ML19332A381
| ML19332A381 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1980 |
| From: | Calkins G NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| References | |
| NUREG-0436, NUREG-0436-R01-S01, NUREG-0436-S01, NUREG-436, NUREG-436-R1-S1, NUREG-436-S1, NUDOCS 8009110639 | |
| Download: ML19332A381 (33) | |
Text
7 NUREG-0436 Revision 1 Supplement 1 Plan for Reevaluation of NRC Policy on Decommissioning of Nuclear Facilities
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MInuscript Completed: July 1980 D:te Published: August 1980 G. D. Calkins Division of Engineering Standards Office of Standards Development U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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ABSTRACT This report supplements and updates the information presented in NUREG-0436, Rev.1, of the same title and dated December 1978.
Supplement 1 defines new terminology for the decommissioning alternatives.
It updates the status and schedules for developing the information base, the draft generic environmental impact statement, and the rulemaking.
In addition, sched'Jles for regulatory guides to support the rules are presented.
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iii e
NUREG-0436, Revision 1, Supplement 1 TABLE OF CONTENTS P39*
Foreword' vii 1.0 Introduction 1
2.0 Terminology 1
2.1 Definition of Decommissioning 1
' 2. 2 Definitions of Decommissioning Alternative 1
.3.0 Information Base 1:
3.1 General 1
3.2 Reactors 4
3.3 Fuel Cycle and Non-Fuel Cycle Nuclear. Facilities 4
3.4 Supporting Information 4
4.0 Rulemaking
-4 4.1 State Workshops 5
4.2 Environmental Impact Statement 5
4.3 Policy Statement and Proposed Rules 5
5.0 Regulatory Guides 6
6.0 Schedules 7
7.0 References 22 V
NUREG-0436, Revisien 1, Supplement 1 FOREWORD TO SUPPLEMENT 1 The information in this report, including any comments, will be placed in record for consideration by the Commission in establishing criteria and new standards for decommissioning.
Persons wishing to comment on this report should mail their comments to:
Decommissioning Program Manager Div'sion of Engineering Standards Office of Standards Development Washington, D.C.
20555 I
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NUREG-0436, Ravision 1, Supplement 1
- 1. 0 Introduction This reevaluation plan for decommissioning was published first in March 1978 and then revised in December 1978.
The purpose of this supplement is to present some new information, summarize the status of the program and update the schedules.
2.0 Terminology Some confusion and misunderstanding has resulted from the variation of terminology used in the decommissioning field.
For example, the words decommission, decontaminate and dismantle have been used interchangeably for the decommissioning alternative consisting of the immediate removal of all radioactive material to permit unrestricted release of the property.
The word dismantlement has been used to describe decontamination activities that involve no actual dismantlement.
Similarly, the words safe storage, pro-ter.tive storage, lay away, mothball and temporary intombment have been used to naae the alternative of decommissioning consisting of placing and maintaining property safely in storage as a precursor to final decommissioning.
In the interest of ending the cc fusion it appears desirable to strictly define decommissioning and the n.a.ior alternatives for accomplishing it.
Furthermore the use of pseudoacronyms for the alternatives avoids words which may have several meanings.
2.1 Definition of Decommissioning Decommission means to remove the property safely from service and dispose of the radioactive residue.
2.2 Definitions of Decommissioning Alternative DECON means to immediately remove all radioactive material to permit unrestricted release of the property.
SAFSTOR means to fix and maintain property so that risk to safety is acceptable for period of storage followed by decontamination and/or decay to an unrestricted level.
ENTOMB means to encase and maintain property in a strong and structurally long-lived material (e.g., concrete) to assure retention until radioactivity decays to an unrestricted level.
3 3.0 Information Base Considerable progress has been made in compiling the information base needed to support rulemaking, see Schedules for Objectives A, B, C and D.
3.1 General (See Schedule, Objective A)
A bibliography 1 and review of regulations 2 were completed earlier.
Now draft staff reports on the very important topics of financial assurance 3 and acceptable radioactive residues
'S have been done.
Two of these draft reports 4
have been widely circulated withia and outside NRC to accumulate preliminary t--_----___
r NUREG-0436, Rsvision 1, Supplement 1 comments.
Also, a contractor report on financing strategies for decommis-6 sioning has been completed.
A separate study has been initiated on the 7 of technology and costs of terminal radiation surveys.
Preliminary results this important study have been published.
3.1.1 Financial Assurance Three basic approaches, used singly or in combination, to implement financial assurance appear satisfactory based on the preliminary staff evalua-and the contractor report.6 tion 3 1.
Prepayment.
Cash or other liquid assets that will retain their value for the projected operating life of the facility may be deposited into a segregated account prior to facility startup.
Prepayment will probably be the only satisfactory alternative to cover costs involving long-term surveillance.
2.
Sureties.
Bonds, letters of credit and lines of credit that guarantee that the costs will be paid may be used.
It appears questionable that bonds of the size and for the time ($50 million for 40 years) involved with power reactors will be available.
However, they appear to be avail-able for facilities that involve smaller costs and periods.
3.
Sinking Funds and Insurance. The sinking fund or funded reserve requires a prescribed amount of funds, subject to annual revision, be set aside annually such that the fund plus accumulated interest would be sufficient to pay for the costs at the time of decommissioning.
The weakness of the sinking fund approach is that in the event of premature shutdown the decommissioning fund would be insufficient. Therefore, the sinking fund would have to be supplemented by insurance which would pay the difference.
There is some indication that such insurance could be made available.3 Some reviewers, mainly associated with nuclear power plants, of the above approaches to financial assurance have voiced concern that the options of an unsegregated sinking fund, negative salvage, or payment at the time of decommis-sioning are not included.
Their major argument is that the options selected are more expensive. While this is true, none of the options significantly increase the cost to consumers.
Decommissioning increases the cost of nuclear power to consumers by approximately 2 to 5 percent. While a segregated sinking fund may be twice as expensive as payment at the time of decommissioning, it 6
is not significantly more costly to consumers.
3.1.2 Radioactive Residues Discussions with the staff at EPA relative to acceptable radioactive residue limits indicate that:
I 1.
potential doses from decommissioned facilities should be less than those I
from operating ones.
2.
doses (whole body equivalent) above 5 mrem per year are probably unacceptable, 2
1
-)
NUREG-0436, Revision 1, Supplement 1 3.
justification would be required for doses more than 5 mrem per year, and 4.
a plan for complying with the criteria could utilize realistic rather than conservative pathway analysis.
Realistic analyses involve recognition that occupancy is less than 100 percent of the time, that the source of sustenance is not limited only to the decommissioned site, that self shielding reduces the dose and that resuspension is decreased by. weathering as a function of time.
As consideration of the application of the above criteria to various nuclear facilities has progressed, it has become clear that the dose range is more prac-tical than specific dose.
For some nuclide mixes and facilities it may be imprac-tical and unnecessary to meet the 5 mrem per year criteria.
It appears that a goal for the release of decommissioned property on an unrestricted basis should be for potential exposure to an individual as low as reasonably achhaable in the range of 1 to 10 mrem per year.
Reviawers of this proposed goal have expressed concern that radiation cannot
- b. detected at that level or that it would be prohibitively expensive to make measurements at that level.
These concerns do not seem to be well founded as shown below:
Recent preliminary work 7 has been completed at ORNL on the terminal radia-tion survey for the case of the decommissioning an 1175 MWe PWR. This study shows that the technology is readily available to make a statistically-designed, terminal radiation survey with a reasonable degree of confidence and at a moderate cost, less than $250,000 at the 5 mrem per year level.
This cost represents only a fraction of a percent of the total cost of decommissioning a large reactor.
Furthermore, it indicates that the cost at a release level of a dose of 25 mrem per year is only about 10 percent less than the 5 mrem per year case.
It was found that the cost at a release level of a dose of 1 mrem per year would be extremely high and not easily estimated In addition, a historical review shows that in the 1960's that written criteria for acceptable levels of radioactive residuals for the release of decommissioned property did exist and were utilized.8'8 The criteria were based on a goal of a limiting exposures to a few percent of the radiation pro-tection standard of 500 mrem per year in uncontrolled areas.
Such radiation rates are similar to those expressed as a dose of 1-10 mrem per year.
Unfortunately, it was decided in 1973 to drop the written criteria and go on a case-by-case basis for the release of property.8 This lack of written criteria resulted in confusion and inconsistency which still continues.
In 1974, guidance for termination of reactor licenses was issued, Regula-tory Guide 1.86,10 but the release criteria were limited to surface contamina-tion. These criteria would produce a dose similar to the 1-10 mrem per year suggested here.
In summary, criteria similar to those suggested here have been used exten-sively over an extended period of time without undue hardship on parties decom-missioning nuclear facilities. The technology for making measurements at this required level appear to be available at moderate cost.
3
NUREG-0436, Revision 1, Supplement 1 3.2 Reactors (See Schedule, Objective B)
The basic report on technology, safety and costs of decommissioning a PWR11 was published earlier.
This has row been supplemented by an addendum12 which provides sensitivity information as a function of reactor size.
A similar report, containing the basic information and a sensitivity study, has now been completed for a BWR.14 The BWR report was nearly 9 months later than planned, and this has delayed the overall program.
The contractor produced a highly detailed report at the expense of the schedule.
Also, a study was completed on the facilitationta of the decommissioning of light water reactors.
Work is now underway on a study of the decommissioning of multiple reactor facilities.
This will clarify differences in the safety and costs for stations with up to 10 reactors as compared to a single reactor in the completed studies.
Another study has been initiated on research and test reactors, and a report is planned on reactors that have been involved in accidents.
3.3 Fuel Cycle and Non-Fuel Cycle Nuclear Facilities (See Schedule, Objective C)
The study of the decommissioning of a fuel reprocessing plant 15 was com-pleted earlier.
Information appropriate to uranium tailings became available in the environmental impact statement for mills.16 Reports have now been done on small mixed oxide fabrication plants 17 and low level waste burial grounds.18 The study of a uranium fuel fabrication plant 19 is nearly completed and one on a uranium hexafluoride conversion plant has been initiated.
Work is also underway on non-fuel cycle nuclear facilities.
This will deal with some of the more significant problems in decommissioning facilities involved in handling source and by product materials for research, medical and industrial uses of radioactive materials.
3.4 Supporting Information (See Schedule, Objective D)
Reports were completed on the feasibility of recycling metals from decom-missioned facilities.20,21 Work has been initiated on three important research tasks which will provide information in the future to improve decommissioning activities:
(1) long lived activation products in reactor materials, (2) char-acterization of radionuclide contamination throughout LWR's, and (3) decontami-nation as a precursor to decommissioning LWR's.
d 4.0 Rulemaking (See Schedule, Objective E)
Major progress has been made in the development of the general policy and rules on decommissioning.
i A
NUREG-0436, R@ vision 1, Supplement 1 4.1 State Workshops Another set of regional workshops on decommissioning was held in Septem-ber 1979 to assure the input of state. officials-to the decommissioning plan.23 i
i These.were a follow-up to those held in September 1978.22 The major impact from these workshops on the program resulted from the first set.
This impact is described in earlier versions of this report (NUREG-0436, Revision 1, Decem-ber 1978).
4.2 Environmental Impact Statement The initial approach to completing the draft generic environment impact statement, DGEIS24, was to utilize contractor assistance as much as possible.
Because the statement is highly policy oriented, the contractor was unable to provide as much assistance as had been hoped.
As a result the staff has had to rewrite most of the document and will send it out for a second NRC internal office review.
This, together with the late BWR report, Section 3.2, has resulted in an overall schedule slip of 10 months.
The current status is that the working paper of the DGEIS will be circu-lated for internal review in July 1980.
Then, comments will be resolved and the document will be issued for public comment in September 1980.
4.3 Policy Statement and Proposed Rules (See Schedule, Objective E)
Collectively the studies and evaluations discussed above suggest that all nuclear facilities will require consideration in rulemaking revisions on decom-missioning.
Current regulations cover the requirements and criteria for decom-missioning in only a limited fashion.
For many types of nuclear facilities the rules are mute.
The rulemaking for decommissioning could be accomplished as a separate part of NRC's regulations.
However, the proposed action would directly affect licensing activities under Parts 30, 40, 50 and 70 of Title 10 of the Code of Federal Regulations (10 CFR).
This implies that amendments to the separate parts rather than a separate new part would be less disruptive of existing pro-cedures and processes.
In the light of the complexity of this rulemaking it appears desirable to issue first a policy statement covering the proposed actions scheduled for publication in May 1981.
This would then be followed by the proposed amendments to the various rules in September 1981 and the effective rules in September 1982.
In preparation for these activities, the decommissioning staff at NRC has 2s prepared a draft paper which summarizes their preliminary thoughts on regula-tory changes for decommissioning.
This was done to stimulate participation by the NRC staff broadly, the public, industry, the states and other government agencies.
The first version of this paper was prepared for the State workshops in September 1979.
It was revised and updated in December 1979 and, most recently, in July 1980 mainly to reflect the information given here in Sec-tion 2.0 on terminology, Section 3.1.1 on financial assurance and Section 3.1.2 on radioactive residues.
5
I NUREG-0436, Revision 1, Supplement 1 I
Actions separate from this plan are already underway in reference to 18 and low level waste decommissioning of uranium mills and mill tailings burial grounds (CFR Part 60).
5.0 Regulatory Guides (See Schedules, Objectives F and G)
A number of regulatory guides have now been planned to support the proposed amendments to the rules.
Work has already been initiated on some of these.
This includes separate guides for reactors and for fuel cycle facilities on (1) format and content for decommissioning plans, (2) financial assurance plans, (3) residual radioactivity levels at decommissioned sites, and (4) definition of decommissioning modes and methods.
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NUREG-0436, Revisien 1, Supplement 1 6.0 Schedules 7
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- 6. LICENSE TERMINATION AND C
CLOSE OUT SURVEYS FOR 3
MISCELLAN EOUS MATERIAL LICENSES C= ISSUED FOR COMMENT A= SCHEDULED F -FIN AL ISSUE A= COMPLETED
DECOMMISSIONING PLAN OBJECTIVE G (CONT,D): PREPARE REGULATORY GUIDES FOR DECOMMISSIONING FUEL CYCLE AND NON-FUEL CYCLE NUCLEAR FACILITIES FY'80 F Y '81 FY '82 MILESTONES 0
N 0
J F M A M J
J A
S 0
N O
J F
M A M J
J A
S 0
N D
J F
M A M J
J A
S
- 4. FORMAT AND CONTENT FOR C
F
^
DECOMMISSIONING PLANS FOR 3
FUEL CYCLE FACILITIES
- 5. DEFINITION OF DECOMMISSION-ING MODES AND METHODS FOR O
U NON-FUEL CYCLE FACILITIES (EQUlVALENT TO REG.
GUIDE 1.86)
O
- 6. LICENSE TERMINATION AND C
CLOSE OUT SURVEYS FOR S
MISCE LL ANEO US MATE RIAL LICENSES i
i C= ISSUED FOR COMMENT A= SCHEDULED F= FIN AL ISSUE A= COMPLETED
NUREG-0436, Revision 1, Supplem nt 1 7.0 References 1.
G. J. Konzek and C. R. Sample, Decommissioning of Nuclear Facilities -
An Annotated Bibliography.
NUREG/CR-0131 Pacific Northwest Laboratory for U.S. Nuclear Regulatory Commission, September 1978.*
2.
A. H. Schelling, et al., Decommissioning of Nuclear Facilities - A 4
Review and Analysis of Current Regulations.
NUREG/CR-0671, Pacific Northwest Laboratory for U.S. Nuclear Regulatory Commission, August 1979.*
\\
3.
Robert S. Wood, Draft Assuring the Availability of Funds for Decommissioning Nuclear Facilities, U.S. NRC, NUREG-0584, Revision 1, November 1979.**
4.
Enrico F. Conti, Draft Residual Activity Limits for Decommissioning Nuclear Facilitie_s, U.S. NRC, NUREG-0613, September 1979.""
5.
M. W. Young and R. F. Eckerman, A Methodology for Calculating Residual Radioactivity Levels Following Decommissioning, U.S. NRC, NUREG-0/0/,
to be published in August 1980.
6.
Financing Strategies for Nuclear Power Plant Decommissioning, NUREG/CR-1481, Temple, Barker and Sloane, Inc. for U.S. Nuclear Regulatory Commission, June 30, 1980.*
7.
H. W. Dickson, et al., Progress Report on Monitoring for Compliance with Decommissioning Criteria, ORNL/HASRD-78, Oak Ridge National Laboratory for U.S. Nuclear Regulatory Commission, May 1980.***
8.
Utilization of Excess and Disposal of Surplus Personal Property (Handbook), Appendix 5170, U.S. Atomic Energy Commission, September 20, 1963.***
9.
Letter to Managers and Heads of Offices from Director, Division of Operation Safety, Subject "Real Property - Radiation Contamination Clearance," U.S. Atomic Energy Commission, January 15, 1973.***
10.
Termination of Operating Licenses for Nuclear Reactors, Regulatory Guide 1.86, U.S. Nuclear Regulatory Commission, June 1974.
11.
R. I. Smith, G. J. Konzek and W. E. Kennedy, Jr., Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station, NUREG/CR-0130, Prepared by Pacific Northwest Laboratory for U.S. Nuclear Regulatory Commission, June 1978, 12.
R. I. Smith and L. M. Polentz, Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station, Prepared by Pacific Northwest Laboratory for the U.S. Nuclear Regulatory Commission, Addendum to NUREG/CR-0130, August 1979.
- 13.
H. D. Oak, et al., Technology, Safety, and Costs of Decommissioning a Reference Boiling Water Reactor Power Station, NUREG/CR-0672, Prepared by Pacific Northwest Laboratory for U.S. Nuclear Regulatory Commission, June 1980.*
l 22
o NUREG-0436, Revision 1, Supplement 1 l
- 14. Emmett B. Moore, Jr., Facilitation of Decomissioning of Light Water Reactors. NUREG/CR-0569, Pacific Northwest Laboratory for U.S. Nuclear Regulatory Commission, December 1979.*
15.
K. J. Schneider and C. E. Jenkins, Technology, Safety and Costs of Decommissioning a Reference Nuclear Fuel Reprocessing Plant, NUREG-0278, Prepared by Pacific Northwest Laboratory for U.S. Nuclear Regulatory Commission, October 1977.*
16.
Draft Generic Environmental Impact Statement on Uranium Milling, U.S.
NRC, NUREG-0511, April 1979.""
17.
C. E. Jenkins, E. S. Murphy and K. J. Schneider, Technology, Safety and Costs of Decomissioning a Reference Small Mixed Oxide Fuel Fabrication Plant. NUREG/CR-0129, Prepared by Pacific Northwest Laboratory for U.S. Nuclear Regulatory Commission, February 1979.*
18.
E. S. Murphy and G. M. Holter, Technology, Safety and Costs of Decommissioning a Reference Low-Level Waste Burial Ground, NUREG/CR-0570, Prepared by Pacific Northwest Laboratory for U.S. Nuclear Regulatory Commission, June 1980.*
19.
H. R. Elder and D. E. Blahnik, Technology Safety and Costs of Decommissioning a Reference Uranium Full Fabrication Plant, NUREG/CR-1266, Pacific Northwest La'boratory for U.S. Nuclear Regulatory Comission, to be published in September 1980.
20.
F. R. O'Donnell, et al., Potential Radiation Dose to Man from Recycle of Metals Reclaimed from a Decommissioned Nuclear Power Plant, ITiTt.G/CR-0134, Oak Ridge National Laboratory for U.S. Nuclear Regulatory Cemission, June 1979.
- 21.
Draft Environmental Impact Statement on Feasibility of Recycle of Metals from Enrichment Plants, NUREG/CR-0518, U.5. Nuclear Hegulatory Commission, to be published in 1980.
22.
Conferen.:e Proceedings for the State Workshops for the Review of the U.S. Nuc 9ar Regulatory Commission's Decommissioning Policy, U.S. NRC, NUREG/CP-J003, December 1978.
- 23.
Conference Proceedings for the State Workshops for the Review of the U.$. Nuclear Regulatory Commission's Decommissioning Policy, U.S. NRC, NUREG/CP-0008, November 1979.
- 24.
Draft Generic Environmental Impact Statement or Decommissioning Nuclear Facilities, U.S. NRC, NUREG-J586. To be published about September 1980.
25.
G. D. Calkins, Draft Report on Thoughts on Regulation Changes for Decommissioning, NUREG-0590, Revision 2. U.S. Nuclear Regulatory Commission, August 1980.**
- Available for purchase from the NRC/GP0 Sales Program, U.S. Nuclear RegQlatory Commission, Washington, DC 20555, and the National Technical Information Service, Springfield, VA 22161.
- Available free upon written request to the Division of Technical Information and Document Control, U.S. Nuclear Regulatory Comission, Washington, DC 20555.
- Available in the NRC Public Document Room for inspection and copying for a fee.
23
o o
e NRC roRu 336
<?,,,
u.s. NUCLE AR REGULATORY COMMISSION
- 1. REPORT NUMSE R (Assignedby DOCl BIBLIOGRAPHIC DATA SHEET NUREG-0436, Rev. 1 Supplement 1
- 4. TITLE AND SUBTITLE (Add Volume No., d yperwnare/
- 2. (Leave etan&J Plan for Reevaluation of NRC Policy on Decotanissioning of Nuclear Facilities
- 3. RECIPIENT'S ACCESSION NO.
i
- 7. AUTHORtSI
- 5. DATE REPORT COMPLETED C. D. Calkins
" N7" I*'#"
July 1980 9 PERFORMING ORGANIZATION NAME AND MAILING ADDRESS //nclude l<p Code /
DATE REPORT ISSUED MONTH Office of Standards Development l YEAR Aunust loan U.S. Nuclear Regulatory Commission 6.(teeve unna)
Washington, D. C.
20555
- 8. (Leave blanki
- 12. SPONSORING ORGANIZATION NAME AND' MAILING ADDRESS (Include 2,0 Codel Office of Standards Development 10 PROJECT / TASK / WORK UNIT NO.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- 11. CONT R ACT NO.
- 13. TYPE OF REPORT PE RioD COVE RE D (inclustre deres)
Staff Report Dec. 1978 to July 1980
- 15. SUPPLEMENTARY NOTES 14 lleav8 d "*)
- 16. ABSTR ACT (200 words or less!
This report supplements and updates the information presented in NUREG-0436, Rev. 1, of the same title and dated December 1978. Supplement 1 defines new terminology for the decommissioning alternatives. It updates the status and schedules for developing the information base, the draf t generic environmental impact statement, and the rulemaking. In addition, schedules for regulatory guides to support the rules are presented.
17 AEY WORDS AND DOCUMENT AN ALYSIS 17a OESCRIPTORS Iili IDE N TIFif RS OPE N ENDED 1E RMS
21 NO OF PA(JS Unclnnnified
' Unlimited 20 SECUmT Y CL ASS (Thes pv; 22 PWCE Unclassified s
NRCfOHU 335 47 77)
.___