ML20059H009
| ML20059H009 | |
| Person / Time | |
|---|---|
| Issue date: | 09/10/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-PII, TASK-SE SECY-90-316, NUDOCS 9009140165 | |
| Download: ML20059H009 (4) | |
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""0".......?..S2,j September 10, 1990 SECY-90-316 Onformation)
For:
The Comissioners From:
James M. Taylor, Executive Director for Operations subject:
DECOMMISSION 1hG RECORDS PLAN
Purpose:
To inform the Comission of the staff's plan for ensuring that records documenting NRC's decomissioning activities are properly preserved and retained. This paper discusses the staff's plan for correcting the recordkeeping problems identified by the General Accounting Office (GAO),
Sumary:
This paper presents the staff's plan regarding the GA0's recomendation that NRC obtain and keep decomissioning records longer than 10 years. This recor.nendation was included in the 1989 GA0 report, "NRC's Decomissioning Procedures and Criteria Need To Be Strengthened that resulted from GAO's revisit with the Office of Nuclear Material Safety and Safeguards (NMSS) to examine its decomissioning records five years af ter issuance of the 1982 GA0 report, Cleaning Up Nuclear Facilities--An Aggressive and Unified Federal Program is Needed. The 1982 report recomended that NRC establish a separate, centralized, permanent collection of decomissioning records.
The staff has developed a plan that will require the NRC to retain permanently tF-decomissioning records that the HMSS contractor and IRM
.atify during their review of terminated license case files. The remainder of those case files, and the corresponding inspection and enforcement case files, will be destroyed 20 years af ter each license is terminated. However, the NRC will retain permanently the entire file for each license case designated as having significant historical value. The staff's plan further requires that IRM and the regional staffs separate the decomissioning records from among the currently active and
Contact:
Brenda Jo. Shelton, IRM NOTE:
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future case files, consolidate them as a subset of each case file, and retain them permanently. The IRM staff will then retain the remainder of each case file for only 20 years after the license is terminated.
The staff believes that this approach is the most aractical and least burdensome to the NRC and will resolve tie GA0 concerns.
The staff considers the impact on agency resources to be minimal.
Discussion:
The 1982 GA0 Report, " Cleaning Up Nuclear Facilities-An Aggressive and Jnified Federal Program Is Needed," contained a recommendation that NRC revise its recordkeeping system to " provide for prompt identification of licensees who have stopped operations effective monitoring of licensee control overcontaminatedYacilities,assurancethatfacilitiesare cleaned up when licenses are terminated, and the development and permanent retention in a central regository of records documenting decommissioning activities.
NRC comitted to implementing the GA0 recomendation and further agreed to
" maintain permanent files containing pertinent information on the status of NRC licensed facilities that are inoperative and had been radioactively contaminated." GA0's expressed concerns.were indicative of a GA0 belief that a permanent, centralized collection of records would enhance the NRC staff's ability to identify the location, condition, and status of abandoned or terminated sites and facilities that are radioactively contaminated, as well as sites that are free of residual contamination.
As a result of a subsequent audit that began in 1987 GA0 issued its 1989 report, "NRC's Decomissioning Procedures and Criteria Need To Be Strengthened."
In this report, the GAO recomends that the NRC obtain decomissioning records and keep them longer than 10 years, as opposed to the earlier recomendation that NRC keep the records permanently and as a centralized, separate collection. Therefore, the staff has directed its focus to the 1989 GA0 recomendation, and believes that events and circumstances no longer necessitate that NRC pursue the original comitment.
NHSS is specifically required to review the records of sites terminated since 1965 as a separate action item evolving from the "Synar Hearing on Decomissioning," and plans to retain a contractor to review the records of terminated sites not previously reviewed. During the contractor's review of these case files, it will identify and consolidate, for retention as a subset of each respective case file, the decomissioning and decontamination records.
IRM wiH review the respective inspection and enforcement case files to identify and retrieve those decomissioning
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records identified by the contractor as missing from the license case files.
IRM has already begun maintaining documents related to decomissioning as a subset of the nuclear power plant case files (Docket 50) to ensure that the staff can readily identify the documents that are to be retained permanently from those that are to be retained for 20 years after the license is terminated. The NRR staff will establish guidelines to ensure that all the decomissioning documents are identified. The IRM staff will begin maintaining the decomissioning documents as a subset of the materials license case files (Dockets 30, 40, and 70) after the NMS$
staff establishes guidelines for identifying these documents.
Regions III and V indicated they also have already begun maintaining the decomissioning records as a subset of the case files. With the implementation of the staff's plan, all regions will be required to begin keeping the decomissioning records as a subset of each case file.
Following are the actions the staff is implementing with respect to decomissioning records related to the categories of licenses identified below:
(1) Terminated Licenses Pre-1965 Materials License Case Files Previously Reviewed By The Oak Ridge National Laboratory Retain permanently this collection of about
+
250 cubic feet of records and the corresponding inspection and enforcement t
case files.
Materials and Reactor Case Files That Require Review Retain permanently the entire file for each license case the staff determines to be of significant historical value.
I Retain the decomissioning segment of the remaining license case files and destroy all other segments of each case file, and the corresponding inspection and enforcement case files, 20 years after the license terminates.
(2) Licenses Currently Pending Termination and Remaining Active and Future Licenses Retain permanently the entire case file, and the corresponding inspection and enforcement
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case files, for each license the staff determines to be of significant historical value.
Retain permanently the decomissioning segment of the remaining license case files and destroy all other segments of each file, and the corresponding inspection and enforcement case files, 20 years af ter the license terminates.
, coordination:
OGC has reviewed this paper and has no legal objections.
l net ~.T or xecutive irector for Operations DISTRIBUTION:
Commissioners OGC OIG LSS REGIONAL OFFICES GPA EDO ACRS ACNW ASLBP ASLAP SECY
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