of radioactive material that is stored at any orne location. (SF-C/6)

Comment: But I think that there is an overall concern,' which I know that this doesn't address, and that is the vulnerability of nuclear power plants to various acts of terrorists. And I don't think it should be ignored, and I think that we-should be very concerned about it. (SF-C13) I Comment: Before September 11th, I probably felt that the SAFSTOR approach was one of the best things, to let them sit for 10, 20 years, and let the radioactive level decrease'significantly before you try to disperse it. I no longer think that. And yet I just heard, well, the licensees have 60 years to decide, and they can do anything they want. And I don't think that's a dangerI that the pUblic should put up with. (SF-C/4)

Response: NRC and other Federalagencies have heightened vigilance andimplemented initiatives"toevaluate and respond to possible'th'reatsp6sed by terrorists,including the'use of aircraftagainstcommercial nuclearpower plants. Malevolent acts remain'speculative and.

beyond the scope of a NEPA review. NRC routinely assesses threats and other information provided to them by other Federalagencies,and souicesl ý The NRC also ensures that licensees meet appropriatese6urity levels. The NRC will continue to focus on prevention of terroristacts I forall nuclearfacilities and will not focus 6n sitesp6ecific evaluations of speculative environ mental impacts. While these are legitimate matters* of concern, they should continue to be addressedthrough the ongoing regulatoryprocess as'a currentand genericregulatoryissue that affects all nuclearfacilities andmany activities conductedat nuclear facilities. The NRC I has taken a number of actions to respond to the events of September 11, andplans to take additionalmeasures. However, the issue of security and risk from malevolent acts at nuclear November 2002 0-171 NUREG-0586 Supplement 1

Appendix 0 I power plants is not unique to decommissioning facilities and, therefore, is not within the scope I of a Generic EnvironmentalImpact Statement (GElS) on decommissioning of nuclearpower I plants. The comments did not provide new information relevant to this Supplement and will not I be evaluatedfurther. The comments did not result in a change to the Supplement.

I Comment: With regard to the threat of attack, I think this relates to our second point. The I document was prepared after September 11 th, but it doesn't seem to respond to I September 11th. We think the document should be responsive to the events of September 1 11th. What is NRC going to do to make sure that facilities are protected and secure during I decommissioning? Has that changed in response to the threat of terror attack? We think it I should. (CH-NB)

I Comment: In light of September 11th it is now abundantly clear that nuclear materials are I desired by terrorist organizations. Our nation's operating nuclear power plants represent I terrorist targets, but so too does the nuclear waste they generate. Since a decommissioned I nuclear power plant would have a greatly reduced security force, the closed plant could provide I an easier opportunity for terrorists to obtain nuclear materials. In the case of plants like Hatch I that have outdoor storage of nuclear waste, the notion of a reduced security force is even more I troubling. Georgians for Clean Energy again stresses the need for a full evaluation of security I measures to be assessed prior to issuing a final GELS. (CL-08/3)

I Comment: NRC staff mentioned at the public meeting on 12/12/01 that a full, top-to-bottom I review of security concerns would be conducted. Georgians for Clean Energy urges that this I review be done prior to the issuance of the final generic impact statement for decommissioning I (GElS). (CL-08/34)

I Comment: The massive destruction of September 11th accomplished by the Al Qaeda I terrorists has rendered the Waste Confidence Policy ineffective and obsolete. No reasonable I person can be assured that high-level nuclear waste can be safely stored at plant sites under I present conditions. The GElS fails to consider the consequences of acts of terrorism and acts I of war perpetrated by suicidal zealots against spent fuel facilities at decommissioned nuclear I plant sites. This failure of the GElS needs to be remedied. (CL-14/6)

I Comment: In the aftermath of September 11th, NRC and licensees must address earlier I assumptions that decommissioning was less dangerous than operation and that security I measures and insurance could be reduced because of it. Nuclear fuels pools as well as on site I dry cask storage of high-level waste are targets for terrorism. In fact decommissioned sites I could be selected as targets because there is less security and oversight during decommis I sioning and the monitoring of the ISFSI. NRC must require increased security and the NUREG-0586 Supplement 1 0-172 November 2002

Appendix 0 reinstatement of insurance provisions. Additionally, emergency preparedness drills and the I EPZ should be reestablished. KI should be stockpiled in communities since the potential for off .1 site consequences from a terrorist attack is possible. (CL-50/28)

Comment: The threat of terrorism: With terrorism now a legitimate concern in the United States, the potential of a suicide assault on a nuclear plant - whether the plant is operable or decommissioned - must be assessed plant by plant, not generically. (CL-51/21)

Comment: THE SPENT FUEL IS THE ULTIMATE INTERRORIST TARGETS. (CL-20/80)

Response: Malevolent acts affecting the physical security of nuclearpower plants is an important issue for all reactors,both operatingand permanently shut down, andis not unique to I reactorsin the decommissioningprocess. Shortly after the events of September 11, 2001, the, NRC initiateda comprehensive review of its security requirements at nuclearpower plants to ensure that the appropriatelevel of protection is in place for both operatingand I decommissioning reactors. The safety review will transcendthe entire NRC licensing framework (operatingreactorlicensing, license renewal,-decommissioningetc.) to fulfill NRC's I responsibilitiesunder the Atomic Energy Act. The findings resulting from the NRC's comprehensive review of its security requirementsand whatever actions the Commission determines to be appropriatewill be requiredof decommissioning reactors. Comments related I to physical security considerationsat decommissioning facilities have been forwardedto the, I appropriateprogram office within the NRC for considerationduring the Commission's comprehensive review of security requirements. The comments did not provide new I information relevant to this Supplement and will not be evaluatedfurther. The comments did not I result in a change to the Supplement.

I Comment: Indeed, under the current plan, facilities under SAFSTOR will have fewer personnel at the site even though the radioactivity of the material will still be high. With less security, these facilities are at greater risk for attack. (CL-11/13)

Comment: Since a decommissioned nuclear power plant would have a greatly reduced security force, the closed plant could provide an easier opportunity for terrorists to obtain.

nuclear material.* (AT-N 14)

Response: Changes in the level of security at a nuclearpower plant during decommissioning I would be related to the type of activitiesand the area that requiresprotection. The Commission I has initiatedactivities to reassesssecurity issues in light of recent terroristactivities with the I principalobjective'of maintainingpublic health and safety. -While these are legitimate matters of I concern, they should continue to be addressedthrough the ongoing regulatoryprocess as a, currentand generic regulatoryissue that affects all nuclearfacilities. Comments related to I physicalsecurity considerationshave been forwarded to the appropriateprogram office within I November 2002 0-173 NUREG-0586 Supplement 1

Appendix 0 I the NRC for consideration. The comments did not provide new information relevant to this I Supplement and will not be evaluated further. The comments did not result in a change to the I Supplement.

I Comment: If an organization like ours can spot a train carrying very dangerous radioactive I waste, any terrorist organization can do the same thing. You've got to take that into I consideration. (AT-B/ll)

I Comment: Re 9/11: I direct you to a quote from a recently published German report I concerning the vulnerability of the Castor containers to terrorism: 'The fact that all the technical I data used in the report can be accessed by terrorists does not imply that a more restrictive I policy towards information is required. Rather, it should be regarded as an argument against I the use of a technology which is, at the time, hazardous and complex to a large degree, I creating a conflict between the necessary societal discussion on the one hand and the I protection of society from terrorist attacks on the other." (CL-2713)

I Response: NRC routinely assesses threats and information provided to the NRC by other I Federalagencies and other sources and ensures that licensees meet appropriatesecurity I levels. This issue will remain a priorityfor the NRC even during the transportationof the spent I fueL However, as discussedin Section 1.0, transportationof the spent fuel is outside the scope I of the Supplement. Comments related to physical security considerationshave been forwarded I to the appropriateprogram office within the NRC for theirconsideration. 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.

0.2.4.2 Safety of Decommissioning I Comment: We're also concerned about safety. With reduced staffing as mentioned in the I document, there's an increased risk of accident [and] the threat of attack on these sites with I huge environmental and human consequences. (CH-AN7)

I Response: The missions of the NRC include the protection of public health and safety and I protection of the environment. Staffing reductions at decommissioningpower facilitiesare I made commensurate with the reduction in risk associated with the facilities'permanently I shutdown condition. 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: Every shut down reactor can take us a step closer to a sustainable energy future I but, unfortunately, reactor shut down is not the threshold of safety, where the public can be I assured that no health or environmental dangers will originate from the site. (CL-4716)

NUREG-0586 Supplement 1 0-174 November 2002

Appendix 0 Comment:, Since many nuclear contaminants are extremely long-lived and dangerous to humans and the environment, decommissioning measures need to be handled most carefully, I as our future generations literally will depend on how well the job is done today. (AT-N10)

Comment: The notion presented by industry and others that decommissioning is inherently safe because the plant is no longer operating is a deceptive argument that confuses the public.

Due to the nature of radiation, even after shutdown, paits of the plant, as we know, remain highly contaminated and extremely radioactive. The nuclear waste, such as the spent fuel produced by the plant during operation generates heat and emits radiation for thousands of years after the plant is shut down. Therefore, there is risk to the workers at the plant and to the local communities during decommissioning. (AT-Nl1)

Response: Decommissioning results in a reduction of the risks associatedwith the nuclear power plant. No major decommissioningactivities take place until the fuel has been permanently removed from the reactor. Those risks associatedwith nuclearpower plant operation are eliminated when the spent fuel is permanently removed from the reactorand placed in spent fuel storage. The risks continue to decrease as contaminatedstructures and systems are cleaned up and dismantledand the contaminatematerialis shipped offsite. Risks associatedwith storage of spent fuel are also reduced over time but are outside of the scope of this review. The comments did not provide new information relevant to this Supplement and will I not be evaluated further. The comments did not result in a change to the Supplement.

Comment: The NRC must address the subject of radiation dangers after decommissioning I HONESTLY, USING THE BEST INDEPENDENT RESEARCH, including: :--exposure of I children --exposure of the weak, the ill, the elderly --offsite contamination --credible, not arbitrary, environmental impact categories FOR EACH STEP OF A DECOMMISSIONING. (CL- I 36/6)

Response:, Potentialradiologicalimpacts following license termination that are related to activitiesperformed during decommissioning are not consideredin this Supplement, as discussed in Table 1-1. Such impacts are covered by NUREG-1496, Generic Environmental Impact Statement in Support of Rulemaking on RadiologicalCriteriafor License Termination of I NRC-Licensed NuclearFacilitiesand given in regulationsin 10 CFR Part20. The comment did I not provide new informationrelevant to this Supplement and will not be evaluated further. The I comment did not result in a change to the Supplement.

Comment: The workers were not prepared. They didn't-whatever the-the moon suits they I were supposed to wear or something, they often didn't. And it was-I mean it's dangerous.

(AT-D/2)

November 2002 0-175 NUREG-0586 Supplement 1

Appendix 0 I Response: Radiologicalconditions that workers are likely to be exposed to dictate the need I and type of protective clothing to be used for a specific task. The industry has a remarkably I good safety record when it comes to radioactive contamination and exposure. The comment I did not provide new information relevant to this Supplement and will not be evaluated further.

I The comment did not result in a change to the Supplement.

I Comment: It affects people's health. Workers especially who are not warned, who are not I protected. (AT-Dill)

I Response: Training is required including notification of hazards for each specific job that I involves the actual or potentialexposure to radiation. In addition, there are regulations I controlling the occupationaldoses to the workers. 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 0.2.4.3 Risk-Informed Regulations I Comment: The U.S. Nuclear Regulatory Commission (NRC) has applied extraordinary effort to I risk-inform reactor oversight but, save for Appendix G of this report, has avoided translation of I environmental impacts from dose based-language to risk-based language. (CL-13/1)

I Response: The commenter is correct. The Supplement does not use risk-based language for I the majorportion of the Decommissioning Supplement. 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: The whole approach-the whole probablistic approach to risk is inappropriate. You I must assume that whatever can go wrong will go wrong and that should be the level at which I your risks are evaluated, not some unrealistic dream-like assessment of probability that isn't I real world anymore. (AT-B/12)

I Response: The use of probabilisticrisk assessments (PRA) as a tool to support regulatory I decision making is a well establishedprocess that has been fully vetted, publically discussed, I and widely accepted. The use of PRA by the industry and NRC staff complements the staff's I deterministicapproach to evaluating safety and supports the more traditionaldefense-in-depth I philosophy. One of the primary reasons to employ a PRA approachis to achieve greater I realism and effectiveness in evaluating andregulatingwhat preciselyis importantand safety I significant. Evaluatingevery conceivable accidentscenario without regardto its probabilityof I occurrence is not realistic,wasteful of resources, and does not lead to good regulatory I decisions. The comment did not provide new information relevant to this Supplement and will I not be evaluated further. The comment did not result in a change to the Supplement.

NUREG-0586 Supplement 1 0-176 November 2002

Appendix 0 Comment: Instead, the NRC has chosen to abandon its former regulatory philosophy (defense I in depth and redundancy of safeguards) in favor of the far less restrictive and less protective approach (performance-based and risk-informed). (CL-52122)

Response: The NRC staff has not chosen to abandon its former regulatoryphilosophy. I Defense-in-depth, Which includes redundancy,remains a principalelement of the NRC safety I philosophy. Any applicationof risk-informed orperformance-basedregulationmust be entiriely I consistent with the principalsof providing for defense-in-depth and maintainingadequatesafety I margins. See Regulatory Guide 1.174, 'An approachfor Using ProbabilisticRisk Assessment I in Risk-Informed Decisions on Plant-Specific Changes to the Current Licensing Basis",July 1998, for a detailed discussionof the NRC's regulatoryguidance on risk-informed decision making. 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.

0.3 Decommissioning Process Comment: The location of intake and outfall structures in the lake alone requires site-specific I analysis. As written, the Draft GElS does not make clear whether an intake/outfall structure on I the facility is considered part of a previously.disturbed area. 'If deemed part of the previously I disturbed area, any work on the intake/outfall structdre will be deemed generic and the impact small. (CL-1116)

Response: Chapter4 of the Supplement has been extensively revised and the concept of "previouslydisturbedarea"is no longer the criteria for initiatinga site-specific analysis. The comment did not prroide new information relevant to this Supplement and will not be evaluated I further. The comment did not result in a change to the Supplement.

Comment: Page 3-5, Section 3.1.2, Lines 31-33 and Page 3-8, Lines 13-16. The document states on page 3-5 that "the impacts of dismantling all SSCs (structures, systems and components) that were built or installed at the site to support power production are considered I in this Supplement." -Itthen states on page 3d-8 that the Supplement does not evaluate switchyards which "may remain on the site.' Ifthey are 'dismantled, would they be evaluated? I (CL- 6/17) I Response: None of the facilities that have'iecentlypermanently ceased operationhave '1 dismantled their switchyards. However, if licensees choose to remove the switchyardsit could I be accomplished with little or no impact to the 6nviroriment. The staff, in deciding the scope of I the Supplemient, atteiptedto place reasonablelimits'on the analysis. Since historically November 2002 0-177 NUREG-0586 Supplement 1

Appendix 0 I licensees generally maintainedthe switchyard the staff chose to not include it in the I assessment of potentialimpact. 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: Could you explain to me what that [previously disturbed area] would mean for an I intake for water for cooling at the facility. Would that, does anything happen to that intake I position during decommissioning? (CH-A/3)

I Response: Chapter4 of the Supplement has been extensively revised and the concept of "I 'previously disturbed area"is no longer the criteriafor initiatinga site-specific analysis. The I intake structure, for the purpose of this Supplement, is consideredwithin the operationalarea I (the concept that replaced "previouslydisturbedarea"). The licensee may choose to remove I the intake structure during decommissioning, could wait until after the license is terminatedto I remove the intake structure, or could choose to leave the structure in place. The text was I revised in several sections of this Supplement to betterdescribe this issue.

I Comment: Major component removal should not be approved with the submission of a Post I Shutdown Decommissioning Activities Report (PSDAR). A clear definition must be established I to clarify what constitutes major and minor component removal. Approval of decommissioning I plan should be required before major decommissioning activities begin. The PSDAR does not I afford the community effective input into the decommissioning process since this document is a I skeletal outline of generalized activities planned by the licensee. (CL-5017)

I Response: Major decommissioningactivities are clearly defined in 10 CFR 50.2. Regulatory I Guide 1.184, Decommissioningof NuclearPower Reactors, July 2000, provides additional I clarification on major and minor components and what can be removed priorto submission of I the PSDAR. The NRC regulationsdo not require the approvalof a decommissioningplan prior I to the commencement of major decommissioning activities. The purpose of the PSDAR is to I inform the public and the NRC of the licensee'splans for the decommissioning of the facility.

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: The original site maps and drawings and photos made during construction should I be consulted (some building techniques may have changed) all modifications and revisions I should be tracked down. All vent systems should go through both HEPA (for the chemicals)

I and sand filters. Additional containment should be added around spent fuel pools including I over the top and beneath it, extra supports, new liners. They will suffer serious embrittlement I and activation, same goes for the casks. Such issues must be addressed. (CL-20f72)

NUREG-0586 Supplement 1 0-178 November 2002

Appendix 0 Response: Licensees are requiredby 10 CFR 50.75(g) to keep recordsof information importantto the safe and effective decommissioning of the facility. Records of spills or unusual occurrencesas well as "as-built"drawingsand modifications to structures,systems, and components are covered by this requirement. The licensee is also requiredto use procedures andprocesses to accomplish decommissioninginma safe mannerand to keep doses to the public and to the workers As Low As Reasonably Achievable (ALARA). The staff does not prescribe specific requirementsrelated to facility decommissioning. The detailedsuggestions made by the comment are outside the scope of this environmental assessment. The staff does, I however, oversee the decommissioningprocess to ensure that appropriateregulatory requirements are being met. 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 License Termination Plan (LTP) should be established, reviewed by the public I and approved by the NRC before site remediation begins. (CL-50/18)

Response: -The NRC regulations require that the licensee submit the License Termination,Plan I (LTP) approximatelytwo years priorto expected terminationof the license.- This could, I depending on the decommissioningoption chosen, be anywhere from approximately3 to 58 years after permanent cessation of operation.-.Therefore,the current regulations I (10 CFR 50.82) allow for site remediation to begin prior to submission and approvalof the LTP. I The regulationsrequire that the NRC staff conduct a public meeting related to the LTP submittal I in the vicinity of the plant. Since the LTP is approvedby amendment to the facility license, the I public will have the opportunity to participatein the review. Amendment of NRC regulations is I outside the scope of this Supplement. NRC rulemaking proceduresare found in 10 CFR Part2. 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.

Comment: But things that shouldn't have been done did happen and things-you know, when I they were washing some of the surfaces to prepare for cutting apart and shipping the wash water-I've spoken about this to some of the people already. It just went into the ground. It I was supposed to be contained and it wasn't. And other things like that, that happened that, I were not supposed to happen, but they do happen. (AT-D/5)

Response: Although infrequent, inadvertent releases of radioactivematerialduring decommissioning occurs, the amount and consequences of those releasesin the past have been minor and pose no threat to public health and safety. Past Releases to the environment have been remediatedor determined to be of inconsequential health risk. The comment did not I provide new information relevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.

November 2002 0-179 NUREG-0586 Supplement 1

Appendix 0 I Comment: One idea that we've talked about for a long time, and we actually had a big meeting I about it and I think the idea is probably still alive, the site-specific advisory board. (AT-G/4)

I Response: Licensees at many decommissioning facilities have developed site-specific I advisoryboards that are composed of elected officials, technical experts, and members of the I local public. These boardshave been used as a means of keeping the public informed I regardingthe decommissioningprocess and to provide public input to the utility. The NRC I encourages the use-of these boards and frequently attends the meetings. However, NRC I regulationsdo not require the formation of these advisory boards, nor is the NRC involved in I their formation or theirmaintenance. This subject is outside the scope of this Supplement. 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.

I Comment: My direct experience is limited to having heard an eyewitness account of the I decommissioning of Yankee Rowe. This person reported a whole list of unfortunate incidents I that released contamination into the air and groundwater, contaminating workers on site who I were not wearing protective clothing, and possibly contaminating people along the rail and truck I routes where parts of the plant were being transported. (CL-10/3)

I Response: Occasionalreleases of radioactivematerialhave occurredat Yankee Rowe during I decommissioning. Such events have been documented, investigated,and determined not to I pose any risk to public health and safety. Specific information on the decommissioningat I Yankee Rowe can be found in the NRC's ADAMS information system under docket number 1 050-00029. The comment did not provide new information-relevantto this Supplement and will I not be evaluatedfurther. The comment did not result in a change to the Supplement.

I Comment: The Technical Specifications and what the facility was allowed to dump under the I license are outdated and bear no resemblance to current knowledge and should be junked and I the whole thing done over. (CL-20114)

I Response: The comment is nonspecific. The Technical Specifications for the I decommissioned facility are modified as decommissioningprogressesthrough the license I amendment process. Releases of radioactive materialfrom the facility must be consistent with I the regulations. The release limits are the same for decommissioningplants and operating I plants. The comment did not provide new information relevant to this Supplement and will not I be evaluatedfurther. The comment did not result in a change to the Supplement.

I Comment: To find out the extent of past problems, and contamination levels, IT IS VITAL I THAT THE NRC; THE LICENSEE (as some are new owners/licensees), AND THE I CONTRACTORS AND SUB-CONTRACTORS, GET ALL REPORTS OF ACCIDENTS, NUREG-0586 Supplement 1 0-180 November 2002

Appendix 0 LICENSEE EVENT REPORTS, VIOLATIONS, INSPECTION REPORTS, SPILLS AND CONTAMINATION EVENTS FROM THE DOCKET FOR THE REACTOR AND SITE IN QUESTION. (CL-20/22)

Response: The staff agrees that those NRC staff members responsiblefor the oversight of the I facility decommissioning should have access to and become familiarwith the relevant NRC documents. Licensees are requiredby 10 CFR 50.75(g) to keep records of information important to the safe and effective decommissioningof the facility. Records of spills and I unusualoccurrences as well as "as-built"drawings andmodifications to structures,systems,.

and components are covered by this requirement. 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: NRC must stipulate, that ALL CONTRACTORS AND SUB-CONTRACTORS, RIGHT DOWN TO THE BACK-HOE OPERATORS MUST BE HIGH SCHOOL GRADUATES. 'I Cleanup cannot just be dished out to any contractor, all involved should not only have a sterling I track record, but experience in nuclear fields. -There should be a radiation biologist on site, plus I a health physicist,.plus a wildlife biologist with a knowledge of radiation effects, plus there must I be federal and state oversight ON THE SITE at all times. (CL-20/23) I Response: Qualificationsand educationalrequirements for various licensee positions are specified in the regulationsin 10 CFR Part50 and are outside the scope of 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: ALL workers must have self-contained breathing systems (moon-suits). (CL-20/32) I

- I Response: Requirements for personnelprotection are outside the scope 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. I Comment: The use of high pressure water sprays is'obscene. (CL-20/69)

Response: High-pressurewater sprays have been used to decontaminatestructures, I systems, and components and are an effective andsafe method of decontamination., The use I or non-use of specific decommissioning equipment is outside the scope of this Supplement. I The comment did not provide new informationrelevant to this Supplement and will not be I evaluatedfurther. .The comment did not result in a change to the Supplement. I November 2002 0-181 NUREG-0586 Supplement 1

Appendix 0 I Comment: Methodology must be established to locate and collect for proper disposal I contaminated tools, soils, concrete blocks, plywood and other building materials that may have I been taken offsite by workers during reactor operation such as was the case at Connecticut I Yankee and Yankee Rowe. (CL-50/15)

I Response: Licensees, as partof their radiologicalcontrol procedures,have established I requirements to limit the spread of radioactivecontaminationfrom tools. The recovery of I contaminatedmaterialimproperlyreleasedfrom facilities undergoing decommissioningis I outside the scope of this document. The comment did not provide new information relevant to I this Supplement and will not be evaluatedfurther. The comment did not result in a change to I the Supplement.

I Comment: It is obvious that the reactor vessel should NEVER be cut up, but do what was I done with the Trojan vessel (p.G-18, remove the whole thing offsite) (CL-20/58)

I Response: Although the intact shipment of the reactorvessel greatly reduced the dose to the I workers and the cost of removal,it was only facilitatedbecause of the proximity of the Trojan I Nuclear Plant to the low-level waste site at Hanford, Washington, the ability to use the I Columbia River, a navigable river that allowed the barge transportfor the reactor vessel, and I the ability of Hanford to take the vessel for disposal. The industry has had experience in I removing reactorvessel internalsand, in the case of Shoreham, did segment and dispose of I the reactorvessel. Such activity has been performed safely in the past and without serious I injury orrelease of radioactivityto the environment. 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: However, the vessel should have additional shielding placed around it prior to I placement on the heavy haul trailer, and upon arrival at the disposal site it should be further I encased in what would amount to a giant burial cask. (CL-20/59)

I Response: Licensees must comply with NRC standardsfor allowable offsite radiation; I regulationsfor transportationof waste materialsare in 10 CFR Part20, SubpartK. Additional I shielding beyond that requiredby NRC regulationsis not requiredto protect the health and I safety of workers or members of the public. 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.

I Comment: Removing the vessel offsite massively reduces worker doses, water contamination I and the contamination to the local community and the environment. (CL-20/60)

NUREG-0586 Supplement 1 0-182 November 2002

Appendix 0 Response: The comment was not specific and did not provide new information relevant to this I Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.

Comment: I noticed that it said cutting methods included abrasive water G-1 7, but in any case I where there is plutonium contamination or depleted uranium metal, that all is meant to be cut 'I under heavy oils and much else besides. Since many of the components will have been contaminated with plutonium, or were made of depleted uranium (when is the NRC going to tell I the public that DU is NOT radioactive waste?) (CL-20/57)

Response: Abrasive cutting of structures,systems, and components has been used frequently I in decommissioning operations(Trojan, Fort St. Vrain, Haddam Neck).' Such activities require '1 stringent contaminationcontrol measuresand occur inside buildings oi structures,such as the I containmentbuilding,'which are designed to contain radioactivecontamination. The comment 'I did not provide new information relevant to this Supplement and will not be evaluated further. I The comment did not result in a change to the Supplement.

Comment: No structural remains should be sent to local landfills. (CL-20/75)

Response: Only materials that have been carefully surveyed and determined to have no detectable radiationare allowed to be releasedfrom the plant. The comment did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comment I did not resultin a change to the Supplement.

0.4 Out-of-Scope Issues 0.4.1 Reuse of Matedals Offsite Comment: In a related issue, there continues to be agap in regulations concerning the I release of slightly contaminated solid materials.: In both partial site release without a license termination plan and license termination for the entire site, residual radioactivity may remain as long as the exposure criterion of 10 CFR 20 Subpart E is satisfied. Conversely, this same residual radioactivity is treated as licensed material prior to license termination--regardless of I how little ihe amount,'concentration, or dose significance--and can only be disposed of at a - 11 licensed facility. This double standard poses an incentive to retain radioactive material onsite I until the license has been terminated to avoid potentially excessive costs for radwaste disposal, I while creating a o10nger term risk for additional site'cieanup required by other regulatoi authority I or Court of law. While we 'ecognize that the U.S., Nuclear Regulatory Commission (NRC) is I seeking to resolve this discrepancy through study by the National Academy of Sciences, and I further agency deliberation, this process may take several years. Prolonged delay contributes I to the erosion in public understanding and confidence in government policy as well as the lack I November 2002 0-183 NUREG-0586 Supplement-1

Appendix 0 I of resolution mentioned above for licensees. Public policy is needed to define the quantitative I dose and radionuclide characteristics that have no discernible public health consequences.

I (CL-01/8)

I Comment: The release of scrap metal from power reactors undergoing decommissioning will I present a far more insidious problem than orphan sources, by greatly increasing the volume of I radioactive scrap arriving at, and the frequency of alarms at, metals companies. This poses a I serious problem for the suppliers and transporters, who must manage and arrange for the I ultimate disposition of the rejected scrap. It would have a similarly enormous adverse impact I on the smaller producers, foundries, scrap dealers and processors, fabricators, and end I product manufacturers. Metals companies experiencing several alarms daily would continue to I incur enormous costs, either unfairly increasing their manufacturing costs or compelling them to I raise detection levels to above background, thereby exposing themselves to increased risk of I inadvertently melting sealed sources. Receipt of even slightly elevated levels of radioactively I contaminated scrap imposes enormous costs on metals companies. (CL-03/6)

I Comment: No radioactively contaminated parts should be allowed into consumer use, I commerce, or unregulated disposal. (CL-39/3)

I Comment: Georgians for Clean Energy also opposes any efforts by the nuclear industry or I licensee of a decommissioning nuclear plant to "recycle"--and I use that in quotes-radioactive I materials for release into the marketplace. It is appalling that there may be an option for I companies involved in a technology that can cause its own facilities to become radioactive, to I financially benefit from selling the hot garbage to unsuspecting citizens in the form of daily I household products. (AT-N38)

I Comment: Georgians for Clean Energy also opposes any efforts by the nuclear industry or I licensee of a decommissioning nuclear plant to "recycle" radioactive materials for release into I the marketplace. No facilities should be able to sell their demolition debris. Instead, it should be I dealt with as regulated nuclear waste since the bulk of the materials will be radioactively I contaminated. (CL-08/23)

I Comment: The radioactive components, parts, liquids i.e. anything part of or to do with or I emanating from the structures and the site MUST NEVER BE RE-CYCLED, OR RE-USED.

I (CL-201109)

I Comment: NRC MUST IMMEDIATELY CEASE ALLOWING, OR THINKING OF ALLOWING, I RADIOACTIVELY CONTAMINATED SOIL TO BE RE-USED FOR ANYTHING. (CL-20/110)

NUREG-0586 Supplement 1 0-184 November 2002

Appendix 0 Comment: Has the NRC no common sense at all? -Releasing radioactively contaminated materials into daily consumer use and commerce and unregulated disposal is a direct assault on humanity. Don't let this happen. (CL-23/1)

Comment: Although it is not certain, a strong possibility exists that power reactors could release scrap metal that has a serious impact on the environment, such as by contaminating the soils or groundwater underneath a scrap yard or by escaping detection and becoming melted inadvertently in a metal company furnace. Furthermore, certain isotopes in scrap metal that escape detection before melting may accumulate and concentrate in emission control systems at metals company facilities, to the extent that metals producers could generate low-,

level wastes ("LLW") or mixed wastes. (CL-03/3)

Comment: Even if NRC eventually does establish dose-based clearance standards for solid materials, thousands of tons of scrap metal with residual radioactive contamination still would be released into the economy or sent to LLW or industrial waste landfills. (CL-03/4)

Comment- The economic and socioeconomic impacts of decommissioning, coupled with the-lack of health-based release criteria using dose-based standards, create a disturbing incentive for the nuclear powerindustry to release as much surplus metal as it can into the economy and 1 market it as useful material, rather than incurring additional disposal costs when the scrap metal meets general regulatory release guidelines but may contain levels of residual radioactivity unacceptable to metals producers. NRC's recognition of these economic and socioeconomic impacts and its concurrent failure to consider the impacts of contaminated scrap I metal on the metals industries create the mistaken impression that the agency has covered all I of the significant impacts of decommissioning. (CL-03/8)

Comment: We oppose any unlicensed disposition of long-lasting radioactivity from the nuclear fuel chain activities. As long as radioactive materials remain, someone should retain a license for those materials, and responsibility for them. That burden should not be shifted to the states I and local communities without clear acknowledgment of the stewardship responsibility for that I material. -(CL-48/17)

Comment: I specifically oppose any release of contaminated materials during decommissioning or other times/procedures. (CL-381)

Comment: Concerning the scope of this hearing and to what extent the radioactive contamination levels that are permitted to be released from regulatory contro! for I decommissioning are being used to release radioactive materials routinely. (SF-D/2)

Comment: We would oppose any release of contaminated materials during decommissioning or other times. (SF-D/3)

November 2002 0-185 NUREG-0586 Supplement 1

Appendix 0 I Comment: I Firmly oppose the "release" of radioactively contaminated materials into daily consumer use and commerce and unregulated disposal. (CL-24/5)

I Comment: I stand firmly against the "release" of contaminated materials into daily consumer I contact and commerce or unregulated disposal. (CL-25/11)

I Comment: I stand firmly against the "release" of radioactively contaminated materials into daily I consumer use and commerce or unregulated disposal. (CL-26/15)

I Comment: I oppose the release of radioactive contaminated materials into daily consumer or I commercial uses. (CL-29/3)

I Comment: I stand firmly against the "release" of radioactively contaminated materials into daily consumer use and commerce or unregulated disposal. (CL-37/1)

I Comment: The Supplement indicates that portions of a nuclear reactor site could be released I from regulatory control prior to the site operator's license termination. This would relieve the I nuclear utility of responsibility and liability for portions of sites (be they materials or real I property) while still being licensed for the control of the entire site. Public Citizen is completely I opposed to any such practice, which would allow radiation/radioactively-contaminated materials I and wastes to be released, reused, or recycled, without restriction, into the unregulated I industrial, commercial, and public environment. (CL-47/16)

I Comment: Subsequent uses of these "slightly contaminated" materials and wastes-in I roadbeds, or construction, consumer products, or other objects individuals may contact-will I each add to the radiation doses received without knowledge or consent of the recipient.

I (CL-52/16)

I Comment: NRC defines decommissioning, in part, to include the "release of property for I unrestricted use...." and the "release of property under restricted conditions..." NIRS stands I firmly against the "release" of radioactively contaminated materials into daily consumer use and I commerce or unregulated disposal. (CL-48/49)

I Comment: The NRC must NOT permit "release of property for unrestricted use" or under "I "restricted conditions." To permit the release of radioactively contaminated materials into daily I consumer use and commerce, or to allow unregulated disposal of such materials is abhorrent.

I Bin Laden might approve of such an interesting experiment; I trust that the NRC does not and I will not. (CL-36/7)

NUREG-0586 Supplement 1 0-186 November 2002

Appendix 0 Comment: MIRC appreciates the opportunity to comment on the draft Supplement and urges NRC to consider in the final Supplement to the GElS the environmental impacts of releasing radioactively contaminated scrap metal into the economy for unrestricted use, as well 'as the economic impacts on the metals industries and related socioeconomic impacts. (CL-03/9)

Comment: The Supplement does not discuss the potential environmental impacts of releasing scrap metal or other solid materials pursuant to NRC's unrestricted release guidance, except to state that licensed facilities must comply with standards in 10 CFR. Part 20, limiting the sum of allowable internal and external doses to individual members of the general public to 0.1 rem per I year. NUREG-0586 at 4-26, (Allowable doses-to individual members of the public following ,I license termination are limited to 25 millirem per year during the control period and 100 millirem 'I per year after the end of institutional controls. See 10 CFR § 20.1402) (CL-0312) I Comment: IF NRC, EPA, THE DOE AND OTHERS DO NOT STOP THIS INSANE RUSH TO I REUSE, RECYCLE,-DUMP AND COVER ETC.'NUCLEAR MATERIALS, RADIOACTIVE I MATERIALS, ACTIVATED MATERIALS ETC., WITHIN FIFTY YEARS NO LIVING BEING I WILL BE BORN WITHOUTSOME TYPE OF DEFORMITY, GENETIC ABNORMALITY, -I CHROMOSOME ABERRATION ETC AND THE IMMUNE SYSTEMS OF EVERY LIVING I BEING WILL BE SERIOUSLY COMPROMISED DUE TO RADIATION SUPPRESSING THE IMMUNE SYSTEM RESPONSE, AND ALL BECAUSE WE WILL BE COMPLETELY ENGULFED INA MIASMA OF MANMADE, OR MAN ENHANCED, RADIOACTIVE CONTAMINATION. (CL-20/112)

Comment: These exposures from multiple unmonitored, unlabeled, uncontrolled sources are I in no way accounted for, but they are additive and cumulative for the individual. They violate I the fundamental tenet of radiation protection: viz., that the recipient of a radiation dose that is I in addition to naturally-occurring background exposures should receive a benefit equal to or greater than the risk incurred. (CL-52117)

Comment: IT.MUST FORBID THE MELTING, SMELTING OR RE-USE OF RADIOACTIVELY I CONTAMINATED METALS, PIPING, PLASTICS, WOOD, (INCLUDING FORBIDDING THE I1 BURNING OF WOOD), ASPHALT, AND SOON. (CL-201111) I Comment: As we have previously commented in other dockets, there should be no release of I radioactively contaminated material of any kind into consumer use or into general c6mmerce,. I Disposal of all materials from decommissioning needs to be regulated, regardless of whether I1 they are radioactive or not. (CL-40/4) I Comment: The NRC should not permit radioactive materials or wastes to be released into the I environment. That is the basic message, the rightful demand of all those who will be affected I negatively by releases. (CL-52/1 8) I1 November 2002 0-187 NUREG-0586 Supplement 1

Appendix 0 I Comment: Because the costs of sequestration ("disposal") of wastes is high, and deemed to I be a "burden" for the licensee, the agency continues its endeavor to allow massive I deregulation-release, recycle, and re-use--of radioactively-contaminated materials and I wastes and their entry into the "free market" for resale and reuse in a host of consumer I products. (CL-52/15)

I Response: During the decommissioning process, solid materialsmay not be released, I recycled, or reused if there are detectable levels of licensed radioactivematerialpresent. Solid I materialsare carefully surveyed before release. The NRC has an initiative underway to I considerthe reuse or recycling of slightly contaminatedsolid material. This issue is being I consideredin an open forum and is outside the scope of the Supplement. Comments on the I reuse or recycling of solid materialwill be forwardedto the appropriateNRC office for I consideration. The comments did not provide new information relevant to this Supplement and I will not be evaluatedfurther. The comments did not result in a change to the Supplement.

I Comment: Since at least as early as 1974, NRC has espoused a policy of "unrestricted I release" of solid materials, including scrap metal, from nuclear fuel cycle facilities, without any I specific, health-based release criteria. Unlike NRC requirements applicable to gaseous and I liquid releases from nuclear facilities, there are no specific criteria governing releases of solid I materials by licensees. Requests to release solid material are approved on a case-by-case I basis using existing regulatory guidance and license conditions. (CL-0311)

I Response: The release criteriafor scrap metals and othersolid materialfrom nuclearpower I reactorsare not "health-based" because the release criteria arebased on demonstrating that I there is no detectable contaminationon the material. While these criteriado not have a specific I dose or risk basis, they are consideredto be protective of public health. The NRC has an I initiative underway to considerthe reuse or recycling of slightly contaminatedsolid material.

I This issue is being consideredin an open forum and is outside the scope of the Supplement.

I The evaluation of environmentalimpacts from the release of potentially contaminatedsolid I materialsis not within the scope of this Supplement. The comment did not provide new I information relevant to this Supplement and will not be evaluatedfurther. The comment did not I result in a change to the Supplement.

1 0.4.2 Partial Site Release I Comment: To categorize as "generic" "the release" from regulatory control portions of sites I before they are completely decommissioned is not responsible. (CL-39/2)

NUREG-0586 Supplement 1 0-188 November 2002

Appendix 0 Response: The Supplement does not categorizepartialsite release as "generic", It does.

indicate that a proposed rule was issued on September 4, 2001 for partialsite releaseprior to license termination. The partialsite release rule does not advocate the releasefrom regulatory control, portions of the site before they are completely decommissioned. 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: I utterly oppose allowing portions of sites to be released from regulatory control before the whole site is released. (CL-33/8)

Comment:. I am opposed to the following change toNUREG-0586: In Supplement 1 to the Generic Environmental Impact Statement on Decommissioning: NRC allows portions of sites to be "released" from regulatory control before the whole site is released. (CL-43/2)

Comment: - am opposed to NRC regulations pertaining to Decommissioning which would allow portions of sites to be "released" from regulatory control before the whole site is released.

(CL-4416) I Comment: NRC allows portions of sites to be "released" from regulatory control before the whole site is released. (CL-48/37)

Comment: I am opposed to the following propbsal(s) in the EIS: NRC allows portions of sites to be "released" from regulatory control before the whole site is released. (CL-26/3)

Response: The partialsite release rule does not advocate the release from regulatorycontrol portions of the site before they are completely decommissioned. The rule 'requires'that pfrtions 1 of a site'releasedprior to NRC approvalof the License Termination PlanTmust meet the same-' -1 criteriaas the entire site would at license termination. In providingpublic review of a proposed I partialrelease, the NRC notices receipt of aa licensee'sproposal for a partialsite release,'

regardlessof the potentialfor residualradioacttivi, and makes it available for public comment. I The NRC is also required to hold a 1ublic imeetin'g in the vicinity of the site to discuss the licensee's request for approval, or license arn~ndmentapplicationin the case of impated property,as applicable,and obtain comments: before approving the release. The commients did I not provide new information relevant to this Supplement and will not be evaluated further. The I1 comments did not result in a change to the Supplement.

Comment: Again THERE MUST NEVER BE A PARTIAL OR FULL SITE RELEASE. ALL PROPERTY DEEDS MUST STATE THE SITES ARE NOT'ONLY RADIOACTIVE, BUT I SUPERFUND-SITES, AS THAT IS WHAT THEY ARE. ITHE RIVER, LAKE, OCEAN BEACH I November 2002 0-189 NUREG-0586 Supplement 1

Appendix 0 I STRETCH OR WHATEVER IS NEXT TO THE SITE SHOULD BE POSTED AS RADIOACTIVE I ALSO, EVEN IF THE SEDIMENT IS REMOVED, AS IT IS IMPOSSIBLE TO GET I EVERYTHING. (CL-20173)

I Response: A power reactorsite or portions of a power reactorsite that are releasedpriorto I terminationof the reactorlicense would not qualify as a Superfund site with respect to a I radiologicalhazard because the site or portion of the site would not be releasedfrom the NRC I license until the licensee could demonstrate that the propertyposed no immediate or long-term I radiologicaldangerto the public. How former sites are identified,posted, or describedin I property deeds is outside the scope of NRC's mandate and regulations. 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 text of the Supplement.

I Comment: Partial release of property for unrestricted use should not be allowed until the LTP I has been established, reviewed by the public, approved by the NRC and implemented on the I given piece of land. Furthermore, methodology should be established for preventing I recontamination of the released property through environmental migration e.g. rain, wind, etc I and future decommissioning activities i.e. excavating, tracking or relocating contaminated I materials. (CL-50/19)

I Response: The partialsite release rule requires thatportions of a site releasedpriorto NRC I approval of the License Termination Plan must meet the same criteriaas the entire site would I at license termination. In providing public review of a proposedpartialrelease, the NRC notices I receipt of a licensee'sproposal for a partialsite release, regardlessof the potential for residual I radioactivity,and makes it available for public commenL The NRC is also requiredto hold a I public meeting in the vicinity of the site to discuss the licensee's request for approval,or license I amendment applicationin the case of impactedproperty, as applicable, and obtain comments I before approving the release. The partialsite release rule does not specifically address I methodologies for preventing recontaminationof the releasedproperty. Licensees, however, I have the same continuing responsibilitiesfor controllingradiologicalreleases onto property I previously releasedfor unrestricteduse as they do for releases onto any other unrestricted I areasadjacentto the site. The comment did not provide new information relevant to this I Supplement and will not be evaluatedfurther. The comment did not result in a change to the I Supplement.

1 0.4.3 Disposal of Low-Level Radioactive Waste I Comment: The draft GElS says that low-level radioactive waste disposal is not part of the I scope of this GElS. However, this would appear to be contradicted by the definition of I decommissioning (pg. xii), and by the scope, the release and removal of Sites, Systems and I Components (SSCs). (CL-3816)

NUREG-0586 Supplement 1 0-190 November 2002

Appendix 0 Response: The disposalof low-level waste (LLW) is not within the scope of this Supplement as it is an activity performedat a facility that is separatelylicensed or regulated. Sections 1.2, "ProcessUsed to Determine the Scope of this Supplement," and 1.3, "Scope of this Supplement,'addresslow-level waste and how it is consideredin 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.

Comment: In addition to the economic gash in the GElS portal, this fatally flawed document does not adequately address, acknowledge, account for, or compute a number of significant barriers related to radiological decommissioning; including:] "Low-level" Radioactive Waste Isolation; (CL-02/6)

Comment: You talk about burying it somewhere, well everybody is in danger when you' do thisI kind of thing. (AT-D17)

Response: -The disposalof LLW is not within the scope of this Supplement, as it is an activity performed at a facility that is separately licensed or regulated. LLW facilities are sited in areas that are away from surface water and where the groundwateris located at depths'sufficiently beneath the trenches to minimize nuclide migration. Sites and the surroundingareasare monitoredusing a system of wells to determine whether radioactivematerialis migratinginto the groundwater.-A combination of naturalsite characteristicsand engineeredsafety features is used to ensure the safe disposalof LLW. In addition, restrictionsof types and amounts of waste disposed of at a site, as well as the technical analysis performed as part of the licensing review to demonstrate compliance with performance objectives in NRC regulations,maintain the safety of LLW disposal. The naturalcharacteristicsof an LLW disposalsite are relied on in the long-term, and they should promote disposal-site stabilityand attenuate the transportof radionuclidesaway from the disposalsite into the generalenvironment. Sites generally must possess the following characteristics: (1) relatively simple geology, (2) well-drained soils free from frequent ponding or flooding, (3) lack of susceptibilityto surface geologicalprocesses, such as erosion, slumping, and landslides, (4) a water table of sufficient depth so that groundwaterwill not periodicallyintrude into the waste or dischargeonsite, (5) lack of susceptibilityto tectonic processes, (6) no known potentially exploitable naturalresources, (7) limited future populationgrowth or development, and (8) capabilityof not being adversely impacted by nearby facilities and activities. Engineeredbarriersare man-made structures designed to improve the naturalsite characteristicsto isolate and contain waste. They consist of various engineeredsystem components,-includingthe following: (1) a layered earthencover, 1 (2) a disposal vault, (3) a drainagesystem, (4) waste forms and containers, (5) backfill material, I and (6) an interiormoisture barrierand low-permeabilitymembrane. Regulations specify the I November 2002 0-191 NUREG-0586 Supplement 1

Appendix 0 I allowable radiationdose from the LLW facilities to the workers and to the public. Evaluation of I the environmentalimpacts associatedwith the disposalof low-level waste is outside the scope I of this Supplement. The comments did not provide new information relevant to this Supplement I and will not be evaluated further. The comments did not resultin a change to the Supplement.

I Comment: The on site disposal of radiological demolition debris (rubblization) is considered in I the GELS. With rubblization abandoned at Maine Yankee, the cumulative effect of disposal of I the debris at a licensed facility elsewhere is not considered. This makes no sense. Nor does it I make sense to "lose" impacts when contaminated materials are shipped to handling facilities for I recycling. Different choices made at the decommissioning site will result in different impacts to I workers and other citizenry offsite and away. These effects should not be artificially separated I from the environmental impacts of decommissioning simply because they are exported.

I (CL-1 3/19) 1 Response: The disposalof low-level waste (LLW) is not within the scope of this Supplement, I as it is an activityperformed at a facility that is separatelylicensed or regulated(see Section 1 1.3). Regulationsrelated to LLW disposal are in 10 CFR Part61 and 10 CFR Part20, Subpart I K, of the Code of FederalRegulations. The staff did considercumulative impacts. Section 4.2 1 has been changed for clarification.

I Comment: If such a tent system were used, afterwards it would be disposed of as rad waste.

I (CL-20/35)

I Response: If the tent system was contaminatedand the contaminationcould not be removed I to undetectable levels then the tent or the contaminatedportions of the tent would have to be I disposed of as LLW. The disposalof low-level waste (LLW) is not within the scope of this I Supplement, as it is an activity performed at a facility that is separatelylicensed or regulated.

I 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: In addition to recomputing the cost of LLW disposal, the reopening of Barnwell has I indefinitely postponed the siting of a waste facility in Pennsylvania. (CL-02/29)

I Response: The factors influencing the siting of regional-compactburialsites is outside the I scope of the Supplement. The comment did not provide new information relevant to this I Supplement and will not be evaluated further. The comment did not result in a change to the I Supplement.

I Comment: The fact is, wherever this radioactively contaminated refuse winds up - from spent I fuel to contaminated rags - it can't be contained forever and will reach the environment, which is I why it must go to a remote location, below ground (none of this idiot parking lot out in Utah or NUREG-0586 Supplement 1 0-192 November 2002

Appendix 0 Nevada cask storage either) in a dry, geologically sound (as far as possible in a moving planet) location where monitoring could alleviate problems that arise prior to reaching the public and wildlife. NRC must recognize that this "solution" - while not a perfect solution, as there is no perfect solution to the nuclear waste issue, is the solution that has been gone back to repeatedly over the decades, after thousands of studies contemplating what to do with the waste failed to identify anything better, or safer. What NRC and industry are proposing in this Draft, flies in the face of thousands of prior studies by some of the world's most renowned people who understand the horror of the dilemma,, and of their conclusions. Leaving all this contamination on sites around the nation to contaminate and kill hundreds of communities is simply barbaric and must be stopped at all costs. (CL-20/114)

Comment: The nuclear industry is leaving humankind a legacy of devastation,- epitomized by its long-lived and highly dangerous nuclear waste. They are unable to solve their waste problem and now, when faced with the eventual shutdown of their plants, are unwilling to take measures to ensure that the public is protected. (AT-N43)

Response: The NRC has stated in its regulations:-"The Commission has made a generic determination that,,if necessary,spent fuel generatedin any reactorcan be storedsafely and without significant environmentalimpact for at least 30 years beyond the licensed life for operation (which may include the term of renewed license) of that reactorat its spent fuel storagebasin or at either onsite or offsite independent fuel-storage installations."-Further,-the 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 reactor to dispose of the commercialhigh-level waste and spent fuel originatingin such reactorand generatedup to that time. The evaluation of environmental impacts from the disposalof LLW and spent fuel is outside the scope of the Supplement (see Section 1.3). -.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: There still remains a mountain of radioactive waste after shut down, including the reactor itself and, typically, an incredibly dangerous stockpile of irradiated reactor fuel.

Whereas the reactor itself and the equipment and materials of the central facilities are often treated as the object of decontamination, it must be noted that the previous operation of the plant has dispersed radiation and contamination that did not regard the facility's fence line as a barrier. Anyserious approach to decommissioning a site must take this into account. (CL 4717) ' , - , - I Response: -Nuclearpower facilities were licensed with the expectation that there would be routine releases of detectable radioactivityto the airand water surroundingthe site. Such releases are controlled and limited to levels consideredadequate to protectpublic health and' November 2002 0-193 NUREG-0586 Supplement 1

Appendix 0 I safety. Radiologicalimpacts of releases duringplant operationsare limited by criteriaset forth I in 10 CFR Part20. Offsite remediationdue to routine plant release is not warranted. The I evaluation of environmental impacts from the disposal of LLW and spent fuel is outside the I scope of the Supplement (see Section 1.3). 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.

I Comment: Allowing NRC to determine whether waste can or will remain after a reactor license I is terminated is contrary to the policy of the respective compacts and in direct disregard of the I federal low-level radioactive waste framework established by Congress. (CL-17/9)

I Response: Materialthat could be classified as low-level waste would not be left behind after I license termination. Any radioactivecontaminationleft behind after license termination must I meet the License Termination Criteriagiven in 10 CFR Part20, SubpartE. Materials that I cannot meet these criteriaare considered to be low-level waste and would have to be disposed I of at a licensed low-level waste facility before the license could be terminated. Therefore, any I radioactivematerialremainingonsite after license terminationwould not be considered I radioactive waste. 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: Inherent in the decision to operate the reactors is an acceptance on the part of the I generator and the regulator of the production of long-lasting radioactive waste and radioactive I and chemical contamination of large volumes of resources. Decommissioning should include I responsibly managing that material, not denying its existence. (CL-48/10)

I Response: Although long-term storage of spent fuel and low-level waste is not within the I scope of the Supplement, as described in Section 1.3, NRC is committed to ensuring that both I spent fuel and low-level wastes are managedto prevent detrimentalhealth impacts to the I public. The NRC has stated in its regulations: 'The Commission has made a generic I determinationthat, if necessary, spent fuel generatedin any reactorcan be storedsafely and I without significantenvironmentalimpact for at least 30 years beyond the licensed life for I operation (which may include the term of renewed license) of that reactorat its spent fuel I 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 I repositorywill be availablein the first quarterof the 21st century, and sufficient repository I capacity will be availablewithin 30 years beyond the licensed life for operationof any reactorto I dispose of the commercial high-level waste and spent fuel originatingin such reactorand I generatedup to that time. LLW facilities are sited in areas that are away from surface water I and where the groundwateris located at depths sufficiently beneath the trenches to minimize I nuclide migration. Sites and the surroundingareasare monitored using a system of wells to I determine if there is any leakage of radioactivityinto the groundwater. A combination of natural NUREG-0586 Supplement 1 0-194 November 2002

Appendix 0 site characteristicsand engineeredsafety features is used to ensure the safe disposalof LLW.

In addition, restrictionsof types and amounts of waste disposed of at a site, as well as the analysis performed as part of the licensing to demonstratecompliance with performance objectives in NRC regulations,increase the safety ofLLW disposal. The naturalcharacteristics of an LLW disposalsite are relied on in the long-term, and they should promote disposal-site stability andattenuate the transportof radionuclidesaway from the disposalsite into the I general environment. Sites generally must possess the following characteristics: (1) relatively I simple geology, (2)well-drainedsoils free from frequent ponding or flooding, (3) lack of susceptibilityto surface geologicalprocesses,such as erosion, slumping, and landslides, (4) a water table of sufficient-depth so that groundwaterwill not periodicallyintrude into the waste or discharge onsite, (5),lack of susceptibility to tectonicprocesses, (6) no known potentially, I exploitable naturalresources, (7) limited future populationgrowth ordevelopment, and, (8) capabilityof not being adversely impactedby nearby facilitiesand activities. Engineered barriersare man-made structures designed to improve the naturalsite characteristicsto isolate and contain waste. They consist of various engineeredsystem components, including the following: (1) a layeredearthen cover, (2) a disposalvault, (3) a drainagesystem, (4) waste forms and containers, (5)backfill material,and (6) an interiormoisture barrierand low-permeabilitymembrane. Regulations specify the allowable radiationdose from the LLW facilities to the workers and to the public. 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. , '

Comet .. - - ,*. -" , .F II Comment: Limerick, Oyster Creek, Peach Bottom, Salem, and Three Mile Island are among the nation's nuclear generating stations currently serving as "temporary" repositories for low level radioactive waste. Limerick, Peach Bottom, and Three Mile Island do not meet the standards set by the Appalachian Compact in regards to a permanent LLW facility. (CL-02130)

Response: The NRC has historicallydiscouragedthe use of onsite storage as a substitute for permanent disposal,but has not limited the amount of time that the waste can be stored.

However, LLW is normally stored onsite on an interim basis before being shipped offsite for.:

permanent disposal. Onsite storage facilities are designed to minimize personnelexposure.

High-dose-rateLLW is isolated in a shieldedstorage area andis easily retrievable. The lower I dose-rate LLW is stacked or-storedto maximize packing efficiencies. The NRC has guidelines regardingthe storage facility, including the following: (1) shielding used should be controlledby I dose-rate criteriafor both the site boundary and any adjacent offsite areas and (2)a liquid drainagecollection and monitoring system should be present. The drain should be routed to a I radw'asteprocessing-system.-The regulatioi, related to LLW disposalar6 in, 10 CFR Part61 1 and 10 CFR Part20 Subpart K. The comment did not provide new information relevant to this Supplement and will not be evaluated further.- The -cbmoment did not result in a change to the Supplement. I November 2002 0-195 NUREG-0586 Supplement 1

Appendix 0 I Comment: Anything dumped or buried from the past practices on site must also be dug up and I removed. (CL-20/21)

I Response: The licensee is required to conduct a site characterization study to determine the I location and extent of radioactive contamination. The LTP addresses the issue of onsite buried I waste and soil contamination. Site remediation is addressed by the LTP. 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: YOU CAN'T BURN IT/INCINERATE IT, IT GOES OUT THE STACK AND I POLLUTES THE STACK, YOU CAN'T WASH IT, IT WINDS UP ALL OVER THE PLACE AND I IN THE WATER, IT IS ALWAYS THERE, THE DEADLY, INVISIBLE KILLER. AT MOST YOU I CAN TRY AND CONTAIN IT. (CL-20171)

I Response: Companies licensed to incinerateradioactive waste are regulatedby the NRC and I EPA. Effluents are monitoredand controlledprior to release and limited by NRC and EPA I regulations. 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: None of the mixed-waste should be dealt with as mixed waste (i.e. a combination of I chemical/hazardous and radioactive) because MIXED WASTE FALLS THROUGH ALL I REGULATORY CRACKS, BUT IT SHOULD BE TREATED AS RADIOACTIVE WASTE.

I (CL-20177)

I Response: The disposalof mixed waste falls under NRC regulations(10 CFR Part61, "I "Licensingrequirements for land disposalof radioactivewaste') and EPA regulationsfor I disposalof hazardous waste (40 CFR Part260 through 40 CFR Part270). Offsite disposalof I mixed waste is outside the scope of the Supplement. The comment did not provide new I information relevant to this Supplement and will not be evaluatedfurther. The comment did not I result in a change to the Supplement.

I Comment: WASTE OILS SHOULD NOT BE SENT TO VENDORS FOR INCINERATION OR I RECYCLING OR REUSE AS THEY ARE CONTAMINATED. (CL-20/78)

I Response: Contaminatedwaste oil will be dealt with in an appropriatemanner consistent with I NRC and EPA regulations. Offsite disposalof LLW is outside the scope of the Supplement.

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.

NUREG-0586 Supplement 1 0-196 November 2002

Appendix 0 Comment: One of the things that has to be acknowledged I think or anticipated is the failure of the United States nuclear waste program on all levels, so that low-level dumps are not getting established, high-level dumps are not getting established. Therefore, we may really have to keep a lot more of this radiation on site than we had anticipated. (AT-G/2)

Comment: No facility exists for the permanent disposal of the nation's high-level waste' (irradiated reactor fuel), and only one burial site, in Barnwell, SC, is currently available to most, reactors for the rest of their wastes (their so-called "low-level" wastes, which ultimately could include the rubble and dismantled components from decommissioned plants). That one '"low level" waste facility however, that is serving most of the nation,- is expected to be closed in the near future to non-Southeast-United States reactors. (CL-51122)

Response: The NRC has stated in its regulations: 'The Commission has made a generic determination that, if necessary, spent fuel generatedin any reactorcan be storedsafely and .

without significant environmentalimpact for at least30 years beyond the licensedlife 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 Commission believes there is reasonableassurance that at least one mined geological repository will be availablein the first quarterof the 21st century, and sufficient repository capacity will be available within 30 years beyond the licensed life for operation of any reactorto dispose of the commercial high-level waste and spent fuel originatingin such reactorand generated up to that time. LLW facilities are sited in areasthat are away from surface water and where the groundwateris located at depths sufficiently beneath the trenches to minimize nuclide migration. The naturalcharacteristicsof an LLW disposal site are relied on in the long term, and they shouldpromote disposal-sitestability and attenuate the transportof radionuclidesaway from the disposalsite into the generalenvironment.- Sites generallymust possess the following characteristics: (1) relatively simple geology, (2) well-drainedsoils free from frequent ponding or flooding, (3) lack of susceptibilityto surface geologicalprocesses, such as erosion, slumping, and landslides, (4) a water table of sufficient depth so that groundwaterwill not periodicallyintrude into the waste-or discharge onsite, (5) lack of, susceptibilityto tectonic processes, (6) no known potentially exploitable naturalresources, (7) limited future populationgrowth or development, and (8) capability of not being adversely impacted by nearby facilities and activities. Engineeredbarriersare man-made structures designed to improve the naturalsite characteristicsto isolate and contain waste. They consist of various engineeredsystem components, including the following: (1) a layeredearthen cover, (2) a disposalvault, (3) a drainagesystem, (4) waste forms and containers, (5) backfill material,and (6) an interiormoisture barrierand low-permeabilitymembrane. Regulations, specify the allowable radiationdose from the LLW facilities to the workers and to the public.

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.

November 2002 0-197 NUREG-0586 Supplement 1

Appendix 0 I 0.4.4 Spent Fuel Maintenance, Storage, and Disposal I Comment: I find nothing in this thick document where [it] addresses at all the generic, or under I generic or site-specific issues the impact and the effects on the structure, systems and I components of an event which happens during decommissioning. And, of course, the I radioactive fuel pools are the principle source in that case of radioactive contamination. (AT I F/3)

I Response: Section 4.3.9 addressesaccidentanalysis, including those involving the spent fuel I pool. Details of potentialaccidents are in Appendix L 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: The Draft says, p.1-6, that NRC and the Commission are not considering the issue I of spent fuel storage (in a pool or in one of those ridiculous casks outside in plain view for every I terrorist to see) as part of decommissioning. The excuse is that its dealt with under other I license aspects. (CL-20/25)

I Response: The commenter is correctin noting that the issue of spent fuel storageis outside I the scope of this Supplement for reasons discussedin Section 1.3, "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: It also says that the Commission has made a finding that the DEADLY, I RADIOACTIVE SPENT FUEL BE STORED SAFELY AND WITHOUT SIGNIFICANT I ENVIRONMENTAL IMPACTS FOR AT LEAST THIRTY YEARS BEYOND THE LIFE FOR I OPERATION ETC. ETC. (CL-20/26)

I Comment: [In addition to the economic gash in the GElS portal, this fatally flawed document I does not adequately address, acknowledge, account for, or compute a number of significant I barriers related to radiological decommissioning; including:]Spent Fuel Isolation. (CL-02/5)

I Comment: When California's nuclear plants received licenses for construction and operation, I promises were made that high-level radioactive waste would be removed within a few years.

I Every deadline to open a safe and permanent repository for high-level radioactive waste has I been missed. Therefore, the issue has grown; we are not accessing only the decommissioning I of a power plant, but dealing also with storage and transportation of lethal substances I unforeseen when licenses were granted. (CL-53/4)

I Comment: One of the things it (the 60 year period) presumes is that there's going to be a I viable option for removing the spent fuel from the site. And I'm just wondering if anybody could NUREG-0586 Supplement 1 0-198 November 2002

Appendix 0 talk a little bit about the relationship there, because I am one of many people who believe that.

Yucca Mountain is not a foregone conclusion, although probably that is not your view here, but there is significant opposition to it from some rather more powerful actors than us in the State of I Nevada. (SF-B/5)

Comment: Can the Commission identify a pragmatist, physicist, chemist, policy analyst, or behavioral scientist who is willing to testify that radiological decommissioning can be achieved with the fate of Yucca Mountain in perpetual limbo and the three current "low-level" radioactive I waste facilities limited by finite capacity and geopolitical considerations? (CL-02/13)

Comment: Spent fuel "disposal" is an unresolved and hugely problematic area. Each reactor I produces approximately 20 to 30 tons of high-level radioactive waste per year. There is presently, and at least until 2010, nowhere to put this waste. The technology to safely manage I spent fuel for an indefinite period of time does not exist. There is no location to permanently I store spent fuel and high-level radioactive waste (HLW) generated by nuclear power plants.: - I (CL-02/21)

Comment: Aggravating the critical shortage of HLW storage space is the bleak estimate for, I the completion of Yucca Mountain, the designated repository for high-level nuclear waste. The ,1 earliest date thisrepository could be available-is 2010. Lynn M.-Shishido-Topel served as the I Overseeing Commissioner of the Illinois Commerce Commission testified, also predicted that. I the amount of spent fuel generated by 2000 will be 40,000 metric tons (MTU). This amount of I waste would exceed Yucca Mountain's capacity, and the State of Nevada has demonstrated I that Yucca Mountain will probably hold about 20%'of the total 85,000 MTU of spent fuel earmarked for the facility. (CL-02/23) Z 1 Comment: Isolation of high-level radioactive waste, which is primarily composed of spent fuel, I can not be separated from radiological decommissioning. The earliest Yucca Mountain will be I available is in the year 2010. Nuclear generating stations can not be decommissioned or,'

decontaminated with the presence of HLW onsite or inside the reactor ves~sel. Aggressive '1 decontamination process will be precluded, necessit&ting utilities to place retired reactors into I extended-DECON or SAFSTOR. Ifa long-term solution to spent fuel isolation is not found in . I the immediate future, some of the nation's nuclear generating stations will b6 shut down prematurely due to an- absence of spent fuel storagecapacity. (CL-02/26)

Comment: It ought to be equally obvious that a satisfactory waste isolation solution evades us I (we do not agree With Secretary Abraham that Yucca'Mountain is-a suitable repository based I on science - the DOE itself admits that the site is not geologically suitable and the GAO raises 'I serious questions about the selection process). (CL-42/2) -

November 2002 0-199 NUREG-0586 Supplement 1

Appendix 0 I Response: Although long-term storage of spent fuel is not within the scope of the Supplement, I as describedin Section 1.3, "Scope of This Supplement," NRC is committed to ensuring that I both spent fuel and low-level wastes are managed to prevent detrimentalhealth impacts to the I public. The NRC has statedin its regulations: 'The Commission has made a generic I determinationthat, if necessary,spent fuel generatedin any reactorcan be stored safely and I without significant environmental impact of at least 30 years beyond the licensed life for I operation (which may include the term of renewed license) of that reactorat its spent fuel I 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 I repository will be available in the first quarterof the 21st century, and sufficient repository I capacity will 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 reactorand I generated up to that time. The comments do not provide new information relevant to this I Supplement and will not be evaluated further. The comments do not result in a change to the I Supplement.

I Comment: I probably have a question in there because I wasn't sure, reading through the I document itself, where, like the outdoor storage facilities at Plant Hatch and elsewhere-how I they are dealt with after the plant itself is decommissioned and if the license is terminated. I'm I not sure how that works and who's responsible and I would like more clarification on that.

I (AT-A/1 6)

I Response: Both operatingplants and plants that have permanentlyceased operationsand are I decommissioninghave the option to store theirspent fuel in dry cask storage outside on a I specially constructedconcrete pad. The facility is called an Independent Spent Fuel Storage I Installationor ISFSI. An ISFSI can be constructedand operatedeither under the same I licensee that is used for an operatingor decommissioning facility (calleda "Part50 license"in I reference to the location in the Code of FederalRegulations that describes the license require I ments) or under a site-separatelicense (calleda "Part72 license"in reference to the location in I the Code of FederalRegulations that describes the licensingrequirements for the ISFSl).

I Licensing the ISFSI separately under Part72 license allows completion of the decommissioning I of the power reactorand its associatedstructures,systems andcomponents while retaininga I license for the ISFSI. The comment did not provide new information relevant to this I Supplement and will not be evaluatedfurther. The comment did not result in a change to the I Supplement.

I Comment: Furthermore, some nuclear plants, like Hatch have overflowing volumes of nuclear I waste that are now being stored outdoors which impacts the environment and could affect I decommissioning. (AT-A/25)

NUREG-0586 Supplement 1 0-200 November 2002

Appendix 0 Comment: Some hucle,-r plants, like Hatch,'have overflowing volumes of nuclear waste that are now being stored outdoors which impacts the environment and could affect decommissioning. (CL-0817)

Response: Some of the spent fuel at Hatch is storedin an ISFSl located onsite. The ISFSl is I licensed under the provisions of 10 CFR Part50. -The spent fuel at Hatch is stored in' accordance with the regulationsin 10 CFR Part50 and/or 10 CFR Part 72. However, the' I impacts from an ISFSl are outside the scope of this Supplement, as discussedin Section 1.3.

The impacts that an onsite ISFSI might have on decommissioning activities were considered to I be insignificantsince it is an independent facility located some distance from structures, systems or components that are likely to be removed during decommissioningý. The comments I did not provide new informationrelevant to this Supplement and will not be evaluated further. 1 The comments did not result in a change to the Supplement. ' ,I Comment: How will onsite; outdoor nuclear Waste storage dumps,,[also known as Independent I Spent Fuel Storage Installations-ISFSI] like at Plant Hatch; be affected by decommissioning? I How will the licensee of an' ISFSI be impacted by events that may happen during decommis-. I sioning, i.e. what if there is an accident nearby and thecasks are damaged or the site is, 1 rendered inaccessible? (CL-08/27) I Comment: Those issues are of grave concern.'-What happens, if during decommissioning I terrorists take out three spent fuel casks blasting them to kingdom come OR two casks had a I major-problem and needed to be opened under shielding inside the spent fuel pool and there I was either no room in the spent fuel pool or the cask came apart while trying to move it due to I embrittlement of the cask from the radioactive decay heat coming off the spent fuel? I (CL-20/27)

Response: ISFSls are generally located far enough away from structures and systems being I dismantled or demolished during decommissioning that an accident during-decommissiohing would be unlikely to adverselyimpactthe ISFSl. If a cask were to be damagedby some - I means, the licensee would be requiredto dedontaminatethe area and re-secure the spent fuel. I Although difficult, such activity is technically feasible and could be accomplishedrelatively I quickly. -The comments did not provide newlinformationrelevant to this Supplemnent and will not I be evaluated further. The comments did not resultin a change to the Supplement.

Comment: The GElS does not consider the impacts of spent fuel storage.' We'believe this to be based on artificial distinctions. Both Maine Yankee and Haddam Neck have identified establishing an Independent Spent Fuel Storadge Facility as a "critical pathway" in decom missioning. ISFSI construction has been regulated uhder the ver'y same Part 50 license that November 2002 0-201 NUREG-0586 Supplement 1

Appendix 0 I will be terminated upon successful decommissioning. Only then will a Part 72 license be I issued. The ISFSI is in the middle of a decommissioning site and physically inseparable from I decommissioning. Its impacts should be considered among the impacts of decommissioning in I the GElS. (CL-13/18)

I Comment: Nuclear corporations should not be allowed to decommission reactors under an I operating license through a series of amendments nor should they be allowed to create an I Independent Spent Fuel Storage Installation (ISFSI) under an operating reactor license when I they are decommissioning. Decommissioning reactors installing ISFSI's should be required to I go into a Part 72 license to provide adequate regulatory oversight protect public health and I safety. The Part 72 general license provision for creating an ISFSI at an operating reactor was I never intended to cover a decommissioning reactor when regulatory oversight is minimized.

I (CL-50/23)

I Response: Both operatingplants and plants that have permanently ceased operationsand are I decommissioning use ISFSls. ISFSls are not unique to decommissioningplants. The initial I development of the decommissioning regulationsoccurredin the early 1980s. At that time, the I NRC and the industry assumed that by the time facilitiesbegan decommissioning, the I U.S. Departmentof Energy's (DOE)high-level waste repository would be accepting spent fuel I for ultimate disposal. Therefore, spent fuel onsite during decommissioning was not expected to I be an issue. Consequently, development of regulationsrelated to /SFSls occurred separately I from the development of decommissioning regulations. Since the ISFSI may in some cases I remain at the site longer than a nuclear facility that is undergoingimmediate decommissioning, I it is appropriatethat ISFSls be capable of being licensed separately. The decommissioningof I the ISFSI is also handled separatelyfrom the decommissioning of the nuclearpower plant.

I Site-specific ISFSI licenses require the evaluation of the ISFSI separately from the remainderof I the facility although other site activities adjacent to the ISFSI are consideredto evaluate their I impact on the storage of the spent fuel. An ISFSI can be constructedand operatedeither I under the same license that is used for an operating or decommissioningfacility (calleda "Part I 50 license"in reference to the location in the Code of FederalRegulations that describes the I license requirements)or under a site-separatelicense (called a "Part72 license" in reference to I the location in the Code of FederalRegulations that describes the licensing requirements for I the ISFSl. ISFSI licensing, siting, construction and operation are outside the scope of the GElS I on decommissioning (see Section 1.3). The 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: Until the spent rods are removed from local nuclear power plants the I decommissioning rules should be tightened, not loosened. Your proposal may have seemed I reasonable earlier this year but we live in a very different world now. It can no longer be I business as usual at the NRC. (CL-2514)

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Appendix 0 Response: The Supplement provides an assessment of impacts related to the decommissioningprocess. The Supplement does not (1) establish policy, (2) establish or revise regulations,(3) impose requirements,(4) provide relief from requirements, or (5) provide guidance on the decommissioningprocess. The regulations for maintenance andstorage of spent fuel are given in 10 CFR Parts50 and 72 and are summarized in Appendix L 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.

Comment: In the case of plants like Hatch, that have outdoor storage of nuclear waste, the notion of a reduced security force is even more troubling. (AT-A/15)

Response: Nuclear power plants are regulatedunder 10 CFR Part50 during both plant operationand decommissioning. Typically once a plantpermanently ceases operation there is a gradualreduction in security requirementscommensurate with the reduction of risk associatedwith the various structures,systems and components. However,' securityaround the spent fuel pool remains at levels commensurate with those at an operatingnuclearfacility.

The comment did not provide new informationrelevant to this Supplement and will not be evaluated further. The comment did not result in a change to the Supplement.

Comment: The excess storage-I mean the storage in pools, but there's a whole lot setting out in dry casks very vulnerable to whatever comes along, whatever happens. I mean the whole thing is just-I don't know how in the world they're going to deal with it. (AT-D/4)

Response: 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 managedto prevent detrimentalhealth impacts to the public. The NRC has statedin its regulations: "The Commission has made a generic determin- I ation that;if necessary,spent fuel generatedin any reactorcan be storedsafely and without I significant environmentalimpact of at least 30 years beyond the licensed life for operation I (which may include the term of renewed license) of that reactorat its spent fuel storage basin or I at either onsite or offsite independent fuel-storage installations." The comment did not provide I new information relevant to this Supplement and will not be evaluated further. The comment I did not result in a change to the Supplement. I Comment: As early as 1995, concerns about Yucca Mountain's integrity surfaced from I scientists at Los Alamos National Laboratories. 7Dr. Charles Bowman warned that plutonium would remain after the steel casks holding the nuclide dissolved. Plutonium could then migrate I and concentrate. And in February 1999, the scientific peer review panel for Yucca Mountain commissioned by the U.S. Department of Energy (DOE) produced a "highly critical" report.

"The review panel said the model [DOE'S computer model] has so many uncertainties - like the I corrosion rates of waste containers, the area's vulnerability to earthquakes and how climate I November 2002 0-203 NUREG-0586 Supplement 1

Appendix 0 I changes would affect rainfall - that its reliability was limited. In February, 1999, the scientific I peer review panel for Yucca Mountain commissioned by the U.S. Department of Energy (DOE)

I produced a "highly critical" report. 'The review panel said the model [DOE's computer model]

I has so many uncertainties - like the corrosion rates of waste containers, the area's vulnerability I to earthquakes and how climate changes would affect rainfall - that its reliability was limited."

I (CL-02124)

I Comment: A satisfactory waste isolation site evades us. Yucca Mountain is not a suitable I geologic repository based on science - the DOE itself admits that the site is not geologically I suitable; storage canisters will be required to protect the waste from exterior environmental I contamination. Additionally, the GAO raises serious questions about the selection process.

I (CL-46/3)

I Comment: I don't think there is any good way to treat the long-term storage of radioactive I waste. I don't think Yucca Mountain is the answer, for darn sure, for various reasons. Also at I Lawrence Berkeley Lab the group that's the Earth science group has done the study on I groundwater transportation. And I know from some of my associates there that they think it is I not a satisfactory location for long-term storage. (SF-C/5)

I Response: The spent fuel repositoryplanned for Yucca Mountain is the subject of a separate I NRC licensing action. Uncertaintiesof specific parametersare being evaluated at this time and I will ultimately be addressedin the licensing action and the specific documents associatedwith it I at that time. High-level waste disposal is outside the scope of this Supplement, as discussedin I Section 1.3, "Scope of This Supplement." The 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: Furthermore, on October 4, 1999, LeBoeuf, Lamb, Green & MacRae, filed a I complaint alleging a conflict of interest by the Department of Energy in their selection and I awarding of $16 million legal contract to Winston & Strawn. Former general counsel to the I Energy Department, R. Jenney Johnson, in a sworn affidavit, stated: "[A] situation has been I created which an entity [Winston & Strawn] will pass judgment on its own work." (CL-02/25)

I Comment: Years ago, when people spoke of some type of monitored, retrievable spent fuel I storage, they meant monitored, so repairs could be made by remote control if needed, and I retrievable so problems could be addressed. Spent fuel is the stuff that the Department of I Energy has been charged withtrying to contain for approx. 10,000 years removed from the I biosphere. (CL-20/81)

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Appendix 0 Response: High-level waste disposal is outside the scope of this Supplement as discussed in Section 1.3, "Scope of This Supplement." 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 SPENT FUEL IS THE MOST SERIOUS ISSUE THERE IS. ANYONE WHO DOES NOT UNDERSTAND THAT SPENT FUEL CANNOT BE LEFT WHERE IT IS ON SITE, IN POOLS OR ISFSI'S BEYOND A VERY LIMITED NUMBER OF YEARS, BUT MUST BE PLACED DEEP UNDERGROUND, IN A DRY LOCATION, GEOLOGICALLY AS SOUND AS POSSIBLE, MONITORED FOR ETERNITY, DOES NOT UNDERSTAND RADIATION OR THE NUCLEAR ISSUE AND SHOULD NOT BE WORKING FOR THE NRC. NRC MUST SET THE TIME WHEN THE SPENT FUEL SHOULD ALL BE REMOVED OFFSITE AS NO LATER THAN I TWO YEARS AFTER THE LAST CORE OFFLOAD HAS SPENT TEN YEARS INTHE SPENT I FUEL POOL, I.E. FROM SPENT FUEL REMOVED FROM THE REACTOR INTO THE SPENT FUEL POOL AND THEN THE TEN YEAR "COOL DOWN" PLUS TWO YEARS, AFTER WHICH IT MUST BE MOVED. IF SUCH A DEADLINE IS NOT DECIDED, AND SET, COMMUNITIES ARE GOING TO BE STUCK WITH IT, WITH AWFUL CONSEQUENCES.

(CL-20/84)

Response: 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 regulations: "The Commission has made a generic determination that, if necessary,spent fuel generatedin any reactorcan be storedsafely and without significantenvironmental impact of at least 30 years beyond the licensed life 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 Commission believes there is reasonableassurancethat at least one mined geological, repository will be availablein the first quarterof the 21st century, and sufficient repository capacity will be available within 30 years beyond the licensed life for operation of any reactor to dispose of the commercial high-level waste andspent fuel originatingin such reactorand generatedup to that time. The comment proposes limits for the onsite storage of spent fuel.

The Supplement does not (1) establishpolicy, (2) establish or revise regulations,(3) impose requirements, (4) provide relief from requiremrents,-or(5) provide guidance on the decommissioningprocess. 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. I November 2002 0-205 NUREG-0586 Supplement 1

Appendix 0 1 0.4.5 License Extensions I Comment: Likewise, there is no experience in decommissioning nuclear reactors that have I operated beyond the original 40-year license period. (AT-A/26)

I Comment: The NRC has no experience in decommissioning nuclear reactors that have I operated beyond the original 40-year license period. (CL-08/8)

I Response: The commenter is correct. Nevertheless, the NRC is consideringthe I environmentalimpacts of decommissioning following the extended operationduring the renewal I periodand, if appropriate,refurbishmentactivities. License renewal is not within the scope of I this Supplement, as it is a licensing activity covered elsewhere in the NRC regulations (see 1 10 CFR Parts51 and 54) and in other ElSs (see NUREG-1437, its addendum and I supplements). The comments did not provide new information relevant to this Supplement I and will not be evaluated further. The comments did not result in a change to the Supplement.

I Comment: We believe that the decommissioning document has definitely underestimated the I impacts of the additional license extension period. In fact, the minimization of that impact I I think is a major flaw in the document and that there needs to be a reassessment of all of the I impacts, including cost, but also including the aging issues, including the waste issues and I other offsite environmental impacts for license extension periods. (AT-B/8)

I Response: An analysis performed for NUREG-1437, Generic EnvironmentalImpact Statement I for License Renewal of NuclearPlants, indicatedthat the physical requirements and attendant I effects of decommissioning nuclearpower plants after a 60-yearlicense renewal (original40 I year license plus an additional20 years for license renewal) are not expected to differ from I those of decommissioning at the end of 40 years of operation. Section 1.3 was changedfor I clarificationof this information.

I Comment: None should be re-licensed - the NRC should be ashamed of re-licensing.

I (CL-20/116)

I Comment: I am opposed to any extensions on operating licenses for nuclear facilities of any I sort and wish for a mnove to cleaner renewable energy. (CL-4112)

I Response: License renewal is outside the scope of this Supplement. The comments did not I provide new information relevant to this Supplement and will not be evaluated further. The I comments did not result in a change to the Supplement.

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Appendix 0 0.4.6 Site Characterization and Final Site Surveys Comment: Additionally each nuclear power plant has a different historical performance record that may have impacted the surrounding environment in ways that are unique to the facility.

What makes it acceptable to ignore these operating histories when decommissioning?

(AT-A/24)

Response: Licensees are requiredby 10 CFR 50.75(g) to "keep records of information important to the safe and effective decommissioning of the facility in an identified location until the license is terminated." These records include records of spills, etc. Priorto termination of an operating license, the NRC must determine that the terminal radiationsurvey and associated I documentation demonstrate that the facility and site are suitable for release in accordancewith I the criteriafor decommissioning in 10 CFR Part20, Subpart E. Title 10 CFR Part51.53(d) requires that the "Supplement to the Applicant's EnvironmentalReport-PostOperatingLicense I Stage," which must be submitted with the License"Termination Plan, update the "Applicant's EnvironmentalReport- OperatingLicense Stage"to reflect any new information or significant environmental change associatedwith the applicant'sproposed decommissioning activities or I with the applicant'sproposedactivities with respect to the storage of spent fuel. The comment I 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: In order to provide a complete and up-to-date environmental profile of the site, the I Supplement should direct licensees to summarize the following in their site-specific NEPA analyses (and as appropriate in the PSDAR and LTP): (a) pre-plant construction environmental I reports (for plants constructed before the enactment of NEPA) and environmental impact statements (EISs) regarding the impacts of plant construction and operation, (b) environmental I reports and/or assessments that were prepared during the period the plant was in operation regarding the impacts of plant operation, (c) significant requirements and changes in the licensee's environmental permits, and (d) changes in the environmental parameters of a facility site during operation and the impacts of any such changes (see also Response to Comment #6-A, page A-11). (CL-1 6/7)

Response: The purpose of the Supplement is to provide an environmentalanalysis of the impacts associatedwith the decommissioningprocess. The Supplement does not (1) establish I or revise regulations,(2) impose requirements,(3) provide relief from requirements,or (4) ,

provide guidance on the decommissioningprocess. The comment did not provide new information relevant to this Supplement and will not be evaluatedfurther. The comment did not I result in a change to the Supplement.

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