ML20077G118

Forwards Telegram from Region 1 Ofc for Info & Appropriate Action

ML20077G118
Person / Time
Site:	05000310
Issue date:	10/13/1971
From:	Engelken R US ATOMIC ENERGY COMMISSION (AEC)
To:	Skovholt D US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20077G108	List: ML20077G118 ML20081G746 ML20081J256 ML20081J275 ML20081J283 ML20081J418 ML20081J461 ML20081J699 ML20081J741 ML20081J808 ML20081J832 ML20081J856 ML20081J900 ML20081J913 ML20081J932 ML20081J946
References
FOIA-90-558 NUDOCS 9106240249
Download: ML20077G118 (2)

Text

,

s y\\

y

.a t

UNITED STATES e

5 2.

i NUCLEAR REGULATORY COMMISSION 5 jb4/

WASHINGTON. D.C. 20556 MM 31 1991 MEMORANDUM FOR:

Eric S. Beckjord, Director Office of Nuclear Regulatory Research FROM:

C. J. Heltemes, Jr., Deputy Director for Generic Issues and Rulemaking Office of Nuclear Regulatory Research

SUBJECT:

NRC PRESENTATIONS AT THE CONFERENCE OF RADIATION CONTROL PROGRAM DIRECTORS, INC. (CRCPD)

On Tuesday, May 14, 1991, the staff gave five presentations at the two NRC public meetings held in conjunction with the 23rd Annual National Conference of the CRCPD in Wichita, Kansas. The purpose of these presentations was to discuss: (1) the proposed process for gaining "early and substantive" input by the Agreement States in the development of NRC rulemaking and regulatory policy which would be mctters of compatibility; and (2) four rulemakings which are at an early state of development and thus were selected as the first rulemaking to solicit Agreement States' views and reaction.

The first NRC meeting was held from 9 AM to 12 noon, and the second was from 7 PM to about 9:30 PM. About 25 to 30 participants attended each session.

General background on and a summary of this meeting are contained in a memorandum to the Commission from Carlton Kammerer dated May 24, 1991.

I presented the first presentation on the proposed approaches and process for obtaining the views of Agreement States on rulemaking involving matters of compatibility. A number of viewgraphs were used (Enclosure 1 - Handouts were also made available) to identify the method and timing to gain this input, and to coordinate the agenda topics sufficiently well in advance that all parties will have ample time to prepare.

A point that I stressed in my presentation was that this process was under development and was expected to evolve and be refined as a result of experience and comments received from Agreement States.

I noted that the NRC's goal was the development of a practical and effective process that meets the objective.

The feedback from this presentation was very positive.

The process and practice seemed to have strong support from the Agreement State participtnts present, and there were no suggestions or comments for how the process should be modified nor were any concerns expressed.

As the first demonstration of the proposed process, fcur rulemakings were discussed by the staff: (a) Glen Sjoblom (NMSS) pretented the proposed rulemaking on " Third-Party Certification of Industrial Radiographers" (Enclosure 2); (b) Paul Lohaus (NMSS) and Janet Lambert (RES) presented the g 62 g 9 901123 DRANNEN90-550 PDR b'oS a

b

MAY 3 1 1991 Eric S. Beckjord 2

pioposed rulemaking to revise Part 61 on "8.icensing Requirements for Land Disposal of Radioactive Waste" (Enclosure 3); and (c) I presented the proposed rulemakings on " Timeliness of Decommissioning" and on " Residual Raoloactivity for Decommissioning" (Enclosures 4 and 5).

Copies of all presentations were provided to participants as handouts.

Questions and in some cases concerns and suggestions were offered by the l

participants on each presentation.

The discussion was candid and in depth.

The NRC participants welcomed the thoughtful and well founded input, and committed to follow-up analysis, particularly where a new perspective cr concern '

expressed.

A transcript of both meetings will soon be available for foll study.

Consistent with the process outlined to the CRCPD, copies of the staff's presentation are being placed in the PDR.

I C.

ene,

Deputy Director

Ger.eric Iss '

and Rulemaking or Of of Nuclear Regulatory Research

Enclosures:

As stated cc:

wLenclosures J. Taylor J. Sniezek I

H. Thompson H. Denton R. Barnero G. Arlotto i

R. Cunningham R. Bangart M. Malsch J. Scinto l

L. Shao

8. Morris F. Costanzi D. Cool M. Silberberg PDR w/o enclosures G. Pangburn S. Schwartz l

C. Kammerer V. Miller P. Lohaus J. Lambert l

W 0 R K I NEG.

DRAFT (h

.CRCPD? PRESENTATION--MAY[14,1991 r-l GIVEN BY:

C.J.

HELTEMES, JR.

U.S.

NUCLEAR REGULATORY COMMISSION 1

l

3 (43)

.CRCPDePRESENTATION--MAYT14, 1991-PROCESS FOR EARLY INVOLVEMENT OF AGREEMENT STATES IN DEVELOPMENT OF REGULATORY POLICY l.

O OBJECTIVE:

TO OBTAIN AGREEMENT STATES (AS) VIEWS / INPUT ON ISSUES INVOLVING COMPATIBILITY AS SOON AS PRACTICALLY

}

ACHIEVABLE.

I O

PROPOSAL:

1 NRC WILL PROVIDE THE REGULATORY AGENDA TO AS SO THEY MAY $

l PARTICIPATE IN SELECTION OF ISSUES TO BE DISCUSSED.

NRC WILL PROVIDE OVERVIEW OF SELECTED REGULATORY POLICY ISSUES AT CRCPD ANNUAL MEETINGS AND ALL AGREEMENT STATE MEETINGS.

NRC MAY HOLD ADDITIONAL MEETINGS, AS NEEDED, TO DISCUSS EXPEDITED ACTIONS.

FEEDBACK FROM MEETINGS WILL BE FACTORED INTO PROPOSALS BY s

STAFF AND HIGHLIGHTED IN STAFF TRANSHITTALS TO COMMISSION.

t 1

m

/%

()f4)s CRCPDKRRESENTATION--MAY. - 14, 1991 t

CONTINUED o

PROCESS DEVELOPMENT WILL REs-LECT:

COMMENTS AND FEEDBACK FROM THIS MEETING, i

EXPERIENCE WITH IMPLEMENTATION, DEVELOPMENT OF PROCEDURES BY OFFICE OF GENERAL COUNSEL, ASSESSMENT OF FUTURE FEEDBACK RECEIVED FROM AS.

2

s

.-r

~

7 (M4)

CRCPDDPRESENTATION--MAY 14, 1991

SUMMARY

OF PROCESS O

WRITTEN REQUESTS FOR AS COMMENT ON A CASE-BY-CASE BASIS.

O NRC PROVIDES ROUTINE UPDATE OF REGULATORY AGENDA (NUREG 0936) TO EACH AS.

O AS IGENTIFY ITEMS OF INTEREST TO NRC.

O NRC, WITH AS INPUT, IDENTIFY TOPICS FOR STAFF PRESENTATIONS AT NEXT NEETING.

O AS PROVIDES SUBSTANTIVE INPUT OF AS ON RULES AT EARLY DEVELOPMENT STAGE AT SEMIANNUAL MEETINGS.

O COMMENTS AND CONCERNS OF AS ARE OBTAINED DURING MEETINGS:

ORAL COMMENTS DOCUMENTED BY TRANSCRIPT WRITTEN COMMENTS WITHIN DIO WEEKS FOLLOWING MEETING.

I

_J 3

l

'[h)

CRCPD PRESENTATION-<-MAY 14, 1991 I

CONTINUED STAFF CONSIDER COMMENTS IN DRAFTING RULES.

o CONSULTATION ON WORKING DRAFTS DETERT1INED ON CASE-BY o

AFTER COMMISSION NOTIFICATION.

AS PROVIDES COMMENTS ON PROPOSED RULES.

o AS VIEWS ON PROPOSED RULES IDENTIFIED AND RESOLVED IN o

RULE PACKAGE FOR COMMISSION ACTION.

o SPECIAL MEETINGS ARE SCHEDULED, AS NECESSARY, WITH MUTUAL AGREEMENT.

l l

1 4

O I

(m44)

CRCPD-PRESENTATION--MAY 14, 1991.

PERIODIC MEETINGS O

STAFF PRESENTATIONS TO BE MADE TWICE PER YEAR:

CONFERENCE OF RADIATION CONTROL PROGRAM OIRECTORS--SPRING ALL AGREEMENT STATES (AS) ANNUAL MEETINGS--FALL.

i.ETTER OF. INVITATION WILL IDENTIFY AGENDA TOPICS AND PROVIDE

SUMMARY

O BACKGROUNO INFORMATION.

MEETINGS WILL BE OPEN TO ALL AND NOTICED IN PDR--MEETING HOTLINE--

l 0

l AND COMMISSION WEEKLY STi.TUS INFORMATION PAPER.

i O

PRIORITY WILL BE GIVEN TO AS INPUT AND DISCUSSIONS.

PuBLIC COMMENTS, IF ANY, RECEIVED ON TIMk AVAILABLE BASIS.

STAFF PRESENTATIONS AND HANDOUT MATERIAL WILL BE CONSIDERED " WORKING o

DNAFTS" AND PLACED IN THE PDR.

i l

l 5

r ej

!Lt;!

.i l:

t S

N R

O E

I I

T n

I T

A P

F C

A I

A F

R G

I R

T D

R O

I E

D C

F A

G O

R N

Y I

L 1

K R

A R

A R

I P

T 0

D S

W R

UD l

i N

iT I

e I

i' l/tl1l1lll

OUTLINE

• NEED FOR RULEMAKING

• POSSIBLE REGULATORY LANGUAGE

• ELEMENTS OF AN ACCEPTABLE PROGRAM

+ ELEMENTS OF AN ACCEPTABLE EXAMINATION

• ELEMENTS OF AN ACCEPTABLE THIRD-PARTY

• COMPATIBILITY

I NEED =OR RULEVIAKING

= More Overexposures per Worker than Any Other Group of NRC Licensees Average 6 Overexposures/Yr 50% of Overexposures > 5 rem 60% of Overexposures > 25 rem

. High Average Exposures for Radiography Workers

.41 rem Average Measurable Dose / Worker

. Failure to Follow Procedures is a Basic Cause of all Radiography Overexposures

• Some Lack Professionalism

• Instances of Willful / Careless Disregard

POSSIBLE REGULATORY LANGUAGE WORKING DRAFT 34.31 Training.

(a) The licensee shall not permit any individual to act as a radiographer until such individual:

(5) is certified in radiation safety by a third-party approved by the Commission.

1 I

draf t 5/14/91 t

ELEVIE\\lTS OF AN ACCEPTABLE CERTIFICK~lOh PROGRAVI

'I i

The Program Must Require Individuals to I

1.

Satisfactorily Complete a Written Examination Covering 10 CFR Part 34, Appendix A Topics draf t 5/14/91

b 1

ELEMENTS OF1 AN ACCEPTABLE i

. CERTIFICATION PROGRAM, cont'd 2.

The Program. Must Re_ quire Individuals to Provide Signed Documentation that Shows the Individual j

has Satisfactorily Completed the 10 CFR 34.31 l

Practical Examination Administered by a NRC.or Agreement. State Licensee q

l l

i i

l~

i draf t 5/14/91 i

I

ELEVIENTS OF AN ACCEPTABLE CERTIF! CATION PROGRAM, cont'd J

3.

The Program Must Require Individuals to Provide Signed Documentation the Shows the Individual has Completed the Required 10 CFR 34.11 Minimum Period of On-The-Job Training

[

i L

l l

draf t 5/14/91 I

I ELEMENTS OF AN ACCEPTABLE CERTIFICATION PROGRAM, cont'd 4.

The Program Must Provide. Security Procedures for Ensuring that Examination items are Protected from Disclosure to Radiographers and the General Public draf t' 5/14/91 t

ELEVENTS OF AN ACCEPTABLE CERTIFICATION PROGRAM, cont'd l

l The Program Must Specify Criteria with which 5.

Certified Individuals Must Agree to Comply with in Order to Maintain Their Certification (Code of Ethics) l l

l l

draf t 5/14/91

~

ELEMENTS OF AN ACCEPTABLE CERTIFICATION PROGRAM, cont'd 6.

The Program Must include Procedures Whereby an individual's Certification may be Revoked, Suspended, or Restricted for Failure to Comply with Established Criteria (Code of Ethics) draf t 5/14/91

ELEVIENTS OF ANI ACCEPTABLE WRITTEN EXAMINATION

• Must be Designed to Test an Individual's Knowledge and Understanding of 10. CFR Part 34, Appendix A Subjects

• Must be Designed to Test at an Educational Level Appropriate for Radiography (Ninth Grade)

- Question.and Answer items Must be Properly Validated in Accordance with Accepted Educational Practices t

s dra'it 5/14/91

ELEMENTS OF AN ACCEPTABLE THIRD-PARTY ORGANIZATION i

. Must Agree to Establish Procedures for Exchange of

..information about Certified Individuals with Proper Regulatory Authori. ties

• Must Establish Written. Procedures Detailing All l

Aspects of the Certification Program J

• Must Maintain Records on Each Certified Individual and on the Administration of the Program

• Must Agree.to Periodically Allow Appropriate Regulatory Authorities to Roview the Certification Program E

l draf t 5/14/91 i

Y-COMPATIBILITY NRC Staff Believes that in Order for Radiographer Certification to be an Effective Program and improve Radiography Safety Nationwide, it Should be implemented in All States l

l l

l i

draf t 5/14/91

W10 R K I.N G D RA F T i

l PRESENTATION - MAY 14,1991 RULEMAKING TO REVISE l

10 CFR PART 61

" LICENSING REQUIREMENTS FOR LAND DISPOSAL OF RADIOACTIVE WASTE."

q 4

GIVEN BY JANET LAMUERT U.S. NUCLEAR REGULATORY COMMISSION i

i

ORAFT REVISIONS TO 10 CFR PART 61 -

l

" LICENSING REQUIREMENTS FOR LAND DISPOSAL OF RADIOACTIVE WASTE" l

l BACKGROUND PART 61 WAS ISSUED IN 1982.

o NRC STAFF HAS DETERMINED THAT IT IS DESIRABLE TO MAKE TWO o

SPECIFIC CHANGES TO Part 61:

1)

THE TERM " QUALITY ASSURANCE" (QA) WILL REPLACE THE TERM CONTROL (QC) IN 61.12(j);

2)

THE DEFINITION OF " LAND DISPOSAL FACILITY" IN 61.2 WILL BE CHANGED TO MORE CLEARLY INCLUDE ABOVE-GROUND DISPOSAL METHODS LIKE AN ABOVE-GROUND VAULT.

1 ON APRIL 18,1991, NRC INITIATED A RULEMAKING TO MAKE THESE l

o CHANGES TO PART 61.

op4 AFT T

l CHANGE FROM " QUALITY CONTROL" TO

" QUALITY ASSURANCE" o CURRENT LANGUAGE IN PART 61:

61.12(j) - REQUIRES THAT THE LICENSE APPLICATION FOR AN LLW l

DISPOSAL FACILITY INCLUDE:

A DESCRIPTION OF THE QUALITY-l CONTROL PROGRAM FOR THE DETERMINATION OF NATURAL DISPOSAL i

SITE CHARACTERISTICS AND FOR QUALITY CONTROL DURING THE i

DESIGN, CONSTRUCTION, OPERATIO,N AND CLOSURE OF THE LAND DISPOSAL FACILITY AND THE RECEIPT, HANDLING, AND EMPLACEMENT OF WASTE.

AUDITS AND MANAGERIAL CONTROLS MUST BE f

INCLUDED."

i i

D71 CHANGE FROM " QUALITY CONTROL" TO " QUALITY ASSURANCE"'

o PROPOSED CHANGE; 4

i "61.12(j) - A DESCRIPTION OF THE QUALITY ASSURANCE PROGRAM FOR THE DETERMINATION OF NATURAL DISPOSAL SITE.

CH ARACTERISTICS AND DURING THE DESIGN, CONSTRUCTION, OPERATION i

AND CLOSURE OF THE LAND DISPOSAL FACILITY AND THE RECEIPT, HANDLING, AND EMPLACEMENT OF WASTE."

i l

l b

L DRAFT CHANGE THE DEFINITION OF " LAND DISPOSAL FACILITIES" 1

.TO MORE CLEARLY INCLUDE ABOVE-GROUND DISPOSAL FACILITIES

-l l

i o CURRENT LANGUAGE IN PART 61:

1 j

UNDER 61.2 -

i l

" LAND DISPOSAL FACILITY" MEANS THE LAND, Bull. DINGS, AND

{

EQUIPMENT WHICH ARE INTENDED TO BE USED FOR THE DISPOSAL OF l

RADIOACTIVE WASTES INTO THE SUBSURFACE OF THE ".. MD."

i i

i b

o PROPOSED CHANGE - ADD "ON" SO THAT l

"l.AND DISPOSAL FACILITY" MEANs THE. LAND, BUILDINGS, AND-i EQUIPMENT WHICH ARE INTENDED TO BE USED FOR THE DISPOSAL OF RADIOACTIVE WASTES INTO OR ON THE UURFACE OF THE LAND."'

i 1

i

WORKING DRAFT CRCPD PRESENTATION--MAY 14, 1991 RESIDUAL RADI0 ACTIVITY FOR DECOMMISSIONING I

GIVEN BY l

C.J.

HELTEMES, JR.

U.S.

NUCLEAR REGULATORY COMMISSION

RESIDUAL RADI0 ACTIVE CONTAMINATION AT DECOMMISSIONED FACILITIES PROPOSED RULE WOULD ESTABLISH RESIDUAL CONTAMINATION i

CRITERIA FOR' BUILDINGS, STRUCTURES, AND LANDS TO BE RELEASED FOR UNRESTRICTED USE (10.CFR PART 20).

CRITERIA FOR.7ELEASE OF C'ONTAMINATED EQUIPMENT OR MATERIALS FOR RECYCLING OR REUSE WOULD BE COVERED IN i

SEPARATE RULEMAKING.

MOST SITES CAN BE RELEASED FOR UNRESTRICTED USE IF RELEASE COMPLIES WITP' i

SPECIFIC RADIATION LEVELS CONSIDERED TO BE GENERIC l

" DEFAULT" ALARA LEVELS APPROPRIATE FOR-

[

DECOMMISSIONING OR BASEDcON A SITE SPECIFIC ALARA l

ANALYSES.

i 1

RESIDUAL RADI0 ACTIVE CONTAMINATION AT DECOMMISSIONED FACILITIES _

(CONTINUED)

THE REGULATION WILL BE S,UPPORTED BY REGULATORY GUIDANCE WHICH:

LEVELS FOR SPECIFIC SPECIFIES RESIDUAL CONTAMINATION ISOTOPES OR GROUPS OF ISOTOPES CORRESPONDING TO THE AND DEFAULT DOSE CRITERIA OF THE RULE, DESCRIBES PROCEDURES FOR CONDUCTING SITE SURVEYS TO DEMONSTRATE COMPLIANCE WITH REQUIREMENTS OF THE RULE.

THE PROPOSED REGULATION AND, ACCOMPANYING REGULATORY FOR PUBLIC COMMENT GUIDES ARE SCHEDULED TO BE PUBLISHED IN FEBRUARY 1992.

FOR DEVELOPMENT OF CRITERIA ON A ELIMINATES THE NEED CASE-BY-CASE BASIS.

2

RESIDUAL RADI0 ACTIVE CONTAMINATION AI DECOMMISSIONED FACILITIES (CONTINUED) i 1

PRESERVES A REASONABLE DEGREE OF FLEXIBILITY TO l

INCORPORATE CHANGES THAT MAY BECOME DESIRABLE AS THE KNOWLEDGE BASE FOR DECOMMISSIONING INCREASES AND/

EPA PUBLISHES REGULATIONS IN THIS AREA.

i 3

~

CURRENT CONSIDERATIONS FOR RESIDUAL CONTAMINATION RULE L

1.

PROCEEDING IN THE ABSENCE OF EPA STANDARDS FUTURE REMEDIAL ACTION COULD BE REQUIRED TO BRING ALREADY DECOMMISSIONED SITES INTO COMPLIANCE WITH NEW EPA REQUIREMENTS.

NRC PLANS TO PROCEED WITH RULEMAKING AND COORDINATE WITH EPA.

OBJECTIVE IS TO OBTAIN THE EPA BACKING FOR THE RULE.

l I

i 4

k

j 1

2. ALARA CONSIDERATIONS L

A PRINCIPAL TENET OF THE CURRENT RULEMAKING CONCEPT IS THAT REDUCTION OF RADIATION DOSES TO DEFAULT LEVELS SPECIFIED IN THE RULE WOULD-BE CONSIDERED' ACCEPTABLE JUSTIFICATION THAT ALARA HAS BEEN

' ACHIEVED WITHOUT SITE SPECIFIC COST BENEFIT ANALYSES.

CURRENT PROPOSAL IS TO ESTABLISH SUCH A LEVELS APPROPRIATE FOR DECOMMISSIONING OF NUCLEAR FACILITIES.

THESE LEVELS SHOULD BE BASED IN PART ON AN ANALYSIS OF THE COMPETING RISKS,

COSTS, AND BENEFITS, AND THE LICENSEE'S ABILITY TO DEMONSTRATE COMPLIANCE WITH 3

THE REGULATIONS USING REASONABLE SURVEY EQUIPMENT, PROCEDURES, AND TECHNIQUES.

BASED ON A PRELIMINARY ASSESSMENT, 10 MREM /Y IS l

BEING CONSIDERED AS AN-APPROPRIATE LEVEL FOR MOST

[

TYPES-OF. FACILITIES.

5

)

t 2.

ALARA CONSIDERATIONS (CONTINUED)

L

CURRENT PROPOSAL IS THAT LICENSEES WILL BE REQUIRED TO DECONTAMINATE STRUCTURES TO LEVELS BELOW THESE i

LEVELS WHERE SUCH DECONTAMINATION CAN BE ACHIEVED 1

USING GENERALLY ACCEPTED GOOD HOUSEKEEPING PRACTICES AND READILY AVAILABLE NONDESTRUCTIVE DECONTAMINATION TECHNIQUES.

LICENSEES WOULD HAVE THE OPTION OF CONDUCTING A SITE SPECIFIC ALARA ANALYSIS RATHER THAN USING THE DEFAULT LEVELS.

i i

i 6

3.

LIMITING. GROUNDWATER CONTAMINATION (ENTITIES.TO WHICH l

DECOMMISSIONING CRITERIA APPLY)

[

i PURPOSE OF SITE INVENTORY LEVEL IS TO LIMIT GROUNDWATERECONTAMINATION TO EPA STANDARDS.

DEFAULT INVENTORY LEVELS WILL BE ESTABLISHED TO j

SERVE'IN LIEU OF SITE SPECIFIC ANALYSES.

l

^

IN ESTABLISHING DEFAULT INVENTORY LEVELS, ANNUAL j

DOSES FROM GROUNDWATER CONTAMINATION WOULO BE SET AT SOME FRACTION (E.G.,

10%)

OF 10 MREM /Y.

j t

THIS WOULD PROVIDE SAFETY MARGIN FOR POTENTIAL f

CUMULATIVE GROUNDWATER CONTAMINATION FROM DECOMMISSIONING OF SEVERAL ADJACENT OR PROXIMATE SITES.

LICENSEES WOULD BE ALLOWED TO APPORTION A FRACTION-F OF THE TOTAL. SITE INVENTORY TO PORTION OF THE SITE j

BEING DECOMMISSIONED.

7 i

3.

LIMITING GROUNDWATER CONTAMINATION (ENTITIES TO WHICH l

DECOMMISSIONING CRITEP.IA APPLY)

(CONTINUED)

LICENSEES'HAVE THE OPTION OF CONDUCTING A SI.TE SPECIFIC ANALYSIS RATHER THAN USE DEFAULT LEVELS.

POTENTIAL PROBLEM:

MAY HAVE TO SET DEFAULT LEVELS SO LOW THAT THEY WILL BE BELOW THE PRACTICAL LEVEL OF

[

DETECTABILITY FOR SOME IMPORTANT NUCLIDES.

[

4.

TREATMENT OF SITES WITH SIGNIFICANT LEVELS OF RADIUM

~

AND RADON AND THEIR DECAY PRODUCTS i

CURRENT CONCEPT IS TO REQUIRE CLEANUP TO LOCAL l

BACKGROUND LEVELS OR LEVELS WHICH ARE ALARA ON A l

CASE SPECIFIC BASIS.

8

[

5.

MATERIALS PREVIOUSLY BURIED ON-SITE UNDER DISPOSAL PROVISIONS IN 10 CFR PART 20.

I UNDER NRC REGULATIONS, LICENSEES MAY DISPOSE OF RADIOACTIVE WASTES ON THEIR OWN PROPERTY.

l CURRENT PROPOSAL IS TO REQUIRE CONSIDERATION OF l

l f

RADIOACTIVE MATERIALS DISPOSED OF BY ONSITE BURIAL l

WHEN ASSESSING COMPLIANCE WITH THE SITE INVENTORY LIMITS FOR RESIDUAL CONTAMINATION.

I THEPEFORE LICENSEES MAY BE REQUIRED TO REMOVE THIS MATERIAL PRIOR TO DECOMMISSIONING THE SITE.

BEFORE A DECISION IS MADE TO EXHUME ANY MATERIAL PREVIOUSLY DISPOSED OF AT A SITE, A SITE SPECIFIC l

l ANALYSIS OF THE RISKS,

COSTS, AND BENEFITS WILL BE PERFORMED.

f 9

6.

TIME FRAME FOR CALCULATING CONTAMINATION 01: DRINKING WATER HOW FAR INTO THE FUTURE SHOULD CALCULATIONS BE CARRIED OUT WHEN ESTIMATING RADIATION DOSES TO INDIVIDUALS AND POPULATIONS FROM MIGRATION OF RADIOISOTOPES INTO THE GROUNDWATER FROM DECOMMISSIONED SITES?

CURRENT DOE PRACTICE IS TO CALCULATE DOSES OUT TO 1000 YEARS.

EPA HIGH LEVEL WASTE REGULATIONS REQUIRE THAT CUMULATIVE RELEASES TO THE ENVIRONMENT BE CALCULATED OUT TO 10,000 YEARS.

CURRENT PROPOSAL IS TO REQUIRE THAT CALCULATIONS BE EXTENDED FAR ENOUGH INTO THE FUTURE TO ASCERTAIN THE PEAK GROUNDWATER RADIONUQLIDE CONCENTRATIONS WHICH COULD RESULT FROM RESIDUAL CONTAMINATION AT THE

SITE, BUT THAT SUCH CALCULATIONS NOT BE EXTENDED BEYOND 10,000 YEARS.

10 l

WORKING DRAFT

~

i e

I CRCPD PRESENTATION--MAY 14, 1991 TIMELINESS OF l

DECOMMISSIONING

,i b

GIVEN BY 3

C.J.

HELTEMES, JR.

U.S.

NUCLEAR REGULATORY COMMISSION 1

i 1

I

- O

I TIMELINESS IN DECOMMISSIONING 0F

~

l MATERIALS FACILITIES l

l RULEMAKING DESIGNED TO REDUCE UNNECESSARY POTENTIAL l

PUBLIC RISK FROM CONTAMINATED FACILITIES AFTER LICENSED l

l ACTIVITIES ARE TERMINATED.

CURRENT PROPOSAL IS TO COVER ALL FACILITIES EXCEPT i

REACTORS.AND WASTE DISPOSAL FACILITIES (10 CFR PARTS l

30, 40, 70, AND 72).

)

CURRENTLY CONSIDERING A 3-YEAR TIME LIMIT FOR COMPLETING DECOMMISSIONING.

LICENSEE MAY PROPOSE ALTERNATIVE ON TECHNICAL OR SAFETY GROUNDS.

END-OF-LICENSE DECOMMISSIONING:

WOULD COVER ALL FACILITIES (AsOUT 8,000 NRC AND 16,000 AGREEMENT i

i STATE).

(

l i

1-l l

TIME'LINESS IN DECOMMISSIONING 0F MATERIALS FACILITIES (CONTINUED) i END-OF-USE DECOMMISSIONING:

WOULD COVER ONLY FACILITIES SUBJECT TO FINANCIAL ASSURANCE REQUIREMENTS IN 10 CFR 30.35, 40.36, 70.25, AND 72.30 (ABOur 550 NRC AND 1100 AGREEMENT.' STATE).

CURRENT PLAN IS TO PUBLISH THE PROPOSED RULE FOR PUBLIC f

COMMENT IN SEPTEMBER 1991.

I t

b i

't i

.j t

[

2 i

m PROVISIONS UNDER CONSIDERATION FOR TIMELINESS RULE l

END-OF-LICENSE DECOMMISSIONING LICENSEE MUST FILE REQUEST FOR LICENSE TERMINATION WITHIN 120 DAYS OF TERMINATION OF LICENSED ACTIVITIES.'

DECOMMISSIONING MUST BE COMPLETED WITH 3 YEARS UNLESS j

' LICENSEE CAN DEMONSTRATE THAT HEALTH AND SAFETY OF PUBLIC WILL BE PROTECTED DURING THE DELAY, WORKERS AND AND COMPLETION WITHIN 3 YEARS NOT TECHNICALLY FEASIBLE, OR SUFFICIENT WASTE DISPOSAL CAPACITY NOT AVAILABLE, OR DELAY WILL SIGNIFICANTLY REDUCE QUANTITY OF RADIOACTIVE WASTE TO BE DISPOSED OF, OR DELAY WILL RESULT IN SIGNIFICANT REDUCTION IN WORKER EXPOSURE.

3 9

7-g 8

e e

END-OF-USE DECOMMISSIONING LICENSEE MUST SUBMIT SCHEDULE FOR DECOMMISSIONING AN INACTIVE AREA WITHIN A LICENSED FACILITY WHEN THE AREA HAS BEEN INACTIVE FOR 90 DAYS.

INACTIVE WHEN LICENSED ACTIVITIES AREA CONSIDERED ARE TERMINATED OR AREA IS USED ONLY FOR PASSIVE STORAGE.

DECOMMISSIONING OF AREA MUST BE COMPLETED WITHIN 3 YEARS.

LICENSEE MAY REQUEST TIME EXTENSION (SAME AS FOR END-OF LICENSE DECOMMISSIONING).

i 4

4

'