ML20058J002
| ML20058J002 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/30/1993 |
| From: | Bless A OREGON, STATE OF |
| To: | Masnick M NRC |
| References | |
| NUDOCS 9312130331 | |
| Download: ML20058J002 (10) | |
Text
{{#Wiki_filter:.. A Date: November 30, 1993 DEPARTMENT OF ENERGY To: Mike Masnick From: Adam Bless subject: ODOE comments on upcoming public meeting and Schedule for State Decommissioning Rules I read the transcript from the public meeting in Massachusetts. I agree that it went badly, and I'm sure we can do better here. Here are some thoughts on the subject: 1. You asked for a " local" official to act as chair. My suggestion would be one of the Columbia County Commissioners. They have a lot a name recognition, and they are on a first name basis with many of the people who live here. They are accustomed to meetings among people with strong differences of opinion. 2. We ought to anticipate what some of the objections might be, i starting with the cbjections raised in Massachusetts. These issues come to mind right away: Early component removal is a way of starting a. decommissioning before the decommissioning plan is approved. ( That is the kind of comment that Lloyd Marbet might make. b. There has been no EIS on early component removal. c. There is concern that the site will not be restored to a "greenfield" status after decommissioning is done. d. Information was difficult to get from the Public Document Room, e. Transportation is always an issue. Ken Niles of ODOE is expert at handling transportation questions from the public.
- f. Folks who object to activities at Hanford BARBARA ROBERTS may object to "more nuclear waste" being covernor stored there.
ODOE has a full time staff gg devoted exclusively to Hanford. p g. Be prepared to talk about fuel storage, MRS, Yucca Mountain, and ISFSI's, if the 625 Marion Street NE audience raises those topics. Salem, OR 97310 (503) 378-4040 FAX (503) 373-7806 y 9312130331 931130 Q Toll-Free 1-800-221-8035 j PDR ADOCK 05000344 R g _ __-Y
l i i Mike Masnick November 30, 1993 i Page 2 1 l l J The Public Document Room issue is easy to solve. We can put ) copies of the pertinent information in several easy to find i locations. I suggest the County Commissioners' office in St. Helens, and the ODOE office in Salem. Someone should pose as a member of the public and try to get information from the PDR in Portland. t I i l EFSC could participate in one of two ways. EFSC members could l sit in the audience and ask questions as interested members of the public. Alternately, we could notice this as a "special EFSC Subcommittee meeting", with EFSC members sitting on a panel. I suggest we ask Terry Edvalson or Bob Weil what they prefer. Let's arrange a conference call between you, Tom Walt, and Dave Stewart-Smith. Dave is very skilled at managing public meetings, and at anticipating public questions. The call can wait until l the new year. 1 For your information, here is our current working draft of ODOE decommissioning rules. Most of the language was actually drafted by PGE. You will see that we are still grappling with a definition of " background". The fastest schedule that I see for this rulemaking is: Notice these rules out in the 1/1/94 State Bulletin. We would have to submit them for publication by 12/15/93. Schedule workshops for mid January. I think we would need at least two workshops. Workshops are not as formal as hearings. Try for a hearing date in mid February. Ask for EFSC approval in March. That is an optimistic date. l I don't know how much we need in the way of NRC support. Written comments on our draft would be helpful. Perhaps someone would attend the hearing, or the EFSC meeting. The intent of the ODOE rules is to give EFSC guidance in approving the decommissioning plan. Any " standard review plans" used by the NRC for review of decommissioning plans would be helpful. We already have most of l the NUREG's and the SER's for Shoreham and Rancho Seco. t Thanks for your help in the past year. We probably won't do much ] on Trojan in December, so have a good holiday season. i l I
PROPOSED REVISION TO OREGON ADMINISTRATIVE RULES i CHAPTER 345, DIVISION 26 ENERGY FACILITY SITING COUNCIL NOTE: Thir document is intended to reflect the proposed OAR's that are applicable only to Trojan. When in final language, it is intended that these rules could fit in just prior to Notification of Incidents in the version proposed by the post-certification working group. l l Regulations Applicable to Trojan Nuclear Facility l 345-26-xlO The requirements of OAR's xxxx through xxx apply exclusively to the Trojan Nuclear Facility. l [New rule to define applicability of the following section.] Environmental and Effluent Monitoring 345-26-x20 (1) The site certificate holder shall initiate and maintain programs for environmental and effluent monitoring of the site and associated facilities. The environmental and effluent monitoring programs established shall meet all applicable federal and state requirements. (2) Specific plans for the performance, modification, and reporting of these monitoring programs shall be reviewed and concurred in by the appropriate state agencies prior to initial implementation. (3) All environmental and effluent programs established shall be provided to the Department. Changes to such programs shall be provided to the Department consistent with specifications in each monitoring program description. [This section is excerpted from the old 345-26-60. The discussions of individual program elements were deleted - since the program has to describe each element, and the Department is made aware of all changes to the program, it would be impossible to delete a program inappropriately.]
Proposed OAR Revision November 4, 1993 Pace 2 of 8 Radiological Environmental and Effluent Monitoring l 345-26-x30 i 1 NOTE: This section.is excerpted from 345-26-60 and i then expanded upon. .l (1) A radiological environmental and effluent monitoring program shall be established by the site certificate { holder and submitted to the Department for concurrence. (2) The site certificate holder shall describe the quality assurance measures applicable to the radioactive environmental and effluent monitoring programs in the i program plan. 1 i (3) Changes to the radiological environmental monitoring program that involve one of the following require Department concurrence prior to implementation (a) A reduction in the number and type of environmental samples analyzed;.or, i i (b) A change in the verification.of the accuracy of j the effluent monitoring program and-modeling of l exposure pathways. l (4) Modifications to the radiological environmental l monitoring program that do not involve a change meeting the criteria listed in (3) above do not require prior l Department concurrence. These changes shall be ( submitted to the Department within 60 days of implementation of the change. i Security Plans for Nuclear Power Plants and Nuclear Installations l 345-26-x40 { [This section significantly rewritten from 345 l' 110. (1) The site certificate holder shall establish and maintain a security plan with capabilities-for J protection of special nuclear material. (2) Upon assurance satisfactory to the Council and the site certificate holder that confidentiality can be maintained, a security plan for nuclear power' plants or nuclear installations shall be made available to authorized Council representatives for inspection and i 1 \\ i i
i l Proposed OAR Revision November 4, 1993 Epae 3 of s approval. In accord'ance with ORS xxxx, approval of the plan by both the Council and the Director, Oregon Department of Energy must be obtained. l (3) Proposed modifications to the security plan that involve a reduction in the ability to detect or prevent unauthorized entry, or a reduction in the ability to i detect or prevent the introduction of unauthorized 1 material into the Protected Area lessen the. l effectiveness of the physical security plan and require Department concurrence prior to implementation. (4) Modifications to the' plan which do not lessen the i effectiveness of the plan may.be implemented without l l prior Department concurrence. Copies of the revised l plan shall be submitted to the Department within 60 l days of the implementation date. I Emergency Planning for Nuclear Power Plants and Nuclear Installations 345-26-x50 [ NOTE: This section revised from 345-26-190.] (1) The site certificate holder shall prepare, comply with, i and maintain in readiness an emergency response plan. The plan will ensure adequate measures can and will be taken in the event of a radiological emergency. (2) Proposed modifications to the emergency plan that involve one of the following require Department concurrence prior to implementation. i (a) A change (other than editorial) in the Emergency Action Levels; or, f (b) A decrease in the planned staff augmentation l capabilities; or, (c) A reduction in the plan requirements for notification of off-site agencies. (3) Modifications to the plan which do not' meet one of the criteria listed in (2) above may be implemented without prior Department concurrence. Copies of the revised plan shall be submitted to the Department within-30 days of the implementation date.
- - _ ~. - ~ ~ ~ ~ l I Proposed OAR Revision-November 4, 1993 ) Paae 4'of 8 Fire Protection i 345-26-x60 [ NOTE: This section is expanded from 345-26-141.] (1) The site certificate' holder shall provide' fire protection measures that. conform to the applicable National Fire Protection Association standards. i Exceptions to the code shall be documented and justified in the fire protection plan. (2) Proposed plan revisions. involving changes to the exceptions to the code may not be made without prior l Department concurrence. l l (3) Plan revisions whichLdo not involve changes to the exceptions to the code may be implemented without prior l Department concurrence. Notification of such plan revisions shall be made to the Department within 60 days of implementation. Planning and Funding for Decommissioning of Nuclear Installations 'i This section is folded into the Financial Report rule and the Decommissioning Rule. l Standards for Council Approval of the Decommissioning Plan 345-26-097 l [This section is entirely new, except it incorporated previous rule on funding.] ~ (1) The site certificate holder shall submit a plan'for decommissioning a facility to the Department for Council approval prior to implementation. (2) The Council will review the proposed decommissioning plan to verify that the proposed activities.will not adversely affect the health and safety of the public or the environment. The Counc31'will ensure the following when evaluating acceptability of a proposed plan: (a) The plan contains criteria for the free release of materials and the area as specified in the table below:
e 4 4 Proposed OAR Revision November 4, 1993 Pace 5 of 8 TABLE 1 ACCEPTABLE SURFACE CONTAMINATION LEVELS NUCLIDE AVERAGE MAXIMUM REMOVABLE Natural Uranium, U-235, U-238, 5000 15000 1000 dpm and associated decay products dpm dpm alpha alpha alpha Transuranics, Ra-226, Ra-228, 100 dpm 300 dpm 20 dpm Th-230, Th-228, Pa-231, Ac-227, I-125, I-129 Natural Thorium, Th-232, Sr-90, 1000 3000 200 dpm Ra-223, Ra-224, U-232, I-126, I-dpm dpm 131, I-133 Beta-gamma emitters with decay 5000 15000 1000 dpm modes other than alpha emission dpm dpm beta / or spontaneous fission'except beta / beta / gamma Sr-90 and others noted above gamma gamma NOTES: 1. Contamination levels given in the Table are in disintegrations per minute (dpm) per 100 square centimeters. 2. Where surface contamination by both alpha and beta-gamma emitting nuclides exists, the limit established for alpha and beta-gamma apply independently. NOTE: This table was excerpted from U.S. Nuclear Regulatory Commission Reg Guide 1.86, " Termination of Operating Licenses for Nuclear Reactors" (b) After decommissioning, the exposure rate at one meter form all surfaces in the facility buildings and outdoor areas shall be 5 uR/hr or less above the background level. Background is defined as (c) The plan must contain provisions that require all radioactive waste as defined in OAR 345-50-025 be removed from the site. (d) The plan must contain an acceptable program for monitoring and controlling effluents to ensure
~ Proposed OAR Revision-November 4, 1993 Pace 6 of 8 compliance with applicable federal limits. This program may be incorporated by reference. (e) The plan must contain provisions-for a program for radiological monitoring to ensure the environment is not being adversely affected. This program may be incorporated by reference. j (f) The plan must contain provisions for hazardous waste removal that is consistent with other-federal and state regulations.. (3) The Council will determine if the level of funding is available and is adequate to implement the plan.. ) (4) Significant revisions to the decommissioning plan must be reviewed and approved by the Council prior to implementation by the site certificate holder. A revision shall be deemed significant if it involves one of the following items: (a) The potential to prevent the release of the' site for unrestricted use; or, (b) A change in the criteria for free release of l materials; or, (c) A departure in the methodology for' determining-background levels to a method not generally accepted by the industry; or,. (d) A change in the provisions made for hazardous and/ or radioactive waste material removal; or,. (e) A significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or, (f) A significant increase in radiological or hazardous material exposure to site workers or to l members of the public, including exposure due to l transport of radioactive or hazardous material. [ NOTE: We still need to' define significant } in the abovo criteria or delete the criteria.] (5) If a proposed change in the decommissioning plan involves a change in costs greater than 10 percent of { l the previous estimation, the Council shall be notified prior to implementation. The Council will retain the right to determine the acceptability of the change i prior to implementation. (6) Revisions to the decommissioning plan shall be j evaluated per the criteria listed above. Records of' 1 1 e
f 1 ~ l' Proposed OAR Revision November 4, 1993 Pace 7 of-8 i all changes and associated evaluations shall be maintained for audit by the Department. Revisions to the decommissioning plan which are not significant changes as defined above shall be included with the j annual report on decommissioning funds. Annual Report j 345-26-x107 [This section is a combination of individual reporting requirements, similar to what is proposed for the new 345-26-075. This section will be integrated with the section on annual reports applicable to all site certificate holders.] (1) General Reporting Obligation: i (a) Annual reports covering the previous calendar year's activities shall be submitted to the Department'within 120 days of the end of the i calendar year, or per an alternate schedule with prior approval of the Department. The report shall include the items listed in this rule. 4 (b) To the extent that information required by this rule is contained in reports the site certificate i holder submits to other state, federal or local agencies, excerpts from such other reports may be submitted to' satisfy this rule. The Council reserves the right to request full copies of such j excerpted reports. (2) Contents of Annual Report: 1 (a) The report shall include summaries, interpretations, and analyses of trends of the results of the Environmental Monitoring Program and the Radiological Environmental Monitoring Program. It shall also contain the results of analyses of all radiological environmental samples and of all environmental radiation measurements taken during the reporting period. [The above was taken from_the PDTS). ) (b) The report shall include a financial report which i demonstrates the financial qualifications of the site certificate holder to perform retirement and decommissioning activities. Changes in the l
i I l Proposed OAR Revision l November 4, 1993 Pace 8 of 8 j financial plan or status of the financial plan' j ~ shall be included. ) Temporary Nuclear Fuel Storage 345-26-x17 i [ NOTE: This is a new section.] l l Exemptions 345-26-x27 l The Council may, either upon written application or on its i own motion, waive or delay compliance with any.of these } rules as applied to a specific site,-if after a public i hearing, it concludes that such action will not result in injury to the public health, safety, or welfare. -f i I l \\ 9 I f e =~}}