ML20045F209

Comment on Proposal Re Radiological Criteria for Decommissioning NRC-licensed Facilities.Supports Proposed Criteria

ML20045F209
Person / Time
Site:	Saint Lucie
Issue date:	06/24/1993
From:	Ken Wilson FLORIDA POWER & LIGHT CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-57FR58727, RULE-PR-20 57FR58727-00068, 57FR58727-68, NL93-0048, NL93-48, NUDOCS 9307070092
Download: ML20045F209 (4)

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t)f "93 X -# P 5 :05 Florida Power CORPORATION June 24, 1993 NL93-0048 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention Docketing'and Services Branch

Dear Mr. Chilk:

Florida Power Corporation (FPC) would like to provide the following suggestions regarding the Enhanced Participatory Rulemaking process the NRC is conducting on the " Radiological Criteria for Decommissioning of NRC-Licensed Facilities":

1. Florida Power Corporation endorses the Heal th Physics Society Position Statement on Site Cleanup and Restoration Standards. The Health Physics Society Position Paper basically endorses the national and international recommendations of the NCRP and ICRP, as applied to Site Cleanup and Restoration Standards.

The national standard should be based on a 100 mrem /y upper dose limit (excluding Radon) for the critical population group, complemented by an ALARA requirement.

Specifically, we note:

- ICRP-60, Paragraphs 144 and 145: Recommends use of dose constraints on source-related values fixed at the national or local level.

- ICRP-60, Paragraph 186: Recommends use of the mean dose to the critical group from the source for which the protection is being optimized. NOTE: ICRP-26, paragraph 85, and ICRP-43, para-graph 15, further define the critical group. ICRP-46 discusses

" Radiation Protection Principles for the Disposal of Solid i Radioactive Waste."

70 092 930624 20 57FR58727 PDR A Florida Progress Company

I 4 Mr. Samuel J. Chilk Page 2 June 24, 1993 '

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- ICRP-60, Paragraphs 191 and 192: Use of a 100 mrem per year dose limit approach (in lieu of a dose goal approach).

- NCRP-ll6, Page 47: Reaffirmation of previous (NCRP-91) recommen-dations for use of a 100 mrem /y limit, with.a provision that if any single site was expected to contribute more than 25 percent of the (100 mrem /y) dose limit, the site operator should ensure-that the annual exposure of the maximally exposed individual, from all man-made sources, does not exceed 100 mrem /y.

2. The NRC regulations should allow licensees the flexibility to use any decommissioning option which meets the above standard, based on an assessment and determination which demonstrates that the chosen option satisfactorily meets the above standards. -

Specifically, licensees should be able to use the decommissioning alternative of on-site long-term storage areater than 60 years under a Possession Only License, as an additional option to prompt dismantling and 60 year Safestore. Entombment should al so be.

allowed as an option. The NRC could allow these alternatives. by making a reconsideration (or reinterpretation) of the existina decommissioning regulations and alternatives, thereby, not requiring additional rulemaking.

NOTE: This reconsideration / reinterpretation could be- done by issuing new Regulatory Guides as an interpretation of ,

existing decommissioning regulations; therefore, this  :

flexibility could be considered already present in existing ,

NRC regulations,

3. Licensees should be allowed the flexibility and responsibility for t evaluating their options and selecting the most effective approach for their facility, as long as the option chosen meets the Site Cleanup Standards.

4. Nuclear power plants have two major different types of radiological hazards: relatively "short-term" radiation contamination and activation hazards (e.g., Cobalt and Cesium isotopes with 5 and 30 year half-lives), and long-lived " activated component" radiation hazards (activation to Ni-59 and Nb-94 with thousands of. years hal f-l ives) . Regulations should allow removal and disposal of the long-lived activated components in a licensed disposal facility which can provide long-term intrusion controls, and also allow on-site decay in place for the short-lived nuclides.

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4 Mr. Samuel J. Chilk Page 3 June 24, 1993 ,

5. In setting standards, consideration should be given to the fact that many nuclear power plants are located on major industrial complexes '

and pose no short-term hazard to the public (certainly for tens of years, and with institutional controls, hundreds of years) due to the unlikely public "use" characteristics for industrial complexes.  ;

6. Therefore, in order to provide regul atory flexibility while maintaining public health and safety, as well as occupational safety, provisions should be made to allow licensees the option and responsibility to make site-specific assessments to identify for their facility the most cost-effective and safest decommissioning alternative available.

7. Environmental Protection Agency (EPA) chemical risk standards should-not be applied to site radiological cleanup standards since the chemical risk standards are based on a per chemical basis instead of total chemical risk. -

In addition, the chemical risk standards affect larae cooulations  :

whereas the radiation risk standards affect only small oooulations '

which may reside on the former licensed site. Therefore, the cost / benefit analysis for each standard would be drastically different (i.e., the chemical risk values of IE-4 to lE-6 apply primarily to large off-site populations exposed . at these risk values, whereas the radiological site cleanup standards apply primarily to extremely small populations located on-site).

The use of EPA chemical risk standards as a basis for radiological protection would be a departure from conventional radiological protection fundamentals as historically established by the ICRP, the -

NCRP, and the NRC.

8. Site Radiological Cleanup and Restoration Standards could be established as follows in a two-standard process: one standard for large numbers of the public located off-site, and one standard for the small numbers of the public who are on-site.

t Off-Site Standards Based on EPA Risk Methodolooy l The proposed off-site cleanup standards would apply primarily to l exposure of the public during transport of the waste to a licensed  !

disposal facility, but include the exposure of the public through drinking water pathways and from effluents from the site. This off-site standard for large numbers of people should be based on the EPA risk goal approach (3-10 mrem /y).

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Mr. Samuel J. Chilk Page 4 June 24, 1993 On-Site Standards Based on NRC Risk Methodoloav The proposed on-site cleanup standards should be established based on the 100 mrem /y maximum individual limit, .with a complementary ALARA requirement.

9. Separate standards should be established for Radon exposures since Radon is controlled separately in both NRC and EPA regulations,'and guidelines for remedial actions. The standards should be based on the recommendations of the Health Physics Society.

Another option would be to base the standard on a percentage of the EPA Remedial Action Level of 4 pCi/L. A suggested value would be 10 percent of this limit, given the variation in background seen in the United States.

Sincerely, K. R. Wilson, Manager Nuclear Licensing WLR:pkt 3

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