ML20134C792

Summarizes Topics That Will Be Briefed Before Joint Subcommittee of ACRS & ACNW by Spent Fuel Project Ofc on 960326

ML20134C792
Person / Time
Issue date:	03/18/1996
From:	Travers W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Larkins J NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW), Advisory Committee on Reactor Safeguards
Shared Package
ML20134B716	List: ML20134B713 ML20134C768 ML20134C782 ML20134C786 ML20134C791 ML20134C792 ML20134C798 ML20134C801 ML20134C806 ML20134C827 ML20134C830 ML20134C837 ML20134C840
References
ACRS-GENERAL, NACNUCLE, NUDOCS 9610080251
Download: ML20134C792 (2)

Text

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. t UNITED STATES NUCLEAR REGULATORY COMMISSION

{ [ WASHINGTON, D.C. 20eeMe01

%, e . . . . $ March 18, 1996 MEMORANDUM TO: Dr. John Larkins, Executive Director I Advisory Committee on Reactor Safeguards and Advisory Connittee on Nuclear Wa!1s a

FROM: William D. Travers, Director I Spent Fuel Project Office Office of Nuclear Materials, M,

V I Safety and Safeguards

SUBJECT:

AGENDA FOR BRIEFING OF JOINT ACRS/ACNW SUBCOMITTEE l This memorandum summarizes the topics that will be briefed before the Joint '

Subconnittee of the Advisory Connittee on Reactor Safeguards and Advisory Coassittee on Nuclear Waste by the Spent Fuel Project Office on March 26, 1996.

The briefing is meant to provide a status sunnary of the activities conducted by the I Spent Fuel Project Office (SFP0) since its creation in May 1995. This briefing will be given by William Travers and Charles Haughney from 8:35 - 10:30 A.M.

'The agenda is as follows:

Discussion of the creation and status of the SFP0 l Current status of SFP0 activities

• Summary of current and expected SFP0 casework Overview of the Dry Cask Storage Action Plan Overview of recent guidance issued by the SFP0 Discussion of additional guidance planned by the SFP0 Copies of the following documents have been provided to your staff separately:

(1) First Dry Cask Storage Action Plan (July 28,1995)

(2) Update to the Dry Cask Storage Action Plan (January 26,1996)

(3) Inspection Procedure 60851, " Design Control of ISFSI Components" (4) Inspection Procedure 60852, "ISFSI Component Fabrication by Outside Fabricators" (5) Inspection Procedure 60853, "Onsite Fabrication of Components and Construction of an ISFSI" (6) Inspection Procedure 60854, "Preoperational Testing of an ISFSI" (7) Inspection Procedure 60855, " Operation of an ISFSI" (8) Draft Standard Review Plan for Dry Cask Storage Systems 9610080251 960326 PDR ACRS GENERAL PDR

J. Larkins ,

The Draft Standard Review Plan for Dry Cask Storage Systems (SRP) was issued for public review, with comunents due by June 14, 1996. We expect to revise the draft SRP and reissue it in final form by the end of 1996. No action is requested from the subcommittee at this time; however, comments regarding the SRP would be welcomed prior to issuance of the final document which is currently projected in the last quarter of 1996.

Please contact Earl Easton of my staff with any questions.

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l Distribution:

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DATE 03/h96 03kM90

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.,1 k UNITED STATES I S NUCLEAR REGULATORY COMMISSION i #

! WASm0 TON. D.C. 20WW 4m January 25, 1996

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r MEMORANDUM TO: James M. Taylor Executive Director for Operations FROM: Carl J. Paperiello, Director Office of Nuclear Material Safety i and Safeguards William T. Russell, Director ffice of Nuclear Reactor Regulati /

SUBJECT:

UPDATE TO THE DRY CASK STORAGE A ION PLAN This memorandum provides an update to the Dry Cask Storage Action Plan originally transmitted to you on July 28, 1995. The Plan was developed to identify major issues and problems in the area of dry cask storage and to -

discuss resolution of such issues. At this time, many of the actions identified in the plan are complete, with the remaining items progressing towards resolution. Issuance of the draft standard review plan for storage '

casks and the inspection procedures is now anticipated in February 1996. l 1

Botn of our offices have made significant progress in resolving the short-term technical issues. Preliminary infonsation and guidance needed to support inspection of dry cask storage activities have been issued. At this time, all immediate concerns in this area have been addressed; however, multi-disciplined task groups have been developed to further investigate the heavy load and unicading procedure issues. These groups will determine whether further NRC actions or guidance in either.of these two areas are needed.

Recently, an open dialogue with the Nuclear Energy Institute (NEI) was initiated to inform the industry of NRC's concerns and expectations regarding utility performance in the area of dry cask storage. Partly in response to the NRC, concerns, NEl established a Dry Cask Storage Working Group. This working group is comprised of representatives of utilities who are currently pursuing or plan on pursuing operation of an Independent Spent Fuel Storage Installati (ISFSI). Periodic meetings with the working group are planned.

Thus far, Wssions with NEI on dry cask storage have been useful, and NEI has been i to propose solutions to the

• long-term technical issues identified .the Plan.

CONTACTS: Patricia Eng, NMSS 415-8577 Andrew Kugler, NRR 415-2828

J. M. Taylor 2 ,

Coordination and communications within the Agency continue to be key elements of the Action Plan. We, and our staffs, have met periodically to review progress on the Action Plan. Conference calls involving staff from NMSS, NRR, and all four, Regions are conducted roughly every three weeks to encourage open staff discussions, identify new or pressing issues, and to develop solutions to these problems. Time sensitive items are distributed to designated Region representatives electronically. Training of affected NMSS, NRR, and Region staff has been conducted on the design bases and licensing processes for ISFSis, with additional sessions being planned for the remaining affected staff. In addition, NRC is planning a workshop to discuss dry cask issues (including recent utility performance), new NRC inspection procedures, and the draft Dry Cask Storage Standard Review Plan.

Two plants are scheduled to conduct preoperational testing of their cask systems in the near future. We continue to place priority on resolving issues at those plants (0yster Creek and Arkansas Nuclear One, Unit 2) planning on completing their dry run testing within the next three months.

In summary, we believe that the resolutions described in the attached Plan are helping to improve the performance in the area of dry cask storage. We will provide the next Action Plan update in July 1996. ,

Attachment:

Updated Dry Cask Storage Action Plan Distribution:

See attached list .

DOCUMENT NAME: G:\ENG\NOV95.UPD

• see previous concurrence OFC ISISS :$FPO* E WISS:SFP0" E IBIBS:SFPO* E leeBSdd E EmEE PErg CNeughn.y Vfr.wors CPaper io DATE 12/19/95 12/19/95 12/20/p5 01/ [ 96 mMM NM MI 0FC Naa:POII* , Imatmp 4 9 % C use:0mma Q$ C meer ano. azi r n L wu...ii DATE 01/17/96 01/24/96 01/24/96 C = G3WER E = CUWER L M nans e = up IXF7 OFFICIA8 Em IXF7

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I l UPDATED DRY CASK STORAGE ACTION PLAN i

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TABLE OF CONTENTS l

1 PROGRESS ............................................... 1 TEC HNI C AL " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 HEAVY-LOAD CONTROUCRANE ISSUES . . . . . . . . . . . . . . . . . . . . . . 4 CASK TRUNNIONS ..................................... 4 HYDROSTATIC TESTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 SEISMIC REQUIREMENTS FOR SPENT FUEL STORAGE PADS . . . . . . . . 5 TECHNICAL LONG-TERM ACTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 CASK WEEPING ....................................... 8 CASK LOADING AND UNLOADING . . . . . . . . . . . . . . . . . . . . . . . . . . 8 OFF LOADING CAPABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 FAILED FUEL STORAGE ................................ 9 SAFEGUARDS CONCERNS ...............................10 COMMUNICATION S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 INTERNAL COMMUNICATIONS - COORDINATION . . . . . . . . . . . . . . -

12 INTERNAL COMMUNICATIONS - STAFF TRAINING . . . . . . . . . . . . . . 13 EXTERNAL COMMUNICATIONS - INDUSTRY INTERFACE . . . . . . . . . 13 )

l EXTERNAL COMMUNICATIONS - PUBLIC RESPONSIVENESS . . . . . . . 14 1

PROCEDURAL ISSUES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

. CHANGE PROCESSES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 )

PART 72 REPORTING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . 16  !

17 i INSPECTION OF SITE ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . .

VENDOR INSPECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 CASK DESIGN AND SAR DIFFERENCES . . . . . . . . . . . . . . . . . . . . . . 18 l

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SUMMARY

OF PROGRESS l The Dry Cask Storage Action Plan was developed by staff from the Regions, NMSS, and

! NRR in an effort to improve agency performance and to increase the NRC's effectiveness in i regulatmg I%t Spent Fuel Storage Installations. The plan identified major issues and j problems related'to design, fabrication, construction and preoperational test activities j associated with the storage of spent fuel in dry casks. The action plan had two basic goals:

! 1. To resolve identified problems and to address anticipated licensing and j inspection issues for dry cask storage.

! 2. To develop and maintain more efficient communications both within the NRC, j and with industry and to foster greater communications on dry cask storage i

issues among industry organizations.

' This report contains the first update since the plan was issued on July 28,1995.

l i Since July 1995, significant progress has been made on the Technical Near-Term Actions. l l Actions to support inspection efforts were completed on schedule, and cask vendors have

! been requested to modify their Safety Analysis Reports to explicitly identify critical design  !

l and testing parameters for cask trunnior.s and hydrostatic testing in their design descriptions. )

In addition, multi <iisciplined workin; groups have been formed to determme whether '

j additional actions are needed in the areas of Cask I.andmg and Unloading Procedures and j j Heavy inada Control. Implem: station of any recommendations regarding the need for j additional guidance in these two areas is scheduled for April and December 1996, l l respectively, i

j Training sessions on Independent Spent Fuel Storage Installations (ISFSIs), including current i regulatory requirements, design criteria, and licensing methods were held in NRC

! Headquarters and Region IV to provide training to NRR, NMSS, and Regional staff.

i Feedback from tramees has been very positive. " Additional training sessions will be held in j the remaining regions and in NRC Headquarters to ensure that all affected staff are fannhar I

with issues related to ISFSIs. Conference calls are periodically held with staff from NRR, NMSS and all four regions to update the staff on items of interest affecting dry cask storage.

Time sensitive information is electronically distributed to designated staff.

An open dialog was initiated with the Nuclear Energy Institute (NEI) in August 1995. NEI subsequendy established a dry cask storage working group which meets approximately every l 6 to 8 weeks. At NEI's request, NRC staff attended portions of these meetings in order to i

i exchange information with NEI. At the last meetmg, NEI was invitea to develop industry positions regarding the I.ang-Term Technical Issues identified in the Action Plan.

i j The Spent Fuel Project Office is currently developing ISFSI inspection procedures and a Standard Review Plan for the review of storage casks. These guidance documents are currently scheduled to be issued during the first quarter of CY 1996 and will clarify NRC's

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expectations for the design, construction and operation of an ISFSI. Publication of these guidance documents will resolve most of the issues identified in the Processes section of the Action Plan. NRC is planning to sponsor a workshop in 1996 to discuss these documents as well as other issues pertaining to ISFSIs.

NRR and NMSS are continuing to work on clarification of how licensee changes to plant programs, fabrication ppm and cask component designs should be documented. To date, changes to casks designated for near-term loading have been reviewed by cognizant NMSS and NRR staff. These reviews have not identified any safety significant deficiencies; however, NMSS is considenng whether to develop additional guidance for review of licensee activities conducted under 10 CFR 72.48. Thus far, the y ality of licensee 10 CFR 50.59 evaluations to support dry cask loading has been inconsistent. NRR will continue to monitor licensee performance in this area.

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ISSUE: HEAVY-LOAD CONTROL / CRANE ISSUES His issue included the suitability and adequacy of crane qualifications at j specific sites, possible inadequacies of generic qualification standards for crane

components, appropriateness of paths traversed by cranes when handling casks d

(hafe load paths), and adequacy of licensee procedures and load drop analyses.

{ Licensees have different plant configurations requiring site specific j evaluations. Interpretation and implementation of existing requirements and 4

commitments, including NUREG 0612 and licensee responses to Generic l Letter 85-11, also varies slightly from site to site. The potential for i inconsistent approaches is high.

i LEAD: NRR with NMSS assistance l STATUS: A working group consisting of two NRR staff and a representative from

Region I was formed. Their charter is to review existing NRC guidance and i licensee performance, identify potential issues and deuermine whether

additional guidance regarding the handling of casks should be issued.

i The Staff plans to complete its review of the existing NRC position and obtain i management concunence on a method of resolution by April 30,1996.

Inspection procedures, if.pyivydate, will be written and approved by December 31,1996. No additional issues have been identified.

j ISSUE: CASK TRUNNIONS T

Requirements for the design and moce testing of trunnions and special l lifting devices for casks were not well understood by affected NRC staff and

licensees. Although each cask design met the requirements, testing

! requirements were not consistently documented from cask SAR to cask SAR.

j This caused confusion during yi+etional testing.

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! LEAD: NMSS i

STATUS: NMSS has historically required that cask vendors design the cask lifting

menschments and special lifting devices to the requirements of NUREG 0612

! and ANSI N14.6. NMSS has included a statement in the Standard Review i Plan for the Review of Storage Casks as a reminder to NRC reviewers that cask vendors should explicitly define trunnion design and testing requirements e

in their Safety Analysis Reports. NMSS has also compiled tables listing the ,

j design and acceptance values for storage cask lifting attachments and special l lifting devices for casks currently in use. Dese tables have been distributed to j

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have been requested to revise their SARs to explicitly identify the design and testing values.

Titis resolves all known concerns related to cask trunnions. This item is considered complete.

1 l ISSUE: HYDROSTATIC TESTING Requirements for hydrostatically testing the primary confinement for dry cask storage systems were not specifically documented in SARs in that test pressures were not explicitly identified in some cases. Also, vendors often did

! not explicitly state the cask maximum normal operating pessure from which the test pressure is derived.

LEAD: NMSS STATUS: NMSS has included a statement in the Standard Review Plan for the Review of Storage Casks as a reminder to NRC reviewers that cask vendors should l

explicitly define both the maximum normal operating pressure and the .

hydrostatic test pressure for the cask in their Safety Analysis Reports. NMSS has compiled tables listing the design and test acceptance values for storage cask pressure testmg for casks currently in use. These tables have been distributed to the inspection staff and affected NRC management. Current cask vendors have been requested to revise their SARs to explicitly identify the maximum normal operating pressure, hydrostatic test pressure and the section of the ASME Code that applies to their cask.

'Ihis resolves all known concerns related to hydrostatic testing of storage l casks. This item is considered complete.

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SEISMIC REOUIREMENTS FOR SPENT FUEL STORAGE PADS I ISSUE:

Under the provisions of the Part 72 general license, licensees are required to vertfy that " cask storage pads and arcas have been designed to adequately support the casks" and "whether or not reactor site parameters...are enveloped by the cask design parameters." One licensee attempted to perform a simple comparison of the reactor site earthquake spectra to the cask design bases without evaluating the spectra at the actual location of the ISFSI. Although subsequent analyses proved that the cask design values were bounding, the NRC determined that the requirements for analysis of the cask storage pad location needed clarification.

LEAD: NMSS with NRR assistance

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STATUS: Information Notice 95-28, " Emplacement of Support Pads for Spent Fuel Dry Storage Installations at Reactor Sites," was issued on June 5,1995. The staff is considenng issuance of a supplement to the Information Notice, to notify licensees that in certain locations the seismic spectra applicable for analysis of ISFSI support pads at reactor sites differs from that used for the plant Safe Shutdown Earthquake.

This resolves all known concerns related to seismic requirements for spent fuel storage pads at this time. This item will be considered complete following determination of whether a supplement to the Information Notice is appropriate.

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ISSUE: CASK WEEPING Transfer casks submerged in spent fuel pools over a period of days are decontaminated upon removal from the pool. Occasionally these casks exhibit recurrent surface contammation a few days later. This phenomenon is hatributed to contammated water becoming entrapped in the interstitial spaces of the metal and " weeping" out over time.

LEAD: NMSS STATUS: This issue currently is not a safety significant issue in that storage casks typically do not remain in spent fuel pools long enough for the phenomenon to occur. Proposed industry solutions to future occurrences will be evaluated as they arise.

This item is considered closed.

ISSUE: CASK LOADING AND UNLOADING Recent experience has shown that some cask loadmg and unloading procedures have been inadequate and of vanable quality. Unloading procedures often are simplistic and may not include sufficient detail for actual use. Few procedures fully account for failed fuel, taking of additional air samples, cask disassembly ami radiation protection requirements. Licensees inconsistently r.pply their procedure writing guidelines to documents governing these activities. Thus far, this issue has been dealt with on a site specific basis.

LEAD: NRR with NMSS assistance STATUS: Issues affecting plants loading in the near term have been addressed as they arise. Guidance regarding inspection of cask loading and unloading activities will be included in the ISFSI inspection procedures. A working group has been fonned including representatives from NMSS, Region III, the Reactor Systems Branen, and the Emergency Preparedness and Radiation Protection Branch to evaluate past experience and to develop additional staff guidance for oversight of these activities.

1 The NRC working group is identifying and categormng observed procedural issues and will provide their recommendations by April 30,1996. This effort ]

is on schedule.

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I ISSUE: OFF LOADING CAPABILITY Some licensees planning to permanently shut down their reactors may choose

to build an ISFSI in order to remove all fuel from the spent fuel pool. Part 72 requires that fuel stored in dry casks be retrievable. This means that plants

! that have decommissioned their spent fuel pools and operate an ISFSI must i have a viable method for retrieving the fuel from the casks for inspection, 3 further processing or disposal. 'Ihis requirement applies even if a spent fuel pool is not available; therefore, such licensees must provide an alternate i method for retrieving their fuel. NRC expectations regarding retrievability of fuel should be clarified and communicated to the industry.

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STATUS: Guidance for reviewing dry transfer methods is being considered. Submittal of an application for use of a dry transfer system is expected in the spring of 1996, and will require NRC review.

This item is considered closed until a proposal is received.

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ISSUE: FAILED FUEL STORAGE Guidelines for the storage of failed fuel or fuel otherwise susceptible to  ;

significant cladding structural failures do not exist. Fuel stored in casks must remain in a coolable geometry for both criticality and cask handling considerations.

LEAD: NMSS STATUS: This subject has been discussed with representatives of DOE, utilities and NEI, who were encouraged to develop a proposed definition of " failed fuel" and to develop a proposal for the safe storage of such fuel. The NRC is currently reviewing a request for storage of spent fuel with degraded cladding.

'Ihe review is scheduled for completion by June 1996. Progress on this review, as well as the projected review schedule, will be discussed in the next update of the Action Plan.

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f J ISSUE: SAFEGUARDS CONCERNS Safeguards concerns have repeatedly been raised by members of the public.

LEAD: NMSS STATUS: The staff completed its analysis of the concerns in December 1995. Final

conclusions supported the initial assessment that current protection levels are adequate.

I This item is considered closed.

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i ISSUE: INTERNAL COMMUNICATIONS - COORDINATION f

j In some cases, communications among NRC offices were incomplete or

ineffective. Some examples of NRC offices not informing each other of j planned inspection activities, issuance of inspection reports, status of technical ,

! , review activities and receipt of intervenor communications in a timely manner

were noted.

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LEAD: NRR and NMSS 1

STATUS: Individuals for NRR, NMSS, and each Region have been identified as official l

points of contact for dry cask issues. Concurrence requirements have been i discussed among NRR, NMSS, and all four Regions. Staff have been

', requested to add a designated representative from each organization to the i distribution list for documents related to dry cask storage and ISFSIs. The

! designated representatives meet by conference call roughly every three weeks i to exchange information and to identify concerns related to ISFSIs. In addition, time sensitive inforn ation is electronically distributed to the designated representatives on an as needed basis.

The roles of the NRR and NMSS project managers h' ave been clarified and I disseminated to NRR and NMSS staff through trammg and distribution of the 1

Memorandum of Understanding. Three traming sessions, including a discussion of the roles of the NRR and NMSS Project Managers, have been conducted: one in Region IV and two in NRC Headquarters. Traimng sessions for the remaining regions as well as mah; sessions for affected NRC Headquarters staff are being planned.

A master schedule of known inspections of dry cask activities, including inspections of vendors, component , fabrication, and licensee preoperational testing activities is in preparation.

No additional concems regarding internal coordination have been identified.

The effectiveness of these initiatives will be monitored for the next six months.

If no additional issues are raised, these efforts will continue as standard 1 operating procedure; therefore, status of this issue will be dropped from the Action Plan.

mis item is on schedule. ,

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ISSUE: INTERNAL COMMUNICATIONS - STAFF TRAINING Many assigned NRC staff had not previously worked on dry cask storage and were unfamdiar with the associated regulatory requirements, inspection activities, and licensing process. General information regarding the design Bases, regulatory requirements, inspection findings, and lessons learned from observation of licensee dry cask storage activities was not provided to NRC staff in an efficient manner.

LEAD: NMSS with NRR assistance STATUS: Training regarding the responsibilities of NRR and NMSS, as delineated in the March 15,1995, Memorandum of Understanding; roles of NRR and NMSS Project Managers; design bases applied to storage casks; the cask certification process; ISFSI license types; status of licensing reviews; and lessons learned through inspection observations has been presented in NRC Headquarters and Region IV. Attendees included new NMSS staff, NRR Project Managers, Project Directors, NRR technical staff, and a number of Regional staff.

Additional sessions, including sessions in each of the remaining regions are being planned. Traming regarding the SAR revision, process, NRR PM .

responsibilities, and the scope and objective of the NRC inspection program was provided to NMSS staff in a separate session. An Independent Spent Fuel Storage Installation Handbook is being prepared for issuance as a NUREG.

No additional concerns have been identified in this area and feedback from staff is positive. Training sessions will be held periodically to accommodate )

staff encountering ISFSI issues for the first time. i ISSIE; EXTERNAL COMMUNICATIONS - INDUSTRY INTERFACE Past communications with licensees have not always been effective or timely. I In some cases, NRC became involved after licensee and vendor decisions, based on erroneous interpretations of NRC requirements, had been made based I thereby causing disputes and delays.

LEAD: NMSS STATUS: Mainierative Letter 95 04 was issued on November 1,1995, to inform the izc sy of the responsibilities of NRR and NMSS pertaining to the oversight and regulation of ISFSIs and the benefits of notifying the NRC as soon as practicable of any intent to construct an ISFSI. These benefits were also discussed with the NEI working group.

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Following a meeting of the Directors of NRR and NMSS with senior NEI staff, NEI established a dry cask storage working group to assess industry's role in developing guidance in this area. NRC staff have since met with NEI representatives several times and pian on meeting with NEI's Dry Cask Storage working group periodically to discuss items of mutual interest.

NRC also plans on hosting an industry workshop to discuss ISFSI related I issues such as NRC's Standard Review Plan for Storage Casks, ISFSI inspection procedures, lessons learned from staff observations of ISFSI activities, and to better understand industry's perspectives on dry cask storage.

This item is on schedule. No additional concerns have been identified in this area and feedback from affected parties is positive.

ISSUE: EXTERNAL COMMUNICATIONS - PUBLIC RFRPONSIVENESS Members of both the public and Congress have expressed concem regarding recent licensee plans and NRC regulatory activities related to ISFSIs. This has been exacerbated by confusion as to whether NRR or NMSS is responsible for answering inquiries from the public on ISFSI matters as well as by poor communications among NRC staff.

LEAD: NRR with NMSS assistance STATUS: The responsibility of NRR to serve as the focal point for inquities from the public associated with a reactor site has been clarified and provided to NRC staff through training and by distribution of the Memorandum of Understanding between NRR and NMSS. Information regarding external requests for information on ISFSIs and .related press releases are routinely ,

shared among the affected Regions,' NRR, and NMSS through the periodic j communistians mentioned previously in this document.

No new concerns have been identified in this area. This item will be monitored for the next six months. If no new issues are identified, this item will be closed.

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The method for approving changes to cask SARs was not well understood.

Some staff members were unfamiliar with the practices and requirements for licensee documentation of the analyses supporting changes to plant programs ind' procedures as well as cask design and fabrication methods.

! LEAD: NMSS for Part 72; NRR for Part 50 I STATUS: NMSS expectations for reviewing and approving changes to cask SARs was l provided to NMSS staff by training presented in August 1995. Inspector guidance will be included in the ISFSI inspection procedures as well as the Standard Review Plan for Storage Casks. 'Ihe procedures and the draft SRP i are scheduled to be issued during the first calendar quarter of 1996. NMSS i may provide additional guidance regarding changes to cask designs in a subsequent revision of the inspection procedures. These documents and the

NRC's expectations related to requests for changes to cask SARs will be discussed at an industry workshop planned for the spring of 1996.

l NRR is concurrently reviewing licensee performance, related to 50.59 changes j associated with the construction and operation of an ISFSI to determme j whether additional guidance for NRR staff in this area is r-7 1

NRC continues to evaluate change prne**m and is considermg issuance of l

additional taWn guidance in this area. Progress on this item will be j reported on in the next update to the action plan.

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ISSUE: PART 72 REPORTING REQUIREMENTS Utilities have questioned whether th'ey are subject to the reporting requirements delineated in sections of Part 72. A formal challenge regarding the applicability of 10 CFR 72.82(e) was received by the NRC on July 28,1995.

LEAD: NMSS, with assistance from OGC and NRR STATUS: On September 19,1995, the NRC informed the licensee that they were seguired to comply with the provisions of 10 CFR 72.82(e).

'This resolves all known concerns related to Part 72 reporting requirements.

This item is considered complete.

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I ISSUE: INSPECTION OF SITE ACTIVITTFS l

In some cases, inspections of site activities under Parts 50 and 72 are not i clearly defined. On-site inspections have been conducted utilizing either j ar

• isting general inspection modules or site-specific comprehensive inspection

! plans. An iaWon program and pertinent procedures must be developed for

oversight of ISFSIs. Also, required resources should be determined and incorporated into the resource allocation discussions for plants expecting to employ an ISFSI.

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! LEAD: NMSS for Part 72 issues; NRR for Part 50 issues; with support from the Regions l

l STATUS: Inspection requirements a 4 guidance for oversight of ISFSI activities will be 4 issued during the first quarter of CY 1996. NMSS is pursuing acquisition of

! contract assistance as well as additional SFPO and IMNS staff to support

! increased inspections in FY96. Allocation of inspection responsibilities among NMSS and NRR staff are being discussed by senior management. NRR is reviewing current inspection guidance regarding on. site programs to determme whether additional guidance should be developed.

No additional concerns have been identified in this area.

ISSUE: VENDOR INSPECI10N Inspections of vendors to ensure consistency with dry cask design requirements have been scheduled when components are near completion. This schedule made it difficult for the fabricator to correct any identified deficiencies.

Inspections were primarily focused on the Quality Assurance Program.

LEAD: NMSS, with support from NRR and the Regions STATUS: fanpar+ian requirements anr1 guidance for vendor inspections will be included in the ISF51 inspection procedures currently scheduled to be issued in the firs.'

quarter of CY 1996. NMSS vendor inspections have been increased in scope to include oversight of fabrication and engineermg design change activities.

Inspection staff have been supplemented by new SFPO staff, Region, and asident inspectors.

Issuance of the revised Manual Chapter 2690, which will provide inspection program guidance, is delayed; however, the delay will not impact ongoing field and review activities. No new issues have been identified in this area.

l 17 l 27 i

ISSUE: CASK DESIGN AND SAR DIFFERENCES Cask Sdety Analysis Reports vary among vendors in style and format. Cask designs vary, and design features and related test requirements differ from cask to cask. In addition, the technical basis for cask designs are not consistently documented among the various cask SARs.

LEAD: NMSS STATUS: Tables of design and testing parameters for the various current cask designs have been compiled and disseminated to the review and inspection staff.

NMSS has contacted the vendors of existing casks to request that they revise their SARs to explicitly state design and testmg requirements. A Standard  !

Review Plan for the Review of Storage Casks is being prepared and will express NRC's expectations regarding the explicit statement of the rationale  ;

and standards used in specifying component design and testing requirements.

This item is slightly behind schedule in that issuance of the draft SRP is now.

expected in mid-February 1996. No additional concerns in this area have been identified. i 18 S$

NUREG-1444 i Supplement 1 Site Decommissioning

Management Plan I

I l l 1 ,

Manuscnpt Completed: October 1995 ' '" ^

Date P6bliihed: November 1995 l

l l D. N. Fauver, M. F. Weber. T. C. Johnson, J. D. Kinneman J

Division of Waste Management a Office of Nuclear Material Safety and Safeguards

! U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

)

~'%

1 / t.

b I b i

)

[f, f +' b -

n

)

1. IPfrRODUCTION

Each year, the U.S. Nuclear Raguisemy ca===iaman (NRC) anst evaluate requests, pnmanly fross materials

heensees, to &socatame hoensed operations ne esponty of those request me rouane, relanvoly

^

i

.-..-..V.1. 4, and amed on in a tunely saanmar sudi that the siens are :==aamad if necessary, and reisesed i for imrestnmed use. However, tenmaanon oflicenses at some sites is = " .;4 more complex bscause of -

the presence of soils and sensems with non-routme levels of ruholopcal cane ==iaseian

! la two reports ma=ated to the Of5ce of the Searetaye dtbe -(SECY), the NRC stafflisted over 30 sites that involve umque and an=k issues requnas specul attannon to ensure tunely '---- ';

l (Thsee reports were SECY-88-308,"Ca=*=== mad Massnel Licensee Fardan= " dated Omober 31,1988, i

and SECY-89-369," Strategy for E---

of Masenals Licensee Sites," dated naannaar 3,1939 )  !

While none of the listed sites represents an inaneeste threat to pubhc hoekh and safety, all of the sites have ,

aa=e=~i=*ia= tim cuoemas exisang NRC cntena for unnutnmed release All of these sites regare some degree of:==aamenan, and several mvolve s+J.;-y issues that r the - must address befose reiensag the sites for unestnmed use and tensnating the app h cable hoenom i

l nose probi,==*= sites have baldags, fanna waste esposal meas, large piles of tanhags, ground water, and i

soil enne===atad with low levels of uramum or thorium (source material) or other rarhamic1=laa l l ra=aarpiantly, the sites present varymg degnes of re&ological hazard, :==aantian complexity, and cost.

i j Sosne of the probiananc sites still have active NRC licanaan, whereas hema == for other sites were already

! tenannted or were never issued. At some sites, the homasse is financially and tach =cally capable of

} compioeng '-- t in a r==an= hic time inane. At other sites, the hcemsee or := pan =h party may l be unable or unwdhng to perfonn '---- - t In adstum, the sites are currently in vanous stays of

=- -- Some fica ==== have already =itimad '- -

while others have not pt planned orinnated the pirocess

! la the staff requir===en memorandan (SRM) deced August 22,1989, r the - &remad the staff to l develop a comprehensive strasegy for NRC admnes to deel with these anw== mad siens in onkr to acimeve

! closurean'--  ; issues in a tandy manner. In a =&aarr-t SRM dated January 31,1990, the j r=====an duecaed the staff to " . subaut a list of anne === sand sites in onbr ofpnanty aciudag the name and

! laratian of the sies, name ofrespaanihla paty, nnaarian of the site, sche &de and descnpanon of the next step in site j cimump, and other pertmut afonnsnon. De list should be annn=p=ned by a discusacm of crasu used to rank 4

cach site."

On March 29,1990, the staff ea=stad SECY.90-121,"Sitenarant====tian Managenent Program," as j the original report authnag the planned strategy. The staff updated that report in April 1991 and May 1992, with the ma===ir= of SECY 91-096 and SECY 92 200, both centled " Site E--- ' ==~ = ~ -5 Mn l Plan"(SDMP). De staff again updated the report in June 1993; however, to faciheme distribution to j menested parties, and to simplify future refenece, the update was published in October 1993 as

NUREG-1444,"Siesn.na uni ianmg Management Plan."

j NUREG 1444 ocataned dotaded descnptions ofeach site, and Aar===ad all policy issues that have been i addressed since the inceptice of the SDMP in 1990. The NRC ine==h to supplement NUREG-1444 l bienmally with cunent informanon about program issues, site status, and erhaanlem The supplements will

also escuss program ====g====t actmnes, as well as "

--"- activities ra=Airmad at each site j over the pncedag 2 years, and progrees on remammg open issues This rgert, NUREG-1444, j Suppl ===r 1,is the first of the planned bu==al updates.

i 1

1 NUREG-1444, Supplement 1 4

i

/7

1

2. SDMP PROGRAM MANAGEMENT 2.I Pr a h' - - - =- Plan ^

This earenn discusses the objectives and bec caround informstron underlyng the NRC's plan for managmg the daan-minevemg program. Sectum 2.2 tan addresses specafic program inliives.

2.1.1 Objectives lhe NRC's ;,.J&ny program for '= -d ashthe followag objectives e Safety and Dawliness - Ensure tunely and safe b- J::i.--.i oflicensed and i=1==M sites that are nnne===meM with radioactive matenals ==anantM with the pnaar==== and use ofsource, special naclear, and byproduct matenals e Documentation - Ensure that '=----- aaxmmg heiaan are thoroughly don-neM to develop a record that will withstand the test of time and avoid transferriag a burden to future generations to

' redevelop information on the radiological status of formerly Iv-M sites.

• Coordination - Coordmate '- - - - =nomng actions with other regulatory agencies at the Federal, State, and local levels, with interested parties, and with n=mhers of the public to promote efficiency and finality for darn ==isev=mg actions e Minimal Burden - Mmimme the regulatory burden unposed on Iv=ece and other responsible parties consistent with amamplahing the other objectrves e Review Capabilities - D velop and mame== NRC review emp=bih, as required to fulfill the objectives of the da--- - ==6sa: program.

The management plan idenrihn approaches that can be used to reduce the level ofNRC resources devoted to dann==ieniomng, while ensunng effective oversight of 4----d==ianing projects listed in the NRC's SDMP and other sigrufkant da~===i==ionmg ac*v== at matenals facilities.

2.1.2 Background Over the last 5 pers, the level of NRC resources devoted to the SDMP sites and pohey issues has increased, reachmg a maxununi in Fiscal Year (FY) 1993 at 48 full-time equivalents (FTEs). The budgeted FTEs include overhead (ciencal and admuuntrative support, as well as ==amaamaat at the Branch Chieflevel and above) and time -- g - 4=' on activities such as staff development, professional maetmas, general adrmmstration, annual leave, arid sick les /e. Actual direct efforts have been far less than the he levels (e.g.,24 FTEs in FY93 for all matenals '- - - 'ioning).

These resources are distributed between the Office of Nuclear Matenal Safety and Safeguards (NMSS) and NRC regional offices (pnmanly Regions I and III). Staff members have a full complement of techmcal and regulatory expertise in the areas of '- - hioning, environmental and epo.awial health physics, nuclear engmeenng, and earth sciences 3 NUREG-1444, Supplement I

4 i

in addeon to staff resources, the NRf, has acquired techtiical support by contracting with Oak Ridge lam *uem for Science and Education (ORISE) to conduct radiological n=====*v (e s., con 6nnatory surveys). The NRC has also contracted with Oak Ridge Nauen.1 Laboratory (ORNL) to acquae *=4=ical support for

]

i ted;;i ; envuommental unpact statements (EISs). In FY95, the tednucal support for theos two propocas totalled appanumsesly $3 nelhos. An additional $160,000 ofocatractor effort by ICF, Inc. is requered to support staffreviews of financial assurance h and special cases.

I Under exisang procedures and pohcasa, the NRC staff typically nmows site characteruation plans and

reports to ensure that hoensees ime ===hh=k=8 the examt and type (s) of radmiosscal corzeumation before l nutianas remedission.

• Site characterussion provides the basis for developmg the :====hm- or

=-

]

plan, windi is typiceDy =d==*eaf as a hosase

• request for a finanand site where

!  ; procedures beve act already beni approved or where ' -- --

could resultin j unpacts (such as efDumas or doses) that have ao

basa enveloped dunas openmans. He ?--- -

i process is illustrated in Figure 1.

1

{ P==-hh beges once the NRC has approved the hoensas's ' = -; plan. For bosnood sites, j approval of abe plan is impb==anaal through a lumnse i====baam mabarung '- -  ; laissuing the ====b===e the NRC staff misy offer an opportusty for a hennes concenung the --- - '-- ". and may j mchade a '- - - ; achadale as a heense candshan To promote broad =anqv==a= and finehty of the planned actions, the NRC coonhasses extensevely with State and local authonnes and other interseted pernes i in renewing and appnmng the f+  ; plan.

l At the a=chmian of the remedial acnons, the hcensee or site owner conducts a termaance radiological j survey to demonstrate that residual rehity levels have been aufhumely reduced in acconlance with j NRC cntena. De NRC then conducts a confirmatory survey to confinn the results of the bonnese's j ternunstion survey. (Confirmatory surveys are either Eiulucted by NRC staffor under contract with ORISE.) I i

I i Despite the dedicatman of an increased amount of NRC resources and ==hanaat exponence with

=-

- ' ; prognes in :====hahng the sites has not amt the awp=*mia== of the NRC or the pubhc Delays continue for a variety of * ' legal, and pnhey-related reasons in addition, several:==adisian projects have been placed on hold pendag completion of EISs that j assess the envran==*al unpact and alternatives to onsite disposal of the radioactive waste.

j -

i At present, the number of sites on the SDMP list is increaring faster than sites are being remediated and j released. In perucular, sites are being added to the list as the regions review sites for which the hasmaan were initially tenannted without mifkiant rachological surveys or h===dmiaa to confirm that resuinal naar==inahan levels are acceptably low.

I i

i i

t i

l i

d I l l

1 '

j NUREG-1444, Supplanet 1 4 4

~

Cessation of Operation v

Site Characterization Plan v

Site Characterization v

Site Characterization Report v

Decommissioning Plan &

Environmental Report v

Decommissioning v

Final & Confirmatory Radiological Survey v l License Termination

& Site Reicase Figure 1: The General Deconumssioning Process 5 NUREG-1444, Suppicment 1 O

l i

i Budget ndamans and ==p=**>aa betwea: NRC programs have forced the NRC to evahme whsdur a mo cf5cient and cost <ffedive

.ec4y approach could be used to oversee site runnediation while ensunng the d saene level ofpubbe protecton. In the FY% budget, for example, the NMSS has been forced to redace i

fauhng for ORISE confmnatory surveys by 66% (.,,, ---

""y $2 sadhon) froen basehne fumbag. In i

1 addman, canassent with duecaco frees Congress and the Of5cc of Management and Budget, staffresource

' dedusted to the SDMP program have beni capped at existag levels to ensure that suf5cient resoscos will be avadable to support other NRC programs dunas FY% through FY98. At the same time, SDMP resources

are irc.--- fj being tapped to support non SDMP work, such as revmw of fonnerly ta===aad !==ad

' sites and more routine '- - - ;prosects. TheNRCstaffisalso-:- '

-g rd.m g support of mobde and fbed laboratones operated out of the NRC regional of5ces 4

2.2 Prnaram I=Ma6es This necean chacusses the followag -- "; program nutistives-

{ e procesares for '-- - ;

j e revised perfonnancemeasures

e site characternetico remews o contanatorysurveys j e busmens process redesign e theinteracove runoluhon process e prehmmary haards analyss

! e the SDMP database j

• deferrels to Envv=====*=1 Protocoon Agency (EPA) and other programs

~

2.2.1 - " -

i Procedures for =C+u...xne ~-tm 1

l The 19g9 General Accounting Of5ae (GAO) report on '- - -

idanrirmed thelack ofpeaceduns as a pnncipal AE=y of the NRC's regulatory program for '=- " ; nuclear matenals f=ld= 1he j

GAO expressed concern that the NRC was not ensunng a thorough and effecove evalumboa ofrendual raar===amiaa levels before tennestag hoenses and reisesag sites for unnutncsod use.

i The

' NRC staff has gamed considwabic experience over the last 5 years in overseems the SDMP and other

-_+-

' " ; activities involving sigmficant radianceive =d-ia=tian In addniaa, since the inaption of the SDMP in 1990, the NRC has pecamigsted new regarements on financial assurance, .w "

l and t=al=a== for ' - ci

-; materials facileian Further, the staffhas developed speafic procedures, i

standard nmew plans, and regulatory guulance on a variety of topics related to '- - ;matsnals

}

fele= and SDMP sites. The program has now matured to the exism that dewsarmane of armadard j proceduns for '- - --

is appropnase and acinevable.

M=Sars of the NRC staffin the low tmel Waste and r=-  ; Projects Branch (11DP)are j

ourrently developeng a comprehensive Manual Chapter to define the pmooduns for A-- ;SDMP j sites and other heensed sites that used nuclear matanals. The objective of the proceduns is to prensate caa=> mane and af5cust regulatory reviews conowmag dana =wmaanamag actmhos lhe proceduns will also j

promote adurance to a consistent pohey and set ofprecuces for ensunng safe and tunely ' - ^;

j in

'= adadian, devasal==* of the procedures will transfer exponence freen the SDMP program for use in

other nuclear matsnais facihues and sites, anchuhng unlicensed sites with elevated levels of j

======rian from sourec, special nuclear, or byprodud matenal use.

i 1

3 The Manual Chapter will provide a randmap for NRC staff to follow in coonhnatag and reviewmg l da====iamag acuans in addition, the Manual Chapter will direct staff to consult estabhshed refenmoe i

NUREG-1444,Supplanent i 6 j

1 JI 2

1 da"'a'=" ach a '=M ,

r=+= proceaum, pohey and guisme decoves, #=d=d revww plans, agulatory salm, NUREGs, and odur du--ra that prmde spec Sc crums for evaluenng the adequey of

,na,,

A prah==ary draA of the precedures to be included in the Manual Chapter was cuculated to headquarters and reiponal amens, at the stafflevel, in June 1995. %c prehnunary drah wm escussed dunng an NRC caianerpart mesang =had..h.d for July 1995. De Snal procedes will be issed by the end of 1995, and will be p 1 by the NMSS and NRC's regmaal odices ImpI===new= of these proceems should resolve the procedural aar---- prmously ia=*.r=d by GAO.

Once issued, the NRC staffmsy rmee the procedures from time to time to monet sigm5 cant develar==ta in the '  ; program, such as the ==.-6-a to the standards for nodual raboscoyny estabhahad by the Code offederalRegulattomt, Title 10, Part 20 (10 CFR Part 20).

2.2.2 Revised Performance Measures De Government Paformance and Resuks Act of 1993 (GPRA) ===Imean the use of performance budgeeng by all Federal agencus by FY97. As part of the approach reqmrod by the GPRA, agencies are requued to idennfy, implement, and evaluate performance of government programs using erw* performance measures  !

Dese measwes me supposed to anpham* "amenma" (that is, the quality and impact of the program), rather l than merely " output" or "annaa-y"(the number of tasks -npletad or the unit cost of completag the tasks,  !

respectively). De Ad===erahon's Nabonal Perfor=== Rmew sandarty focuses on "me==e" by i anphasinng responsivauss to a=ea==s, redecmg overlap and regulatory burden, and *=hannng the d"'1-- y and effecoveness of governeunt programs Since the incepoon of the S'>MP, the NRC has used a single performance measure for the program, namely the number of sites da===anianad and removed fresu the list of sites an=ta=~l in the SDMP. On the basis of this measure, progress has been limited. To date, only Sve sites have been anaaely r===hamadt o be resnoved fhxn the list. Other sites have been removed from the list for progrs==new reasons For example, Kest-McGee's West Clucago site was removed from the list when regulatoryjmeducon for the site was transfered to the IHin=a Agr==-e State program. However, the NRC did not take credit for removal of this site because =*===arian at the site was not ranadisead or ensured before the site was removed from the list. Other sites have fully or partially completed r=~Maa. but have not yet been removed from the list for a variety ofreasons-From an objective *=adpa=e the ==iher of sites removed is an inadequate >formance measure for the program, and only partially reSocts the overall objectives of the NRC's da===ienian=g program (see brenan 2.1.1). In particular, this measure only evaluates output, and yields little or no insight about the quahty of NRC > L = For ===ata, the NRC could accekrate approval of ? - -  ; acuans to improve the apparent performance aganst the measure However, such an acceleranon aught sacrifice the desmed outcome of a safe, w" 1 '<----- -i and final 4=-  ;

In addition, a perfonnance measme based on the number of sites removed only inecates an=phenan of the i======innmg process and provides no indemev= about interum progress. As a result, this measure is not useful for assessag parfonnance at most sites that are at earher stages in the " = -- -- ; process In -

fact, as the NRC staff ~===ead in rmeweg a draA GAO report on the SDMP program in early 1995, use of this measure ignores the anamdarable progress made in completag rmews of site characterization plans and reports, dann===eianmg plans, and termmation surveys, where the bulk ofprogram resources haw been dewted awr the last couple years. Successful completion of these earlier milamenaam is a necessary prerequisite to cunpleting dann==ianianmr in a safe, timely, e,erh4 and final manner.

7 NUREG-1444, Supplement I c2 b

i 4

1 0- - - - - 9, the NRC staffis developing alternative perfonnance measures that will better track the proyees and autoosne of the NRC's masonals '

propam in gameral, and the SDMP proyam l in parnoular For exasspis, the stafTis consulenna abanienve maasses that would evaluate propees in j reviewing and appamag '--- --

plans.

, 2.2.3 Sies Characternation Revwws i

i %e perfonnance aflicensees and site ossers listed in the SDMP varies significantly. Some have j I

=T ===a=8 effsenve programs, staffed by campstest profemmonsis, that me enskas tonely propass in ranedianag =*h sites. At other sites, vanous factors have resuhad in nuore housed or non austent prognos.

Recosaamag this significant vanabihty in the perfonnance of ha====== and sies owners, the NRC could conserve its resources and reduos hasasse fees by conducnng less in<ispth reviews c(lacensees that exhibit a highlevelof i f - -- SpamAcally, the NRC could ressee the enount ofoverught cunently devoted to reviewing site characteruanon plans and reports The NRC ==ph=M he t need for early and omsomg coonhannon betwem I- and the NRC in planung and condmeng site characteruanon. For example, the SDMP Accan Plan, released in April 1992, encouraged such interaccons and =4==.==== of charasseruanon plans for NRC reyww. This approach was based on the NRC's exponence with '= - - ; SDMP sites, as well as the expenance of the EPA and State agencies in the barardous waste and Superfund programs.

Since the SDMP Accan Plan was released in April 1992, the NRC has devoted considerable attennon to site charasserusban at both the genene and -46 levels. In November 1992 and Novanbar 1994, the

, NRC aa=A=*=8 pubhc workshops canoenung the SDMP propan that isansed the importance ofeite charasseruanon to the sunomes of ' ---

In addinon, the NRC pubhshed prelumnary draA guidemos on she dieracteruanan in July 1992, as well as the "DraA Branch Techacal Pompon on Site Characterustaan for D----- ' ;"in November 1994. The final rule on "Ti-al- in C=  ; of Maesnais Facihnes" p=hl=h-i in the Federal Register (59 FR 36026) added a regenmaant to subant characternanon data with the '=- --

plan. De NRC has clearly an=hiM and --=e=a=8 apar*=*ia== to the hoensees and other respoemble parties for site characteruanan in y g_s=  ;

De NRC {---?-- ' these genanc efforts by revwwmg nummous site characteruanan plans and reports for specific sites between 1992 and 1995. In typical cases, the NRC staffiavested .n - / 'ione-half to a full,, e J of effort (spread out over several months)in rmeweg each she charasserussion plan and report. Ahhough the reyww raised enha*=ative issues that requesd r==ahvian by the hoensees and re=pa==h partes, they proved costly and delayed '-- - -

that could otherwise have proceeded in paralist with resolving

ug issues. In addinon, uhamme resahmon of some issues depended upon the boensse's prefened approach for '= ' ^ '- . wiuch is not ===hh=h=8 until the hoensee submits a proposed '= - ; plan. In some cases, such as the Rah-* A Wilcox (B&W) Parks Township Shallow land Disposal Area (SLDA), Aar====a== about site characternanon issues were placed on hold psahng the hasasse's me=====ina ofits , .L.w.J approach.

As an abernative, the NRC plans to forego rmew of she characteruanon plans and reports for I most -

and :==paanihie parnes lastead, site characteruanan infonnsoon will be canadored in the NPC's revww of the '=- --

plan. His ahernative is enanimaar with NRC regulariaan, which reqmre characteruanon das to be submitted with the '= - " '; plan. -

NUREG 1444, Supplement 1 8

.._ ___ O k_. -

The NRC's abernserve appmed will also promoes a more coordenand and focused revww of sies i derammene informanon. This is became renewers will be ar=l=lbd to emphenne issues that affem the seneman and' /- W of a '- -  ; approach. (By comerast, the current appread allows renouers to ecosider neues that are more acadamse in nature med may have little beenng on assual personnanceof' --

!  ;) As a result, the new appress will allow the NRC staff to focus on the

'+-

'"; plan renews that me amore armeni to ensunng protoman of the pubhc and the eenronment .

The new approod may delay i<l=eir-e- of agesfloant afonashan gaps. However, the NRC will partially sv=y===a. for this risk by imzonsag rouane contact with beensees through she visits and meannes in addman, the NRC will pey haghanned attenhan to hosasses and :=r===Ma pernes that beve lower levd: #

perfonnance Resources thus conserved will then be focused on snes needag secreased staff senawa or on

{ otherNRC pnonbes.

The NRC would generally use the foBowmg cntena to idenhfy a licensee or :=p,==ad, party warranong hughtsmed attennon dunas site charactenzaban planung-l (1) a Seventy level 1, II, or III notahon on the most recent ==pr+=

(2) issuance of an anler or other a=ral=ed enforr===r on the most recent aspecoon, or based on a boensmg renew or petman response

, (3) aclusion of a " management paragraph" in the cover letkr transmittang the notice of wolauan on the  ;

most recent ==g=r+v= a managanent paragraph requaes that the I- describe how it is '

ensunng adequate ==ag==ne control ovw the tww==d program (4) occurrence of a sigmficant event requanng a reactrve ==per==

1 i

(5) repetitive v=ist===

(6) falure to take appropnate short-term correcove measures to nutissee or control ensung

.. .. . . . resukmg in current pubbe doses that are a significant fracace of the pubhc dose limit or that are actively migranng in soil, gr-W , or other arvui===tal media

~

(7) lauted na= rial and ancha=1 nabihty of the housee or responsible site aumer i

The goal of these cntena is tc predict sites where past perfonnance subcates a lindiharwl that charactenzaban may be inadequate or incouph For these sites, it will likely be more e&=ar to apply staff resources to earty renew of the charactanmm plan dnM by the inw==ar or neponsible party.

In m/=htv=, for some sites, very laused informahon may exist as to the type (s) and laraav=ts) of rv=e===atum pneant. This infor.aanon shortage may result from a lack ofindmdmals with ia=rmur==al memory of operamans and wases disposal practaces at the site, or from a lack ofrehable reconis. This may be i

the case for a mir-Ac=* number of the sites idenafied through the onpoens NRC renew of files concermag tenmasted masenals i======

i Another probian at the sites irlaneirmwl through the ternunated house renew is the las of an orgn=ratv= with mme with the EPA's new approaches for overseems ran=haenaa at Superfund sites or in hazardous waste facahty amaam==na and conectrve schon prognuns la some cases, an iadaaa~i-* third-party may be involved to confirm the results subnutted in the heensee's teraunat= survey.

Unless a housee vohananly ena==*= to i% twi,ey samphag, the NRC may need to resort to orders to roquae such surveys whenjustiri=I on the basis of health and safety considerations.

For SDMP siess, and ottur complex darnmminaianmg cases, the NRC staff will enarh=* a routme cla===*

==part= before tennmating the beense. For less complex cases a clan ==* ==part- may not be needed.

When required, the inapa+= would typically include general area scans using appropriate survey equipment (such as handield or large-arcs floor survey probes), hmated fixed menswan=*=, and random samples collected from anos -impa ead of havag elevated ===enan levels.

ImpI=aaneneian of this approach incurs some increased risk that sites could be released with elevated levels of resuhaal radianerivity in isolated " hot spots." Past confirmatory surveys have id-niriad hot spots at a ==nhar of sites. These spots have been hauted, and in most cases did not poec sigmficant henkh and safety enanerns Naamhelane, release of sites with hot spots could increase the hirelihand that future land owners, or other mienstad parties, may deem it neassary to reevaluate the site.

I1 NUREG-1444, Supplement 1

i i

i The stas behoves, honever, that the prs =al is now that sudi reevahmw= would utentify a sigmficant risk to

{ the envuoansme or pubhc bankh and safety. This pr=*w= is supported by recent staffefforts to develop i risk 4esed sesshods for evalustag hot spots. Prehmanary results subcate that, for many cases, current NRC l guidance on the mar =re=hla levels afradioactivity in a given bot spot is commervanve, and may be increased

vnthout excomhng current '---  ; does ansria. If the hot spot gedance is revised to allow hisbar i )

levels af radmaatsvity, the probabihty of a site being subgen to future aupanes should deamese, and the risks j of redeems the scope doonrnestory surwys should be songssed.

Radmosag the scope of - ?- ^ -f surveys would also decrease the svedabihty ofi=dTaad=*

A-==**= demonstratag that a sine meets NRC creena. This daa==ne== bas, in the past, been shown to be reassunng to thepubbe I The NRC will mensee timese risks by insseemag emphasis on the review ofliosenes da===me== cf ternunation surwy plans and repnets, moinding QMQC reconis asoessary to confins thes the program renamed effumve throughout the arvey. The NRC will plans the grossest emphens en heresses or

=Ta==* params shst ediiba poor parfannemos bened on past expensmos, sociedag the results ofNRC i inspemaan dunng the lissesse's ternanshan survey. The NRC will also comedor amnesag the scope of l confanatory surwys for hoensees or responsible pertans where past expenamne adicates a potential for l =d==*emi ofi==d-p=aa or iman=pA* ternunataan surwy data.

i l ladspomles asesuremmes collected by the NRC dunng the boassee's survey and any adAew==8

meannemmes cell cs d dunng the classaut ==r ~= could indicae elevated ~w===== at the nues. If E

l , - = commat be reeddy resolved between survey maassumasmas, the NRC may reques (by anier) or j request that a hosames or :=Ta-M party combiet ada*==al =dT==8=* surwys to confine the radiciassoal

status of the site, or the NRC mey itsoif condum a more oosuprehemsrve confinnesory arvey Tuning afsuch ,

a arvey will be detsnamed by the svadsbihty of fnuhng and other program pnonnes Such a survey could l result in =4t==*=1 delsys and - unpacts on hoensees or smyannihie pernes before release of the j sites.

}

2.2.5 Bumness Process Rademan J

{ Appiacetaan of the Bumness Process Redesign (BPR) approach to the current hoemmag process results in a "y acw heenmag process for reguisang soutme uses of tw===ad enemials This asw heemmag j process, summanand in SECY-95 114, ----/ - i= of a Radosamed Materials Lacenang Process,"

j dated May 5,1995, is composed of tbree aupor ~=aT*=

1 l (1) a Rapistory Produm Design Cener wbme ta4=& cal ma=hers of the mananals beenmag and

= Tare == ar====iey een inseract, in boek vetual and amuel speos, to damp and prepare regulatory j products necessary to aqsport, ma=*=n, and embana the new hoemmes process

] (2) unproved processag o(licenses through reviewer perfanned and computeressisted heenses, using j a graded approach --ste with the safety hamrds posed by the appbconon (3) a new way of woriang in Apacy-wide teams

{

I i The NRC staff has used many c(these concepts to ovesse the n==aA*= ofmost SDMP siens. As new

! concepts and ==rhad= me developed rto shew the pels of the BPR propos, the staffwill evaluate their j  ;;N2Wto the SDMP program.

The samffcurrently plans to explore two specific mees wimre the BPR protect may have near-tenn j sppbcabihty to the SDMP pmgram. First, the staffhas begun explanag the possibehty of using a comrector j

i j NUREiG-1444, Suppiament 1 12 l

22

1 i

i, r

to amheme a funcemnal revmw of the SDMP program to identify handaN= trad turnarounds, and assess the j proyees of the program. Second, the staffplans to explore the iden of formag SDMP J+-  ;

i sannagement tessus As curandy myimoned, these teams would canast c(staffmembers frees NMSS, other l Headquarters OfBoss, and the Ragsms, with 2----

exponence and regulatory /boenseg

. "'i for abs SDMP sits. These teams will 6=enn in the same manner as the BPR Agency wide i teams, managing by exception, reaches collaboretrve W decmons, and employag parallel

] concurrence to expedite the evaluation and approval of J--  ; plans and reports.

i l The SDMP and BPR proyam staffs have been discussag, and will aa=*=ne to discuss, the applicabihty of

, the BPR concepts to the SDMP proyans, while moveg forward with the staffs arrent untiatives The staff i also plans to conduct siinitial ========e concemag appbcation of the BPR concepts to SDMP, in

] coagunction with its revww of heenseg mid i==parenan prognens under Phase II of the National Performance j Raymw. Rasults of this ========* will be available in March 1996.

i l The staff =*iey=*a= that, as the BPR sul SDMP programs aa=*==a to mature, there will be several l opportuness to incorporate into the SDMP the ==shada or concepts developed under BPR. In order to keep

{ the r a==uaanan aformed of the staffs efforts,the staff wiu discuss the application of the BPR concepts and l

j methods in future SDMP program updates

, )

2.2.6 lateractive Resolution Process i

! in March 1995, the NRC staff met with the Nuclear Energy lastitute (NEI) and Fuel Cycle Facihenen Forum

! -(FCFF) to discuss ==pl===e=enan of an interactive issue r==ahmaa process The obpectives of the process j are to share information about genene or specific precedents that may be of general eterest, mid to exchange l

mformation about omsom8 ""P'"==entian of the ---- " '; program outside of specific ralanalang j andlacasmg actaans j

l The industry is currently developeg a list of sparenc ==planan*=tian issues for NRC consideraten. The NEI j and FCFF tr===*eal he t first set ofissue worhhaats on June 6,1995. An open meetag between the NEl, j FCFF, and NRC was held on June 13,1995, to discuss these issues, as well as planned gmdance dar=neate i

and pohcy pamtia== These diac===>a== were the prelude for a more interactive process for developmg regulatory gmdance on issues ===arimead with 2-- ---- - ==:=M such as methade for deternames background

r=<haeian levels, modeling potential exposures, ea=hia= survey measurements, and implananrmg the tunaha*=s rule.

l

) On May 4,1995, the NEI proposed to the Comnussion that the NRC use a samalar meeractive process to j develop regulatory gmdanar dari===ta that implanant the final rule on :adiological criteria for l J+ - - =" ; The NRC successfully used such an approach in d 4,-g the regulascry smdes that implernentad the 1991 reymons to 10 CFR Part 20. This interactive process should cannerve staff resources by casunng SilAlhaane of the following objectives:

(1) i ic===== and responsible parties are aware of NRC staff positions on vanous issues before 1 prepanng and submitting daenami==ioning and survey plans.

)

(2) The staff applies a enneinter, streamhnad set of procedures and pohcies in reywwmg proposed l

i daca==nieeianing actions

)~

(3) Staff efforts to develop gmd=are are responsive to progran needs, and provide constructive apprnachen for resolving issues associated with darnmnussionmg.

i i

4 13 NUREG-1444, Supplement 1 i

i

j i

i J

l 2.2.7 7.hyHazards Analysis 1he NRC will develop a more dotaded nwhM for assescing risk at sites id-eirwl through the ORNL and f

NRC staff review of tarmmated tw=== (Secten 4.1.4) that are confinned to have residual -dammmm j from fonnerly hoensed openecas lhe purpose of the risk =aa===t is to deternune if remdual

-w===*ian =*= mad in a relatively small ares poses a sismficant risk to the envuonment or pubhc heakh

)

' and safety, and whether it warrants add *ianal action by the responsible party and the NRC.

i

) Any site idantariad through the tenmassed heense review project would regare r==adia*== if the average

======enan level exceeds the gedehne value at the 95% mnrut=na level However, for ongoing

. da=====w mg pra,ects, addeonal:==adimu= may also be r====== dad if tacal==i =wa=mmesaa

' exceeds the averagog cntena described in NUREG/CR.5849," Manual for Conducamg License Ter===atw=

in Support of License Ternunat== "

The averagag gedance in NUREG/CR-5849 was designed for sites that have widespread =wa====a==

i This gudence is used to help plan the site r==adimenaa and deman the survey to damaamrate comphance with dart ==manianmg cnteria (termi==enaa survey).1his sindance may not be appropnate for sites where a i

license wasr. s y termmated. In such cases, tacalimi areas with elevated matommatian levels may be acceptabic, on a risk basis, dependmg on the total inventory present, the size of the tacah=d ====natad ,

l '

area, the r=du==rtide of concern, and other factors The staffis perfarnung a more detaled evaluation of the risk -atad with tarah=d aantammarian as a part of the develwy

of the MARSSIM discussed in Section 2.2.4.

j Before requestas that the hoensee or responsible party perform additional site d. w.zation, and possibly

---==e of tarati-1 ==e====*ian j . 9%it iq W that the NRC conduct a more dotaded risk

for three reasons' l (1) Desaded risk ==an===t is maa>at=t with the r an====='s duestion in the 1992 SDMP Action j Plan to answe finahty in damnumanianmg unless a sigmficant unpact on public health and safety is i

i vieneirind A

i l (2) Perfannmg additional characterirarian and renadiat= for a very low-risk site may regare an unnacman=y expenditure of resources and cause undue public cenarn. ,

l s

l Detaded risk amarap==t would set a desirable precedent as to how the NRC will respond to future i (3) discovenes oflow levels of anae====t= at sites. l q l l

The staff will consider fanarly ter-manad tv-aad sites in a two etep process First, after determmmg that a  !

j site =*=== elevated levels of remdual -wammarian the staff will conduct a prah====y maam==ent based on avadable aformation to determme whether additional charactenzation and r=naeme= are -a-y.

j Some sites mey have such mmimal levels of =*=maata that they do not pose a sigmficant risk and do not warrant additional action. The NRC will daci=nent these findags in a letter to the cumet property owner and

) the fonner liammar i

! unand, for sites that warrant additional d w;sratv=, and possibly r==adiat=, the stoff will perfann j

additional hazards analysis to identify thoes that should receive prompt met-t= and higher NRC priority.

The hazards analysis would be maAread based on available infonnation (including scoping surveys) by j compenng site conditions agamst the following priority criteria:

(1) The site currently emeen doses to wwmhers of the general public in excess of 50 mdhrem/ year (total j effective dose equivalent), or 50% of the NRC's public dose limit in 10 CFR 20.1301.

l NUREG-1444, Supplement 1 14 c59

(2) The sies currently exhibits measurable migrataan of re&olopcal enatamme== to groundwater, l surface water, soil, di--+ or other an;,-- ==I me&a.

(3) The =pa==ihta party lacks the financial and tachancal capabdity or manag-a er nammmmant to 4 ansure secunty and control of the <=ta==ated matenal. l Compared to other <=e===stad sites that are added to the SDMP or considered to be more typecal

-f=- - "; cases, sites that most may of the above cntens would reconvc lugber pnanty canadorataan by the NRC for revwws of proposed-f--  ; piens, site charactenzation data, and radiological surveys raneammmend sites that do not satsfy any of these cntens would be bacidogged for reviews, and i addressed by the staff as the higher pnanty sites are resolved and as resources become available. This approach will allow tae NRC staff to focus on er=tammatad sites havag greater risk, while aantammr the siac of the SDMP and 4=- - "; program to witius existag staff budgets.

2.2.8 SDMP Database Over the past several years, the NRC has manually tracked completion oflicanamg actions and other

~- '

-f+ - ~ ; maamnaas in the SDMP program. Dunng this penod, the staff has received frequent i requests (from the C-- Ra Congress, and outside parties) for status informatum Such requests have required considerable effort in revieweg the beensmg dockets and protect fdes to compile the requested inform =m-In 1994, the ggagimtistad dcg '___-=^ of a u ugnMvg datahame management systegn enntammg informatma on SDMP sites. The prototype datahane has beni dee;ispd, using the Macrosoft ACCESS compuser program, as a cooperative effort between the NRC Office ofInfonnation + Jeources Managanent (IRM) and NMSS. Status information and other site characternatma data will be loaded into the Adahaw and routmely mamtamed by licensms amenaeanen in LLDP.

The Ad=hama will be used to produce peno&c reports to NRC management on SDMP accomphahmm*= and status, as well as the annual reports to theenn=manian on the SDMP. As such, the datahame reports will

=hm*uee for the more labor-intensive descnptions of the individual SDMP sites that have been inchidad in previous reports on the SDMP. In addition, the datah=* will be used to respond to internal and external requests for infonnation concernmg the status and charactenstics of the SDMP sites. (The most recent request was from Senator Glenn in a letecr dated May 8,1995, with the response from the Cammianum dated June 22,1995.)

Mamtananne of the datahaw is ai-w to require about 0.2 FTE manually Use of the d=*aha- in place of the individual site desenptaans and manual searches of the files should save about 0.5 FTE per year.

2.2.9 Deferrais to EPA and Other Programs la SECY 95-056, the NRC staff raer==nandad that the C-iaion defer oversight of danammisman=g actions at two sites that are already being addressed under EPA's Superfund program un&r the CM- ive Envu ---- - I P=aaa . C-:- ;===% and Liability Act. The two sites were the DuPont Corporation site in Newport, Delaware, winch was not listed in the SDMP, and the West Lake Landfill near Bndseton, Missoun, wluch was listed in the SDMP. The staff based its rarn==nendatv= on recosmtaan of the followmg factors

• NRC regulation of the ranediation of ra&oactive contamination at the two sites would overisp with and duplicate the EPA's actions under Superfund.

15 NUREG 1444, Supplanent 1 3o

The EPA's w*w== would be sufrrww to protect the public and the cumrnammt frain resologica hazank panent.

The Conanismos approved the staffs raar===wishan in an SRM dated April 28,1995. The NRC has sinc aanhd ties EPA that it plans no further accan on eitimar site, and will runove the West Lake Imifill fruem the SDMP list. This decasion sets a precedent for other deferrals to EPA regulataan ofrane&al actm well as other sondar accons by States and DOE, where and accons are expected to pnmde =ffic=ne protection to the pubbe and the esmronsnent.

Several other sites listed in the SDMP or addressed in other * - -

propectsiney be can& dates for e

! sud deferrals. For example, the Passes site in Pulaska, Punesylvania, is being renseated by EPA under Sgerfbed. In such cases, the NRC staff will assess the adequacy ofexisting or prop.aod Mahan of these sites, and will detenmne whether deferral is appropnate. In ad&taan, the NILC *aff will coonhnste proposed deferral waaan with the other agency (ies) that regulate the HW at hvill inform the r--.maa before fannally uunaang any deferral.

l i

NUREG-1444, Supplanent 1 16 3)

I F

.i i

f 3. SDMP SITE STATUS OVERVIEW

! Simoe May 1993, the staff has removed the folkmns sites from the SDMP list, and adamtsed the indsated

papers to inform the N-n-j

• AMAX, Inc. (Washmgice Bottom, West Virgmua) ,

Messerandum from James M. Taykir,"Ranovel of the AMAX Site from the Site Nv==menianmg j j M- . ^ Plan," dated April 25,1994.

e Chevron Corporatnam (Pawhag, New York)

SECY-94-162,"Pawhng Site Release and Removal from the Site P+- - - - - ; Managanent j Plan."

i e Old Vic,Inc. (Cleveland, Ohio) j SECY-93 062,"Okt Vic, Inc., Laccese Tcr===rian and Ranovel from the Site Nan =mesmamg y _ _ . pg,,,.

)

! Ili additian dannmanimenaning has beni emmenitially ocunpimed a tim followmg sites:

i t

e UNC Recovery Systems (Wood River Junctica, Rhode Island) l e Unded Technologies /Pratt & Wheney (Maddletown, Ce - -- = >) I i e Rahnnele & Wilcox (Apollo, Pennsylvania) 4 e Ah==== Company of Amenca (ALCOA) (Cleveland, Ohio) l I => tad sus'vdyror other admmastrative activities need to be completed before these sites can be lanov'edi i froni tbc SDMP list. For -9 at the UNC site, issues related to narate aane====rian of the groundwater

! have delayed ranoval of the site from die list. These issues have been resolved through a cousset agreement

. between the State of Rhode Island and UNC. Sinularly, at the B&W Apollo site, a 1-year pened of l groundwater monitanng was required aAer dart ==mineianmg activities were completed. This 1-year penod I cads in November 1995. All four of theos sites should be renoved from the SDMP list in 1995.

I Seven additianal sites have approved -h-  ; plans, and =nadiarian is ongoms at these sites.

) Portxas of two other sites have been daean==mananad and released for unresencted use. These sites, Cabot

, (Readas, Pennsylvania) and Northeast Ohio Regional Seww Disanct (Cleveland, Ohio), will remma on the SDMP list until the astire site is darn ==neenanad Figure 2 presents a map depicting the tacarian of each of the 51 sites listed in the SDMP. For each of these sites, AWw A updates the daran====mamg progress since May 1993 (the end of the penod covwed by NUREG-1444). Nailad background informatian is not repeated for sites that were listed in NUREG-1444.

2 However, for sites that have been added to the SDMP since May 1993, Appendix A presents decaded i descnptions inicimhng site operations, radioactive wastes, radiological hazards, financial assurance and

rearaneihla orgah status of h -- ---....g activities, NRC/liarnaae actions and schedule, and i probWissues i

l i

l a

l i

17 NUREG-1444, Supplemem i f . .

3 SDMP Sites TT.- % .

Q"'T'q. . : .+

4)g(,

_:. df ;? ~~ , <,

{:n _. ;r-

_4  ;..

g .- ,,

~

n., m,. g- e

'n =*

w

• a .y

{" =^bl .y%,- MI:y7 # 2,

(qq

, y}

M11 -

.= ~. C.-- 9. d..

\,\

ates l

l l

. . x , , .. . ..

Figure 2: I ~=*= of SDMP Sites i Of the $ 1 sites curnetly listed in the SDMP, Immaari opersoons are ongoing at 5 sites, and tN I==maar do not erase ceasms opershons in the near future. In peeral, the obpective at these 5 sites is not to dam == nan == the entire site in the near future lastead, the objective is to prepare for f- ---- -----5. or to evaluate vanous W6 probkuns that would Ekely lead to a complex <=- '

acnon, M over a protracted period af time, if operabans were to cease. Prognes at these 5 sites is evaluated on a cano-by case basis. See Appendu A for descnpoons of actmties at these sites since May 1,1993.

The 46 ranammt sites listed in the SDMP require Aammmissamt of the entire site, or an inactrve enatammatari paroon of the site. i ==aari opershoes have ceased at these 46 sites or inactive areas. The status of each of these sites can be r===anaNy gauged by trackmg the folkmma 8 ?= ---- =-- ; activities, or malesarman (1) Site characterushan, ii.d4 prepanns the characteruanon plan, perfonung the characteruanon, and prepanag the characteriratina report (2) NRC review and approval of the site charackzuahon plan and report (3) Develap=*=t and submittal of the hie =Wiag plan ,

(4) NRC reyww and approval of the ?=- =:==Wiag plan  ;

(5) Perfonnance of the < == =i==' =--; acuans described in the plan NUREG-1444,9_f 1 18 33

l F

l (6) Performance of the termmatum survey, and p and =nh=itt al of the termmatum m report (7) NRC j,ei'. 4 and da- a**6 of the confirmatory survey (8) NRC tenmahcm of the Ivam Subnuttal and review of site characteruaban plans and reports are inchdod as milemense in the progress smnmanes, as is nnaart of the confirmatory surveys. However, as Aar==ed in the management plan (Secuan 2 of this update), the resouras enemitted to these areas will be deatased. The revew of characterirahan data will =*iaaa but, in most cases, will be canar**d along with the /--- -- :==iania:

plan revww Separate revwws ofcharacteriranv= plans and reports, before submittal of the '= -- :==ianing plan, will be reduced. For confirmatory surveys, some level of effort will be requred at each site listed in the summary figures and tables; however, the extcat of the confirmatory survey will be reduced, in some cases sigmficantly Figure 3 ===nanzes the overall /-+ ===*ia: progns: at the SDMP sites as of May 1,1995, by displaymg the total number of sites that have completed a given >= - - J:mioning =itadaaa Figure 3 includes mita*=an that apply to the entire site, as well as those that apply when portaons of the site have been characterned, ran~4idai or surveyed, which in many casee ,a sigmficant progress However, the " Release Site" category includes only the five sites that have completed the /--- .iuioning of the entire site, and have been removed from the SDMP.

Charactertration 35 DP Submittal

• 20 DP Approval

• Final Survey Report Confirmatory Survey g

Release Site 5

C 5 10 15 20 25 30 35 40 s of snes l *DP = Decommiseloning Plan 1

Figure 3: D+- - "ioning Activities Completed Before May 1995 l

l It is apparent from Figure 3 that a substantial portion of the Aarnrnmieeioning effort to date has been applied

' to site characteruabon. Of the 51 sites,35 have completed all or part of the site characternabon. In many cases this included staff review and approval of characternation plans. Following characteruanon,19 sites have submitted d = - =ioning plans for all or part of the site, and 14 plans have been approved by NRC.

19 NUREG-1444, Supplement I h

- _ . -_ . - . - - . _ - - - .. - - - ._ - - . - . . .. .=- ._ - - -- . _ . - . _ - .- _ _ - _ .

Apprwal of the '-- - =1 plan is the most significant =a*=* , since it initiates the rahacnon or q LT.. stabihannon o(~=e=ainat== at a site and the correspondag reduchon in risk to pubhc health and safety. In addinon, the remew and approval of the daraavanasianing plan psawally poses the possest tM and W ' " n -

AAar appewal of the -'--  ; plan, the activities become more rouane, akhough problems can be

-=amed that can cause delays or require reymons to the approved dara=====anmg plan. This is

plans,but only 5 sites apparent Ace Figme 3, winch shows that 14 sites have approved '--

have completed - --  ; and been removed from the SDMP list. Tbc approved schedule for i

1 dara=====aamt may be protracted as a result afleytunate techmcel or cost comederanons l

Wlule Figure 3 summeruns dana ==aama==g proyees since the begamag of tbe SDMP progrun in 1990, Table 1 prwides a 6 ; L breakdown of the daaa=====aams activines conspleted since May 1993, the end of the penod covuod by NUREG 1444. Table 1 shows the effort expeded over the last 2 years in planung and parfarnung site charadensations for all or part of 13 sites. AAer ocampiseng the characumanons ova the last 2 years,2 sites =d= ament, and reasived NRC approval of, hing

plans for the entire site. These sites, Anne Arundel CountyCurtis Bay and Alf0A, have nearly completed

'~ '

and should be runoved from the SDMP list in 1996. Eight add *-I darn ==ainwming i plans wue =d==ntarover the last 2 years, and four were approved.

l i

l t : nut i....... . ,,,7,_, , ,

I i

k NUREG-1444, Supplement 1 20 35

F Table 1 - E-s - ' ' ; Acthities C9a Betwece May 1,1993 and May 1,1995 W Ashby Schadehd see SITE CHAIUCTDUZATION PLAN m y.- ,-

Cabot Corpr=maa (Readas,PA)

Femme Invasenset Company Hardsy and Hanisyland611(SCA)

Wlumalist Corporeman Sanwy ugle Capommon Sequoph Fusis Corporemon Approval AAR '

-, lac.

Babcock and Wiioca (Parks Townslup, PA) u.g -.,a knen Molycorp,Inc.(Waalungeon,PA)

Subenmal and Approval Clevise Corporanon FW Corporanon Lake City Amunua han Plant (U.S. Army)

Molycarp,Inc. (York,PA)

Nenheem Ohio Rayonal Sewer Dunos5cmherly Plant Wa= mage === secenc Corporaban (Waltz MiB Site)

SITE CHARACTDUZATION REPORT Subraniaal hhar=+ and W~iloca (Parks Townsimp, PA)

Cabot Corporamon (Revere,PA)

Engsihard Corporaean Laks City Ammumtion Plant n-

._ m g Moly orp,Inc.(Washaston,PA) l Nodhenst Ohio Rayonal Sewer DunctSomherty Plant Nucisar Meania Inc.

Pennepan Products,Inc.

RMITianamenca=y=y Texas lastunnants,Inc.

Wasanghouse Elecine Corporanon (Waltz Mill Sies)

DECOputenreG40 PLAN AppmvaldPertial Plan Engelhard Corporanon Northeast Ohio Rayonal Sewer Dance / Southerly Plant Subnued dPaniniPlan Dow Chenmaal Company 21 NUREG-1444, Supplernent 1 D

d I

l 1

l Table 1 - P+ - ** - '-

4

Activities Completed Between May 1,1993 and my 1.199 i 4

AceMay ww Star l '

i NCr*? ""*'HINO PIAN (cost) t, tw andAppnweldPetial i

i Plan Cabot Corporeton(Randme,PA) a

.i l SubemanidFad Plan Huhyand HueyImede i Karr4dsGee Cushing i Kerr4dsOss Cananen l

Corporamos(Harvard Ave.)

j Corporamon (Bert Aw.)

RAG Tamama Company i

i Subemmeland Approval dFmal 1 j Plan Aane Arunded CountyCurtis Bay Ah= r r==y dAmerion 4

l i

)

} AppnweldFmalPlan Chevron Corporamon FAmn Meads, lac.

1 Watertown Ananandall Wassroown OSA l

i \

)

i TNNATX)N SURVEYREPORT l

- i 4

SubnunaldReport for Partial 6 Cabot,Inc. (Randmg, PA)

Northeast Ohio Regional Sewer DuanctSoutherty Plant

BP Chaumonis Amenos,Inc.

! Jesanon Pnmes Ground

' th!WFeel Report AlummussemaranydAmance 4 hhaark & Wilaos (Apollo,PA)

Chevron Corporamon Ekan Meania,Inc.

i old vs,Inc.

a i

4 4

I 4

NUREG-1444, Supplement 1 22 37

f

~

r Table 1 - P+- -- '- '- '; Activities Cosapleted Between my 1.1993 and my 1,1995 (Contissed)

W Assidy Schedehd am NRC CONFIRMATORY SURVEY confirmosory f.arvey o(Paniel Nonheast Ohio Raamaal Semw DutnctSoudwrty Plant Site #- Company c(Amance BP Chamuuals Amanca,Inc.

Cabot Corponean(Randes.PA)

Fmal Confirmatory Surwy Ral-4 & WilcoK(ApoGo)

Cheme Corporanon Old vs,Inc.

RELEASE FOR UNRESTRICTED USE Release Paniel Site Alununum Company c(Amanca BPChammals Amence,Inc.

Nonhenst Ohio Repoest Sewer Dutnct/Southerty Dutnct Cabot Corporamon(Randes,PA)

p .re ,4 tv *,., :, i .,3 pmand TN M & % . , , _,,

Release Entre Sies Old vs.Inc.

Chemn Corporanon

[ REMOVE SITE FROM SDMP UST Old ve,Inc.

Chevmn Corporaban AM,0C 23 NUREG 1444, Supplement 1 38

Figure 4 shows the ==nhar of arr=====mnmg activities abe&ded for compiece by May 1,19 Includag those completed by May 1995, a total of 41t sites are achaA>W o m=phee the c part or all of the site by May 1997. In addition,25 /=

" ; plans should be approved, with a total of May by 14 1995).

sites completag all of the acuans required for removal frtun the SDMP list (includ 1

Characterization DP Submittal

• p.

DP Approval *-

25' Final Survey Report g i Confirmatory Survey g

Release Entire Site 34 0 10 20 30 40 50

. . # of sites NBefore 5/1/95 @5/1/95-5/1/97

• DP = Decommissioning Plan Figure 4: N 1---- hia: Activities to be Completed by May 1997 Table 2 prcmdes the site-specifac h i hia: =ih rqpected p for complebon between May 1995 and May 1997. Notably, the ==nhar ofprotected characterirat=== bas decreased compared to prmou years.

6 are -haa S,*'h,12 charammanon reports where submitted between May 1993 and May 1995, but W for =>hemetal from May 1995 to May 1997. However,11 <lamminie===ing plans are whaAiw for approval ovw the next 2 years, compared with 9 approved over the last 2 years. In mahten t

plans to be approved over the next 2 years are generap y more complex than those previously appromi. Together with the imusuve A=aw in Le*== 2.2.3 asmed at reduang NRC staff resources devoted to the rmew of characterivatv- plans and nports before me= metal of the i- - =

plans, the decrease in whaa W site characterirmemna is a poetrve wwhememri that staff renowess over the next 23 cars should be adequate to compicte the -haaiW < --- 2==U ' ; plan reviews - -

FinaDy, Table 2 indacates that 9 additional sites me whaaiW for ranovel from the SDMP by May 199 NUREG-1444, Supplement 1 24 37 .

l Table 2. rs. _ _._... :1 w.:a: Activities W'M for %W % & pg May 1,1995 to May 1,1997 W Activky Scheduisd She SITE CHARACTERIZATION REPORT Submment Abaninen Primag Ground (Risk Asunament)

Clevine Corporalen SasayLight Corporanon Sequoyah Funie Corporaten Sbsoldalky "" "- W Corporanon (Cambridge, Ohio)

DECOh0dISSIONING P1AN

.i Shead of Paniel N Ida City Army Ammunition Mant(US. Army)

Sequoyah Fucis Corporenne Whmaker Corporanon i

Approval ofPartial N 14e City Army Ammunison Plant (US. Army)

Whittaker Corporanon

~

Subemal of Final N Clevies Corporanon Hartley and Hartley LandGH(MDNR)

Hartley and Hartley Land 6D (SCA)

Mohcorp.Inc. (Washmssm,PA)

Mohcorp,Inc.(York,PA)

Nuclear Mesala,Inc.

Shaeldauoy(Cambridge,OH)

Submittal and Approval o(Fmal Dow Chenucal Company N Northeast Ohio Regional Sewr Dannet/Soudurfy Plant Permagram Products,Inc.

We,anshouse Electne Corporanon, Wakz MiB Approval ofFmal N BP Chamaceis Amenca,Inc.

Chemetron (Bert Ave.)

Chemecon (Harvard Ave.)

RMI Titanium Company Kerr-McGee Cimarron 25 NUREG 1444, Supplement 1 9D

W AdotyS M Em I l

l 1ERMINAT10N SURVEY REPORT

, l l

1 i

SubaumaldRaport for Ponial Sies

, th dFuel Report Anas Arundel CountyCwtis Bay

' Tsums W lac.

Wassnome AnemeFWaB Wsennown OSA NRC CONFIRMATORY SURVEY C=' -

- y Surwy dPaniel Jefferson Pnmng Ground Sins Final Confinnatory Survey Alununusacm dAmance Anas Arunds:CeumsyCunis B y Elkaan Meania,Inc.

RTI,Inc.

Lsas huem%Inc. 3' Wassnown Arm anL1dat Wassnown OSA West IJkslandL1 Uniend TW Pratt & Whaney RELEASE FOR UNRESTRICIED USE Reisses Paniel Sies RTI,Inc.

Reisens Entire Sies Alununwncarag=ny dAmenos Anas Arundai CountyCurtis Bay ,

Lhaar+ and Wiicon(Apollo,PA)  !

Texas lasm=naman, lac.

UNC Rasowy Symenu Unised T ' ' J Pres & Wlueney l

1 NUREG-1444, Supplement 1 26 4/ .

a

(

i

)  ; AceMey h

' seen 1

k REMOVE SrIE FROM SDMPIET Ah CampseyofAmanns 4

j Aans Ansadsl CommeyCutis Bay Bahacek and Wiloca(Apato,PA) i Mapsmus Elskemn l kTLine.

TenneInsmaneses,Inc.

j UNC Rasomy Sysemos i

Uniend T-h=aang . p,,a a wgun,y West Laks Landdis i

+

Since May 1993, the followmg six sites were added to the SDMP:

i i

(1) AAR Manorm Inc. (Brooks and Perians Corporation)

Livonia, Michigan (2) Clevise Corporation (Neigd~fd Progress, Inc.)

Cleveland, Ohio (3) Fm lov=*===t Company (Brooks and Perians Corporation)

Detroit, Michigan (4) Horuces, Inc. (T mmarite)

Cleveland, Ohio A J

(5) Jefferson Provag Ground Madison,Inanna (6) Kaiser Alummum Specialty Products Tulsa, Oklaha==

With the ar= ream of Jefferson Proving Ground, these sites were identM through the ongoeng rmew of ternunated matenals 1- The sites were added to the SDMP aAer NRC inspect. ors ==A-*ai a scopag survey at the sites and ideervd mnemmmarian ~~~94 the NRC's camat cnterm for unresencted use.

Section 4.1.4 presents = Mea ==1 infonnation on the review of tenmasted 1-n=== Appendix A provides detaded desenptions of the six new SDMP sites listed above. i I

27 NUREG 1444, Suppl ===t 1 n

g.-- --- . - -

1 l

l

\

l l

s 1

i l

t i

1 1

i 1

i 1

1 l

1 1

4

l 1

} 4. DECOMMISSIONING POLICY ISSUES l 1

i As the NRC foonsed on r===harian of the SDMP sites, several usues anerged u impediments to their

}

l tunely cleanup. A pnmary objective of the SDMP is to identify those issues and ensure that the NRC staff  ;

j resources ne devoted to their resolutna in order for '- -

of the SDMP sites to proceed in a tunely manner. '

Several pahey issues have suunc ==plearia== for the NRC's overall '- - - - ';progren,orinvolve odur matters that must ultanstely be doculed by the cam===ian Pa=ahn- of the pohey issues diaca-d i boks will provide a regulatory framework for more of5cient and consistet heensag actions for futwo site

,,g , _ _

J 4.1 Onen '- - - '

)

j 1his section discusses the followag open issues with paene unplentiana for the NRC's overall

"; program I

l e ankaaaad participatory rulemslang on radiological critens for

~_ _; _ _.

l e nd===hng on timelma== in '- - - ";ofmatenals facilities e rulemakmg on daran=menianing recereaaaint and liename termmarian

• reyww of hmnand sites ter-matad aAer 1965

e guidance on the conduct of ter==mtian surveys

]

e previous waste disposal seder 10 CFR 20.302 and 20.2002 i e revww of non-power reactor license termmat=s i e d;;v@ of procedures to ensure that future beense ter==mtiana meet NRC requsements

! e reyww and madirratian of hccese ter-marian procedures e consideration of a "r=apa=r" nilanabag

NUREG-1444 annea-d compechensive background informatian on each of these open issues. Instead of j repeatag the 'eea,ommi information, this supplenuet diac===a= the progress made since May 1993, which was the end of the penod covered by NUREG-1444. I 4.1.1 Fnhanand Participatory Rulemalang on Radiotopcal Criteria for C+- =';

This section discusses the followmg issues concernmg enhannad pamcipatory ndanahng on radiological l l critais for d-a-mi.*iaaint i

e ndan hng

e devalapes=w of tehnent bases for '- -- -- I

iaaing lands and Struct1Nes

• regulatory guide l 4.1.1.1 Rulemalang i

i Since May 1993, the NRC caahad an enhanced participatory ndanabng to estabhsh radiolopcal criteria j for danamminamnmg The proposed rule was published in the FederalRegister (59 FR 43200) on August i 22,1994, as proposed amandmente to 10 CFR Part 20.

enmmants received on the proposed rule raised a variety of macerns, including the reaannahlemaar of i selecting 15 mdhran per year as the dose limit for i wM use, and whether costs nn--tad with

! ranadiarian of anntaminazad soil and groundwater had been appropnately ei- *=d in order to address the

! substantial an==nente roccived on the proposed rule, the NRC staff will not submit the rulemalang package l 29 NUREG 1444, Supplanema 1

1 for e n==== nmow until narwanhar 1995. In the meanwinie, the staffplans 2 canthre a pubhc wor in the Washnesten DC area in breamher 1995, nis m.W will prcmde an opportumty to &acuss J

practical amplementanon usues resed by the -na-en, deeribe cumet staffevakiahans based on nel-world data, and supiore abernatrve approaches that could be used to i=pl==== the final cntena.

he NRC staffis also soonhnstag with the EPA in that agency's development ofresidual radme j standants. De EPA arculated a preproposal draA ofits standards in May 1994. Many of the same issu remad in the pubbe comments on the NRC's proposed rule were also raised abow the EPA's dreA

De objectrve of the agency &acussons is to allow the EPA to find that the NRC's regarements j sufficassa pecescnon of the pubhc and the omronment. Based on such a findag, the EPA would exclu NRC and Agreement State 1- frcen the scope o(its standards i

i Until the NRC promulgstes ra&ological cntana for >=- '

=-5 ni10 CFR Pat 20, the staffwill

<=r=ma to use the miens id,= HAM in the Action Plan to Compel Cleanup ofSite ?-e '" = ';

Management Plan Sites, winch was r=hhahd in the FederalRegister (57 FR 13389) on April 16,199 j

ne NRC acticas needed to complete rulemalang and the ==*=neM dates for compienon are as follows 1

• rnn,hre workshop to &scuss imple===eme=

i assues resed by the pubhc a<==-en l Dead: RES; support: DWM,OGC)

(

Septanber 1995

• Subaut final rule to the ra=====an Ocad RES; support:DWM,OGC) 2 nara h.,1995 4

4.1.1.2 Devatap==* of Terhaal Bases for Dooomnusmomag Lands and Structures ne NRC Office e of Nuclear Regulatory Research (RES) is developing NUREG/CR 5512, "Remdual pma-reive nneammahan frasnrwc_z i =g" to pnmde the eachmeal bases for use in propanng regulatacas ennemment radiological cntens for ?=- *

!  ; NUREG/CR-5512 is a:-*M to be

pubbshed, for intrun use and namn=e, in three volumes and one supple ==ne Volume 1, aanemma maahanaheal for==lahans with parameter values and refeneces, was pubhshed in October 1992.

j contaming the =nemer code and related user maanal and example applicar==,is 2-T= +1 to be publisb j in March 1996. The pihhear= date for Volume 3, <=#aimag sensitivity analyses and compensens, h j yet been detenmned. A NUREG will be developed to prcmde a haerarchy ofincreasanth saphishcaeM t ground water models in enanarev= with the NUREG/CR 5512 rc =L '*ty.

5' i 3

he NRC acuans needed to develop technical bases for da===i= Wing land and structun:s, and the l j eshma,M dates for compiceca, are as follows:

i e Complete NUREGCR-5512, Volume 2 Ocad RES; support:DWM,NRR) 4 March 1 96

• Complete NUREGCR 5512, Volume 3 i Ocad: RES; Support DWM,NRR) 4 TBD j

• Complete Supplement I to NUREG/CR 5512 1 TBD Ocad: RES; Support: DWM) 3 a

NUREG-1444, Supplemait 1 30 l .

4.1.1.3 RagnimaryGuuie

& NRC madrwill papere a neulsory guide ~w=mg resological crama for ' --

In ademon, this asulmory guide willPmv4 detaded guulance on an acceptable appmach for d-aamsung

. f -- with the dara-~===aamt entens in the final rule and haemse m The NRC accons needed to develop the regulatory guide and a=e==aad deans for P are as follows e issus draa Reguisory Gade for canunset (lead: RES; support: NRR,DWM,OGC) nar,naw 1995 e lasus final Regulatory Gumle (lead: RES; support: NRR, DWM, IMNS, OGC) narnaiw 1997 4.1.2 F='-- '4=;- on Timai-man in C- ---- -- '; c(Matenals Facdnaes The final rule on "Ti==Imasa in C+---- ' --- ; of Matenals Facdmes"was pubbshed in the Fedemt

)

Register (59 FR 36026) on July 15,1994, with an effective date of August 15,1994. The rule establinhad l specific time penods for d+- - -- -; unnaad portaans of operatag nuclear matenals famheias and for J- -- "; the entire site upon ter-naem of operations. The rule is ineended to reduce the g=enarial risk to the envuonment or public health and safety fmm radmartive masmal resnessag for long penods of time at such famht- aAer bcensed operabans have ceased.

The finai t=al-aan rule was annan=rai and summarued in the E+; ---/ October 1994 NMSS Newsletter (NUREG/BR 0117, No. 94-3). In addman, NMSS is developag'gndance for its staff to use in unplementag the *==l== rule. When the g=dmare is A 1M its availability will be mananarad, possibly in a futun: NMSS Newsletter or an Infonnauon Notice.

This issue is closed, and no further actaan is reqmrod. I 4.1.3 F r'-- ' :---; on P = ' " ^; Recordkeeping, and lacense Termmarian The final rule on "E---- '- " ; Recordeeping, and Liamase Ter===rian naa=nanentian Additions" 4 was pubhshed in the Federal Register (58 FR 39628) on July 26,1993, with an efEnctive date of October 25, 1993. The rule applies to holders of a specific heemme for pa=== man of certam byprosact matenals, source matenals, special nuclear manmals, or for iad--adaa* storage of spent nuclear fuel and high-level waste.

The rule reqmres such liensees to prepare and ma= tam additional dan =-atme=n idenrifying the following areas:

e all resencted areas where he,n=d matenals and equipment were stored or used e all areas outside of restncted areas where documentation is reqmrod under cummt d a~==iaioning regulaticas for unusual occurrences or spills e all areas outside of resencted areas where waste has been buned e all areas outside of restncted areas coritammg matenal such that if the hcense were ternunated. the hcensee would be required to da~=*=ia ra the area or seek specul approval for disposal b final rule also reqmres 16- to submit specific informauon at the time of final da"==inioning-Such informatm must identify da~=tamia *ad equipment that had been involved in the licensed acuuts that will remain onsite at the time of heense terrnmarion. The informanon required by this rule will provide 31 NUREG 1444 %=plement I

i s  !

poseer assurance the E- =- % and dara==ianian ng of hcensee facilities have been carned ma in  :

accordanos with the e,====ia='s regulanons '

i This isses is closed, and no fwthar acune is regered.

I

< 4.1.4 Rev;wr of Licensed Sites Twannated AAer I N5 l

la 1990, the NRC inessed a review of ternunsted matenals hoenses folkmag aa===*=aata made to l Conyesa by Channan Carr. The nrot stase of the revww has been parfanned for the NRC by ORNL, under a teriuscal asustance eerstment. ORNL developed an expert system compiser program to process )

mformanon tem dockst 51ss and make a relauve evalumnon of the likahhood and magstude of site

=====e== This evalustaan is an estamate based on the infonnsoon in the 51ss, wluch is oesa 1 imaamplaam ORNL compissed E' . ^ and tennes of the computer cods in 1991, and began to amir afonnamon froru the Ales for evah=han 4

The first phase of tie propect evolved the evaluanon c(apprn==analy 17,000 heenses ruered between 1%$

and 1985. The gyahnahan ygelded a list c(322 laosases with inadequate dar=====*=ha= to prochade the potential for remdual an=*====han

} Begemag in 1992, NRC Reponal Of5ces further mvestigated the hoenses to detenene wbsther there was i

adeed residual an=sa===han at the sites. The reponal investiganons meluded reviews of the files; contacts l with forener bosasse pareannel, current site owners, and State authonnes; and, if warranted, site visits. The i reposal eveenganons idaahf=d a numbs of aa=8v===*ad sites.

j laosases retned before 1965 had prmously been reviewed between 1977 and 1981, and were thaefore not

} moluded in the initial scope afwesk. However, the success of the evalumnon of tw==as tersunsted between 1965 and 1985 eaused the staff to reevalente its decision not to include hemises ternunated earher.

The arrent revww revealed na*=n=ahan at a number of sites that had been cleared in the eerber review, and

! penmund a greater answance o(accuracy in the rev w. Entenas the previously ter==atal heenses into the 4

an==a= database also yields a more complete datahame, facihtstag compenson of sites on a unifonn basis.

The contractor has completed the resiew of the pro l%5 tes===ha=, and has idannfiel 300 marinianal hasases wahaut adequate domensatanon to preclude the palannel for site anae====han bnngmg the total to 622. The reponal urvestiganons of these 622 hoenses resulted in the discovay o(26 ar=#===,eal sites,6 of whudi have been placed on the SDMP list. The Rapons have cleared 24I haa==ar, leevmg M5 to be ruolval.

4.1.5 Guidance on thee,= whet of Tammahan Surveys in early 1994, the staff reviewed aa====*= received conommag Draft NUREG/CR 5849," Manual for Condmetas Raholopcal Swveys in Support ofIaoense Ter===han " and consaksed f=almap the NUREG.

However, at that time, the RES had propects underway to develop eariharmi support donsnents that could be used to d==a==ste ar==ph==aa with the proposed rule on Radiolopeal Criteria for P+----- -

In addman, in cooperanon with the NRC, DOE, and DOD, the EPA inmated an effort to develop a muhi-agency manual to provide gedance on inveenganng ruboiopcally nam ====aat sites.

The staff decided to postpone finalmag NUREG/CR-5849, pendmg the conclumon of ruh-nainne ori ruholopcal critens and completion of th .nulti-agency awmal. The staff envisions that the multi-agency

====1 will incorporate the gennane aspects of the final *-4=eal support dar==n=*e, as well as providag NUREG-1444, Sigipisment 1 32

i f~

1 addmanal duecnon that can be used to apersede DraA NUREG/CR 5849 as the NRC gedance on conducang termunshan surveys 1 Suppornas n=4=iaal dar====*= will be issued by the staffin August 1995, and di===ad at the workshop on

raboiopcal criesna in bg*=nh 1995. The draR nedti-agency

nanual should be issued for pubhc n==naar

. in November 1995.

4 The NRC achons needed to develop the gudence on the conduct of ter==== surveys, and an=amad dates

for ocampleter., are as follows e lasue draA andti-agency ra&ologaral

site invesuganon manual

! (lead: RES; support: DWM, IMNS, OGC, FCSS, Rapons) Novanber 1995

4.1.6 Previous Disposals of Wastes Under 10 CFR 20.302 and 20.2002 i The staff crismally pt==ad to issue an Infonnahan Nance on recortkaapas and >--- " '- ; for

Ampa= ale under 10 CFR 20.302 and 20.2002. However, the sfaff deter ==adthat the Final Rule on

] "Timehness in naran nm innmf of Matenals Facilities"(59 FR 36026, effective August 15,1994) applied j to previous bunals if the former dispa==1 site met the defimhnn of an inactive andaar area.

1

The NRC Office of the General Counsel (OGC) confirmed the staff's posioon that inactive 10 CFR 20.302, 20.304, sad 20.2002 disposal sites at facahues heaiend under 10 CFR 30,40,70, and 72 are subject to the requennants of the Timalma=, rule. Because thisjoterpretanon was considered a new NRC staff posanon,

! the daci==== will be changed hose an InformahoiENotice to a Gemene Latter. The staffis curready makmg the required changes to the daci-w== and plans to issue the Genenc Latter in Lgwand=r 1995, i

in addman, the original staff plans called for a Tanparary lastruchon to the NRC Reponal Offices to

identify sites with onsite disposal areas. However, such an instrucuan is no longer necessary. Because the Timalma== Rule now requuss that haan=aan provide a 2+v-- " "; plan for the disposals, or propose an

alternative " -Mag achadiile, withm a specified thne frame, the NRC will be able to idatify the fonner onsite d=pa==le 'Ibe need to idsinfy former bunals will be incorporated into the daran maananmg j mapenhan procedwes die ==ad in behan 4.1.8.

The NRC actions needed to develop g= dance for recordkeeping and t ;-- == ----g for waste disposal I

areas, and cari==nad dates for compleuan, are as follows

e issue final gemenc letter l (lead DWM; support: IMNS, FCSS, Regions, OGC) September 1995 i

! 4.1.7 Revww of Non-Power Reactor bene Termmauons j Based on a revww of 59 docket files of tenmnated licenses for test and research reactors by the ORISE, the NRC staff reached the followmg conclusions i

.

• Of the 59 sites,13 satisfy the prisent guidelines for unresencted use.

4

• Of the 59 sites,16 sites may have e- W residual ra&oactive canta-mannn These sites are i currently hrennad for other activities, and will be d-- = =='aaad as part of the termmauon process of the subsummg liceners j

4 4

33 NUREG-1444, Supplement 1 i 97

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - . - _ - . _ . - . - - - . - . _ . - . _ - _ _ _ - _ _ _ - ~ - -

For the renaming 30 sites insufk=nr infonnataan exists in the docke curent status of these sites would meet the cntens for assetncted release.

In consumaties with the NRR Non-Power Reactors - - '

and 4-LLDP developed a strategy to address the renamung 30 sites. N sV Sahags Of the 30 siens,12 had a very km probabihty ofcontamang i remdual!

sneens for imresencsed use. He staff based its desrammation on the typ AGN or L 77) ^ Ay-d at these sites, a well as favorabic con 6nnstory ==

time of ficense tenninanon. &t staff ==W hat the hasanes for these tenannted.

Eight sites me currently under another hosame. Dese siens wiu be '

Ia part of the samunanon were process acceptably tarininated of the =d==ning hoemass. The staff condudes that the

• I Forone site,the State ofCahfanna n ;h ofHesith Sernnes ovesaw the '=-

hoense for this site was manape=hly termmated. process. Based o

• nroe sites re these surveys,qmrod that the NRC perfonn immted confinastory surveys Based o the starr~~h i that the hoense for these sites were acceptably tennmate For two sites, enfh==r afonnahan was avadable for the staff to demnnme these sites were acceptably ta====sai

• . q,, .. cow (--P. anc For three sites, the staffconcluded that additiceal surveys me regered be made concenung the ma=prahalay of the hoense tarin==r-r For one site, the staffis still gathenna and evalustag available infonnata aM*=a-al site surveys are ascessay.

De NRC follows acuans needed to ackkens the ranaamng four sites and the ==e==a Perform folkw up surveys and conect mMiriaaniinfonnanon (lead: DWM; support: ONDD) n--nha,1995 i 4.1.8 Develap==== ofProcednes To Ensure nat Future 1 - Ter==>arnaar Meet A draA1 Manuel Chapter enntled "n= --- - -- -g laspection Program For Fuel Cycle F Matenals "was cuculated for a=====r withm the NRC. The Manual Chapter has since the foHowag purposes *fmahml, and is being issued through the NRR insp Pronde the gueral policj for the inspecuan progran for fuel cycle and matenals im Pronde geanne for plannmg and ==-hwia: inspections of fuel cycle and matenals 1==

undersomg 1 <--- 3-aomng.

NUREG-1444, Supplement 1 34 44p +

41 -

w- -

r-

d 1 -

i

, promoes consstent aspecuan of rariinha undssoms ' - ---- -- ;

) ' - -

! la addman, asperses '=-  ; i parenaa proosdes will be developed for fuel cycle facile === and l

{ mansnais facdass by June 1996.

11e NRC aetaans needed to develop procedme to mure that future hosnee ter=====a== most NRC regarements, and the an=nmad dates for completion are as follows 4 l

. Issue Final Manual Chapter (leed; DWM; support: IMNS, FCSS, NRR, Regions) August 1995 l

. Issue draa inspecuan processes for fuel cycle and matenals facdmes (lead: DWM; support: IMNS, FCSS, l

Regions)

June 1996 4.1.9 Revmw and Madirienhan, if Needed, of tassene Ter==dian Procedses l 1he '-- -  ; rnlanabar aa-platad in June 1988 (53 FR 24018) madiriad the heense ter===han procedures used by I- and the NRC staff. The staff had planned to develop a Regulatory Gude to - i reGect the 1988 '---

rule, and RES had the lead for this project. However, this task was not istaated because of competag pnenties, prunarly the RES effort to develop a rule concenung radiological critesia fa *- - - - ";

As described in Section 2.2.1, the NMSS recently mutiated the develap= ant of a Manual Chapter on that will clanfy the staff procedures for heense ter==ahan This Manual Chapter will include procedwes for the NRC staff to use in assessmg compliance with the Tunal=ame rule (Section 4.3.2),

the Recordkeeping rule (Section 4.3.3), and the 1988 P---- ' "; rule. Although this gedance is miended for use by the NRC staff, it will also be made avadable to I- In addman, a dran Regulescry Guide will be issued -.4 with the final rule on radiological cntens for '----- - ; These darinnante supersede the proposed Regulatory Gmde on the 1988 C--- - ; rule.

This issue is considered closed, and no further action is roquared.

4.1.10 Consideranon of a "Paap==" Rulemakmg To Reqmre Addihanal Dglontarianahnn With the =hmittal of SECY-89-369 on Dana-her 8,1989, the staffinfonned thera===iaman ofits insenuon to develop procochares to naufy I- that tenunated laamaan may be recalled if final NRC or EPA resuhial ar=*===mv= standards indicate the need for further :=nadiarian. In an SRM dated Janumy 31,1990, the en======= igd that the NRC staff expedite the remdual aana==ashan rulemahng As part of that ralanabnf the C;===i==iaa r=" that the NRC staff petmde a general notice to liemimaan that additional ranadiarv= may be necessary to comply with future EPA standards in addition, the ran====== directed the staff not to develop specific proceduns prtmdag such nouce to licaina= As a result, no rulemalang is contemplated to reopen terminated licenses as a resuk of more stnngent EPA standards.

In a related SRM issued on February 28,1992, the Commission stated its position regarding the need to recall ter==atai !===== if future NRC standards are more restnetive than criteria currently used by the NRC. Saarine=Ily, the C(-- =- s stated that if a licensee or responsible atity remediates a site under an NRC-approved dec'.mumssxuung plan that meets the criteria at the time the plan is approved, the NRC will not reopen the case as a result of any changes in NRC cnteria or standards. This position on fmality of daen==iaioning is reflected in the SDMP Action Plan and the proposed rule on radiological criteria for 35 NUREG-1444, Supplement 1 i

i 1

4 I  !

i .

I i

}

} EPA standanis.

In adshtm, the staffis wortang cooperatively with the EPA to ensure = ^ y wiA I i j i 1his innes is closed, and no futher acnon is requinut 4

t 42 7- -'--

h NRC staffis curready evalusang the folkmag pobey assues for wind resolutna could enhanceI i

t NRC's performance and propees in regulahng the '- - '

ofnuclear materials facdmes  !

j e allowns for concentratmo averagag e delayas certam >== * '

-- ;acnons l i

1

}

• i t using more reehsuc expoews sonnanos and assunynons  !

e

! coonhashes reguisory mww and pubbe atonnaten with other agences

) e drawing genanc -h=naan from mee-specific EISs i

j e amahl=h=g convement ==**=a1 control arraara==== for sites that will be released with land '

This secnon desenbos these ismos and the related staff evalushans presently inderway.

4.2.1 Concentranon Averagiks ' ' -

. The NRC staffis assessung the aschacal and pobey =pe=*=== a(alloung vanous types of con averaging assocuesd with nmows ofproposed '- - --

>=- - ' accons Averages could be impl===*wl a i

sites in at least three ddierent ways

(1)

Average measured concentranons afradaoecove masenals in soil over a finite area

" average" conoontration for use in dose or risk ======a=*=

(2) Allow csedit for unavoidable dilution that occurs danag excavation and pla===* of both

=*=====i and i==ma=== tad soils dunas r== h===, or nounts fmm the tr===a=# of the weses.

(3) IW blend aa=*====*a4 ami i==*=====8 soils to reduce the average ma=neranon of  !

rubomouve massanal, as well as posannel andmdual doses associated with exposwe to the d!

Current NRC regerunnents do not spanre=Ily addnas or prohibst everages of soil an===* rations in evaluateig the adequacy of?--

-- ; acnons. Other NRC regar==enee ==plenly allow dilution or averaging of r=l==el=le concentranons. For example, liquid efthent limits in 10 CFR Part 20 conside eNars of ddubon in evalustag the assocessed projected doses. In addataan, the waste ==aaners 10 CFR Pat 61 allow ddubon in =l=1=*aa== that relate concemations to potenhal doses to inadven intruders The EPA has taken a sandar approach in promulganas waste and efDuent limitauons for bot ruboiopcal and w6 =*====a The staff alkms medit for averagmg soil concentrabons wbme the staffdesenness that a resuks in rosadual radmactivity levels abat are as low as .My achsevable (ALARA) and controls er

• NUREG-1444, Sippianset 1 36 50

l piace to p,em high---anons orraama nve m.mia m staram mm.s:ih ihis s is consiment with the Accan Plan to Enswe Timely r'"- -- =hN of SDMP Sites. This approach is .

pnocularly attracerve for long-lived =waminarma (e.g., thorian and uranmm), recognmng the uncertamhea i associated with the leng-term performance ofw,ir 4 barners meendM to contam the waste, and the value of dihamg the soil enan=*ataans to ensure that indivuhaal doses remam suitably low.

Nonetheless, staspractice and pobey have generetty disalkmed credit for averagmg soil ===*abans in l evaunung pne-==i exposwes to imanens from residual radioacave macral -nri-M with Aarnmemesv=mg or waste diapas=l. For example, in the now defunct pohey traa==ent on "Below Regulaanry Conown," the NRC enemittM that it would not allow 1- to inaavumally dilute waste ===*anons solely to meet --aema critwia.

This approach results in increased costs and delays in 4 ----- = =:== Without talang credit for some l

aviragmg, soil =wntrabons at existing SDMP sites exceed established NRC cntena for unrestncted release, especially for wamum and thanum. In these amiahnna, lwneces arg rgquggd either to excaYme and dispose of the enntam==sM matenal at existag oEsite disposal facilities, or to seek an -----?b or exphcit authonzanon from the NRC to dispose of the enatammatM soil onsite, be==a of the relauvely large

volumes of cane =nmaeM soil and dispnaal costs rangmg from $10 to $300/ft8 or more, SDMP site ownes would have to spend millions ofdollars to excavate, transport, and dispose ofennsammated soils offsite.

Requests for --antiaan or autharuauan for onsite disposal are also costly and time consummg The NRC has typically considered such requests through the development of an EIS, and has co -L-.:M their renew with other Federal, State, and local murhnrities. A typical EIS may cost on the order of $1 nulhon in NRC

, fees alone, and may require 2 pars to complete.

l i The LLDP staffis preparms a prehmmary analysis of the pobey and techmeal impficahnns of adoptmg an approach that would allow more credit for averagmg soil ennenntrances The staf erammed a variety of subissues anancia:M with averaging, such as potential mdmdual and populaban doses, cost-effectiveness of the vanous alternatives, risk-risk trade-offs between averagmg and offsite disposal, legal and regulenry prer-lente for averagmg, and long-term uncertamnes of hmnan exposure. The preimunary analysis will also supplernent the earhaie=1 bases for adoptmg more reahsuc exposwe arenarios and assumpoons (see secuan 4.2.3), as well as the rulernaldag on radiologpcal criteria for 4 -- :=hing. Followag meernal management review of the prehmmary analpis, the staff will evaluate a specific site as a case-study of the implicannne of an averaging policy for k - a=ionmg. .

4.2.2 narnmmieninaing Timeliness In July 1994, the NRC completed a rulemahng that established hiia: r% ;i for aneine= tina, initianon, and completion of L -- -- =hing accons at matenals facthties (the Timehness rule). These requirements became effective on August 15,1994.

Immediately before the rep-. w were promulgated, the Barnwell low-level waste (LLW) disposal facility in Barnwell, South Carchna, closed to waste generators outside the Southeast Cn===ct However, although legislative and regulatory actions are in a state of flux, the Barnwell LLW disposal facility began acceptmg LLW from throughout the United States (except North Carolina) on July 1,1995.

The staff will enannue to monitor the status of the Barnwell site, and other LLW disposal sites (Hanford and Envirocare), as well as the effect of disposal site access on e--- ; ":= Wing timaliaa== If site access is agam severely limited, heenece= and other responsible parties may not have a suitable chsposal facihty to send h - - - ='- d=g waste in some cases, L <- -- =ioning may have a mmimal benefit if the wastes generated will have to be stored for an indefinite penod pendmg dispe:al site access In other cases, subarannat delay of &e -.....Minnmg may result in iruW public exposwe, en6 -- m:al ena'==ia=tian, loss of control of radaoactive materials, liabilities for remediation costs, and public burden for A -- =:ening. The staff will 37 NUREG-1444, Supptement 1 5/

i l comeder such famers when reviewmg requests for alternative ' -- -

achadida= umkr the j Timishness rule.

i

4.2.3 Rashes Exposure Aassessiset lineesses

' and other interested parties have com poissed out that the level a(protection =- N 'in the

=

program is a funmon of the antana, as well as the does snodshng med swvey protocols used to impl==== the antana. The NRC spent more than a decado developsag the sessmans method for i convernas surface aa=*====== levels and soil concentrahams into prepeated doses. The authod was l daa===nad in NUREGCR 5512 and cuculated widely in support of abs proposed rd===har on i radiological mesria for '-~ -  ; The NRC staffhas sinos i yn====aad a standard set of exposwe '

scenanos for residual radioactmty in Policy and Gedance Direarve 8 Og, doesd May 1994.

l At the NRC workshop on site charactananon for '  ; and in comuments on the proposed rule,

! manerous commmmears resed conearns about the amenhec nas of the ---rma- used in--===r doses from semenal rahoemmty. 4-*.ny, .a m : muhans d that mou., sends i,o,,,,s l possanal doses by anaking asmanpoons that can ineses doses by an anier of magstude or store.

1 i

Sandar concerns surfmend in compenng NRC and EPA approaches to risk assessment as part of the l inasragnacy propen ce risk harma===enan (See the draA Fhis paper on Risk #ernoonisation, deced

Janusy 1995.) For example, the NRC typically assumes that an indivuhial is +- - f exposed to resuhial radioactmty throughout a 70. year hfetune la contrast, the EPA typically assumes 30 years of j exposwe in assesamis potannal human risks to ansse resukets in the Superfund progran. In addition, the '

NRC rouanely asmsnes that angmeered barners, such as earthen covers, will not be effemive in lanmag or j prevennag human exposure over long penods (e.g., grosser than 500 years). C--- - - ; "y, the MtC staff 1

1 estunates potesnal human doses by assuomag that an casse resident fanner will intrude into the weste and be i exposed to rendaal ruboectivity through a wide variety ofexposure pathways la ocatrast, in the bassalous waste progran imdar the Resource C-- .-- = and Recovery Act (RCRA), the EPA typically assumes that

-=1 controls (e.g., deed restnmans) will runans effaceve in indar=*aly preventang human exposse i to hazards wastes. Fwther, adustry repnmentatives have requested that the maffconsukr the probabshey of i

human intrusion and fadure ofiam**v==3 controis and engmeered bemers in evalumnas potannal exposure j to humans.

i The staff has inmated a review of the potental conservansas that have been included in the NRC's standard expoewe scenanos and does modeling used to impla=== rubological cntena for '= -

- This i

review supports the evahiation c(pubhc nam-ants concenung the proposed ral===hng on radiological j cntens for '- - - -

does modehng at indmdual sites, and risk har=a===== with EPA and other agencies the revww will inchide canaderation of the lilemlihaad and i-*=- of standard exposure

! ===5ma== that compnse the resuket fanner scenano

' Prehmunary results of the revew should be completed by the sad c(June 1995. To promote a commstant and cohanat approach to radiological risk ==a-mad, mamficant aa-h- based on the review will be l coonhassed with other Federal agsscess through the laterassacy Steenng n===*~ on Radianon Standants '

i 4.2.4 Coonhashon with States and Odur Agencies

{

! E- - ~

projects at NRC hoensed sites oAen fall under thejunedicoon of several Federal, State, 1 and local seemes. For example, the pnmenos of hazardous or solid waste onnee could subject the accan to regulatson by the NRC, the EPA, and a Sune envuonmental agacy la some

! cases, '--  ; is already prognaang at the sites under supersee mmr=====1 programs, apart from i the regarements of the Asanne EnerEy Act In other cases, h ;regumenumas are l

}

NuREo.1444, Si,pienent 1 3:

n

l l compla=='"y Coordmauan of the regulatory reyrws prnmnae= adopuan of consistemt soluuons and reduces the regulatory burden.

t in SECY 95-056, the e ,-=- approved deferral to regulatory oversight of two such overlappeg

,__ 4=1 actions =nair*M by the EPA unda the Comprehensrve Enviranma=r=1 Response e nmp-ame-and Liability Act. Saari6*"y, the two propects were r==aame- of the DuPont site in Newport, Delaware, and the West Lake Imnan!I near Bndgeton, Missoun. In both cases, the staffproposed to defer to the existag rummedial programs maanenM by the EPA beoed on the staffs findag that those programs will i adequately protect the public from radioecove wastes at the sites. Other cases, sudi as the Pesses site in 1

Pulaska, Pennsylvania, will also be considero61 for deferral The NRC has begun negotiatmg a en=nrandum of understandmg (MOU) with the Pennsylvania Depart ==#

of Envirn===tal Resources & objective of the MOU is to prnmnae a coaranmeM and enaniment gover===tal response and oversight of proposed remedial actions at the site and other sites in the

C-aaawealth of Pennsylvania. & staffs devW of the MOU is descnbed in SECY 95-108. Based on the enm=i==

's review of the proposed MOU, the staff plans to develop samlar MOUs and agr==aante ^,

, with other State and Federal agencies to foster a coorananM sow.-..=.:al respn==e For example, a ==lar t

agr== ear may be nare===y for wu.t stion of d-- ----maing acuans at sites in Ohio.

These coordmauon activities include efforts to inform and involve the public in thea - . a i. ....g process i The objective of these efforts is to prcmde earty and meamngful opportunities for public involvement in the

d- - A=L =

=: proczss This approach has been promoted genencally in the proposed rulemakmg on j radiologpcal criteria for h- AA-t In addition, the staff has initiated public informauan meetmas at the Parks Township SLDA and the Sequoyah Fuels Corporauon facility. Srskehnader n.r _ =:=tives are routmely invited to participate in tr==Atahle discussions and informauan -veh=aaa on the status and issues associated with the t--y-- J:=iaaing protect Nec initiatives are consistent with the staffs draft public itsponsiveness plan defined in NUREG/BR-199. Other public informat- meetags and involvement efforts

will be implemented on a site-specific basis, wuhm available resources, to address specific needs that exist in

, afrected enmmunities.

i 4.2.5 Genenc Conclusions on Disposal of Uranium and Thorium Waste In the proposed rulernabng on radiological criteria for t e -- . =%ing, the Cn==i== ion id=rinM tens of j sites that will not be able to satisfy the proposed criteria. These sites are similar to near-surface disposal

facahties for radioactive waste. The staff has begun developing site-specific EISs to consider onsite disposal

of uranium and thorium wastes at five much sites

1 1

i (1) Shieldalloy-Cambndge i (2) ShielAmitay-Newfiekt

] (3) Parks Townshap SLDA i (4) Jeffwson Provmg Ground j (5) Sequoyah Fuels j Several additional SDMP sites are c=AAmes for other EISs. These include Molyoorp-W A=.-ena.

Whittaker,3M, Wyman-Gordon, Lake City Army Armennal, and Faneteel However, the staff has not begun developing EISs for these sites because of resource limitauons or the current st,tus ofi- - - ==hia

arrinne at the sites.

l

& EIS: p-i&=Hy evaluate whether onsite disposal of existag r=&nactrve wastes at the sites is feasible j and preferred, with some appropriate land use restncuans to preycat or inhibit human strusion into the l

waste. Ahhough the site and waste charactensucs vary for each site, the alternatives under considerauon are 39 NUREG-1444, Supplement 1 i b

s 4

l 1 l

4 l ==hemmally samlar among the EISs (i.e., onsite disposal, offsite esposal, combianhan of o esposal,and no action). l J

Afhar compishes its reyww and evalumnon of aa===== on the draft EISs for three of the I i plans to sesses in amid 1996 whether say genene -h- can be drawn beesd on the sac-spec and supporang genanc e=i-i na==

I If genmc ~=eh- can be supported, the staff will consider

! developsag a genanc EIS regar&ng ansas waste esposal,in lism of the more coady;and F = -

preparanon of tems of t ;-- T-: EISs. The genenc EIS could support either sea specific hasan i authormas cosas disposal or some other abernahves, or a r=l===Ar=g on esposal of r using annesdeposet ,

! t 4.2.6 lammmanal Contrals l The proposed r=la==lring on resological cntens for '- -

I i - ; allows for resenched tenanence of j NRC laosases in accordance with specified "

entana. In addioon, as discusend in Secnon 4.2.5, =

consels misy be needed for some '=-

; projects that involve the inab=hmat== oflarge voksnes of

low activity, bulk redmacan waste onsite. However, the fans and -k ===== for impt=====g t

==**ia=al ocarois heve not yet been amahhahad

( In tie abemos of general approaches, I- would have to develop and defend specific proposals for applying such iam*manal controls to ensu1 the pubhc med envn=====

l However, under section 151(b) of the Nuclear Waste Pohey Act, the DOE has aheedy bem au pa======= of waste &sposal sites provided that the follomag entena are met:

I,

e The NRC certifies that the disposal accan ==t=fiam applicable requusments m -

e The hasasse sets aside aufhiaar funds to casure that long-tenu custody would be at no cost to t j Federalgevenonent 1

The NRC detenmoes that such controls are necessary or dearable to protect the pubhc A sundar provmon in sectaan 151(c) was used as the valucle to transfer custody of the AMAX site near

Parkersburg, West Virgmia, from AMAX to DOE.

i j

i If DOE is supportive and has avadable resources, and if the legislative lustory supports the this manner, the sachon 151(b) opoon would amm**e a ready-ninde ==ch==== to pnmde for i==**===1 ccatrol of the waste disposal sites. Use of this opuan would al====* the need for I- and

! r= pan =>hle parties to develop and negotiate specific msutunanal controis for &sposal sites. This ap j could reemos the regulatory burden and simplify the 4=namrataan that would otherwise be requesd t i

that the proposed canaal ==ehma== will be durable and offective in proteccog the pubhc In August 1995, the NRC staffinneds to initiate d===-==

with the DOE to ingune whether, and under what tunna, the DOE would be ===ehle to using the pnmsion in secoca 151(b) to transfer custody

! disposal sites and =ana ph h long tenn control and surveillance of the sites. If the DOE is amenable, t NRC could develop a standard procedure for transfernas the sites. In addanon, the NRC could then gedance to hoensees and r= pan ==hla panies about the use of the ==rh====

and implemet the pnmsnon in consuncoon with the final rul=nahng on rabological cntena for dana ==i=====ng Ifone or more bemers to j

the use of this provmon exist, the NRC could draft and subaut sandar legislanon for Congr===w=al

====larataan. In this latter case, the negotianons with DOE would prove insenactrve regenhng the types issues that are likely to arise dunng legislative amadaration of the proposal 1

j NUREG-1444, Supphanat 1 40 i

i 1. - --

i

i WHAT IS DECOMMISSIONING?

e NRC Regulations ._

4 Decommissioning means to remove (as a facility) safely from service and reduce residual radioactivity to a level that W permits release of the property for unrestricted or restricted

• use and termination of the license.

Does not include care and disposal of spent fuel

• Does not include non-radiological demolition (Example: restoration to " green field" conditions)

• Covered separately by 10 CFR 50.54 (bb) which requires submittal of spent fuel management and funding program.

n t

9

= ,

I 2 .

DECOMMISSIONING ALTERNATIVES *

• Under DECON (immediate dismantlement), equipment, structures, and portions of the facility containing radioactive contaminants are removed or ,

decontaminated to a level that permits release for unrestricted use and termination of the license. (See Reg. Guide 1.86 for guidance) i e Under SAFSTOR, often considered " delayed DECON,"

a nuclear facility is placed and maintained in a condition that allows the decay of radioactivity to reduce radiation levels at the facility; after this it is dismantled.

e Under ENTOMB, radioactive contaminants are encased in a structurally long-lived material such as concrete and the entombed structure ist appropriately maintained and monitored until the radio _ activity decays to a level i

r l

permitting unrestricted release of the property. l l

l

• Described in Generic Environmental Impact Statement on g Decommissioning; NUREG-0586.

u COMPLETED & CURRENT DECOMMISSIONING PROJECTS e 63 research and test reactor licenses terminated e 11 research and test reactors now being dismantled or have license amended for Possesion-Only 4

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ __ _]

e 17 power reactors in decommissioning process 2 power reactors completed Pathfinder & Shoreham 1 power reactor now being dismantled Fort St. Vrain 9 power reactors with approved SAFSTOR g decommissioning plans

• CVTR, Dresden, Fermi 1, GE VBWR, Humboldt Bay 3, La Crosse, Peach Bottom 1, Rancho Seco, & Indian Point 1; Three Mile Island 2 in Post-Defueling Monitored Storage 5 power reactor decommissioning plans under review Big Rock Point, San Onofre 1, Trojan, Yankee Rowe &

Saxton i

5 l-

TYPICAL CURRENT REGULATORY PROCESS FOR PREMATURE DECOMMISSIONING e Continued compliance with license and regulations is i l required after shutdown l

l e Licensee submits license amendments / relief requests to NRC j w e Possession-only license amendment i

e Reliefs / exemptions granted may include:

Containment leak testing Licensed operators a.

Offsite emergency preparedness reduction Property damage liability? insurance reduction

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RULEMAKING ACTIVITIES e Radiological Release Criteria for Decommissioning Facilities e Initial Part 50 Decommissioning Applicability e Revise Spent Fuel Pool Fire Sequence Affected Regulations and Indemnity ,

Levels for Permanently Shut Down Reactors  !

i e Physical Protection for Storage of Spent Fuel i

D e Decommissioning Cost and Funding Evaluations e Operators, Plant Staffing, and Training th Shut Down Reactors' l D

si

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e TECHNICAL GUIDANCE i

• Revise RG 1.86 - Will be a new guide -

• Standard Format and Content for Decommissioning Submittals e Standard Review Plan b

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RANCHO SECO e Shut down in June 1989. SAFSTOR Decommissioning Plan approved in March 1995.

e Conducting activities in accordance with approved plan.

e SMUD intemal review considering DECON decommissioning attemative.

e Part 72 (specific license) ISFSI pad is completed and horizontal storage modules are being delivered. Part 71 (transportation) license application undergoing NRC i review for multipurpose (storage / transport) cask. Licensee could be ready to offload fuel to ISFSI by October 1996.  ;

YANKEE ROWE e Shut down in October 1991. SAFSTOR Decommissioning Plan approved '

February 1995. Appeals Court decision (July 1995) granted hearing opportunity.

On March 1,1996, after a prehearing conference, Atomic Safety and Licensing

] e Board issued an order stating its finding regarding the the joint petition of Citizens  ;

Awareness Network and New England Coalition on Nuclear Pollution to intervene on the Yankee decommissioning plan. Although the ASLB determined the  ;

petitioners had standing, the ASLB did not find any of the five contentions to be '

admissible. Subsequent Commission order prevents staff re-approval of Plan until I

appeal process completed.

e Yankee Atomic applied for a (10 CFR 71) license to enable shipment of the reactor vessel. The vessel will not be shipped before summer 1996. i e Yankee intends to pursue dry cask storage of its spent fuel.

I i

11 i

THREE MILE ISLAND UNIT 2 e Accident occurred in March 1979; Defueling completed April 1990 e' License plans for Post-Defueling Monitored Storage (PDMS) and Possession-Only License approved by NRC in 1993.

e Conducting activities in accordance with approved PDMS technical srecifications.

I SAN ONOFRE, UNIT 1 e Shut down November 1992.

e Conducting activities in accordance with approved permanently defueled technical  !

specifications. Proposed decommissioning plan awaiting NRC review.

e Licensee considering ISFSI, but has not submitted Part 72 license request.

i r

w TROJAN i V

\

e Shut down November 1991 ,

e November 1,1995, licensee completed the large component removal project.

e Commission issued order preventing further dismantlement until final ,

decommissioning plan approved. i e No requests for hearing received for December 22,1995, Federal Register notice on Eevironmental Assessment and Safety Evaluation for decommissioning plan.

e Combiced NHC/ State of Oregon public meeting held February 13,1996, to  !

discuss the results of NRC and State decommissioning plan review.  !

e No requests for hearing received by State of Oregon for its public notice. Hearing regarding State approval of decommissioning plan held on March 7,1996. State  :

approval granted.

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4 BP24 (03/96)

DECOMMISSIONING NUCLEAR POWER PLANTS Backaround Several licensees have announced their decisions to permanently cease power

operation of their nuclear power plants. The licensees

• decisions have been 2

based on economic and technical considerations. Thus, these facilities and

! several others have entered the decommissioning process before their operating licenses expire, earlier than originally anticipated. Decommissioning highlights for individual plants are presented in Tables 1 and 2.

Decommissionina 2

Title 10 of the Code of Federal Reaulations Section 50.2 (10 CFR 50.2),

defines decommissioning as the safe removal of a facility from service and i reduction of residual radioactivity to a level that permits release of the property for unrestricted use and termination of the license. Decomissioning involves three different alternatives: DECON, SAFSTOR, or ENTOMB.

i Under DECON (immediate dismantlement), equipment, structures, and portions of

! the facility containing radioactive contaminants are removed or decontaminated

! to a level that permits release for unrestricted use and termination of the i , license.

Under SAFSTOR, often considered " delayed DECON," a nuclear facility is maintained in a condition that allows the decay of radioactivity to reduce radiation levels at the facility; afterwards, it is dismantled.

' Under ENTOMB. radioactive contaminants are encased in a structurally long- ,

lived material such as concrete and the entombed structure is appropriately .

maintained and monitored until the radioactivity decays to a level permitting i unrestricted release of the property. .

I To be acceptable, the rethod selected must provide for completion of

, decommissioning within 60 years. A time beyond 60 years will be considered only when necessary to protect public health and safety in accordance with j Nuclear Regulatory Comission (NRC) regulations.

Reaulations 4

~

The procedure for decomissioning a nuclear power plant is set out principally in NRC regulations (10 CFR Parts 50.75, 50.82. 51.53, and 51.95). An underlying assumption embodied in the current regulations is that decomissioning would occur after the facility operating license expired.

Five years before the licensee expects to end operation of the plant, it is

obligated to submit a preliminary decommissioning plan containing a cost estimate for decomissioning and an up-to-date assessment of the major technical factors that could affect planning for decomissioning. Then, within one year before expiration of the license. (or two years after operation for plants closing before their license expires) a licensee must submit to NRC an application for authority to decomission that facility.

)

67

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I BP24 (03/96) together with an environmental report covering the proposed decomissioning activities. The application must also be accompanied, or preceded, by a proposed decommissioning plan that includes:

(1) A description of the decommissioning alternative chosen and activities involved:

l (2) A financial plan showing an up-to-date cost estimate for decomissioning, the amount of funds currently available for decomissioning and plans for ensuring the availability of adequate funds for completion of decomissioning.

The NRC reviews the decomissioning plan, determines its impact on the environment through an environmental impact statement or environmental assessment and gives notice to interested persons. If the NRC finds the proposed decommissioning plan to be satisfactory, it issues a decommissioning order that approves the proposed decommissioning plan and authorizes decomissioning. Upon completion of decommissioning activities, including the I

termination radiation survey, the NRC issues an order that terminates the l license. I i

Prematurely Shutdown Plants Since the firral decomissioning rule was published in 1988, six power reactor facilities have shut down prematurely:

e Fort St. Vrain Nuclear Generating Station, e Shoreham Nuclear Power Station, e Rancho Seco Nuclear Generating Station, e Yankee Rowe Nuclear Station, e San Onofre Nuclear Generating Station. Unit 1. and e Trojan Nuclear Plant.

Three Mile Island Nuclear Station. Unit 2. also ceased operation after the )

March 28. 1979, accident. In addition. Indian Point Nuclear Generating Station Unit 1 and Dresden Nuclear Power Station Unit 1. which were shut down in 1974 and 1978, respectively, are in the decomissioning process.

Moroved Decommissionina Plans In June 1992, the NRC issued an order to Long Island Power Authority, approving the Shoreham decomissioning plan. Long Island Power Authority announced completion of dismantlement of the facility in October 1994.

In November 1992, the NRC issued an order approving the Fort St. Vrain decommissioning plan and dismantlement activities are ongoing.

The NRC approved Yankee Rowe's decomissioning plan on February 14, 1995.

On June 16, 1993, the NRC staff issued its safety evaluation and environmental assessment of the Rancho Seco decommissioning plan. The plan 3roposes safe storage (SAFSTOR) of the facility for about 20 years followed )y dismantlement bd

l d

BP24 (03/96) l and decontamination. Approval of the s commissioning plan was delayed because of contentions raised by the Environmental and Resources Conservation Organization (ECO). However. ECO reached a settlement with the Sacramento Municipal Utility District. the licensee for Rancho Seco, and on August 1, 1994. withdrew from the proceeding. The staff reviewed and updated its arevious safety evaluation and issued the order authorizing decommissioning of Rancho Seco on March 20, 1995.

Early Comoonent Removal In January 1993 the Commission issued guidance regarding activities that may be permitted before a decommissioning plan is approved. Licensees of plants that do not have operating licenses or have shutdown orders should not undertake any decommissioning activity that would (1) foreclose the release of the site for possible unrestricted use. (2) significantly increase decommissioning costs. (3) cause any significant environmental impact not previously reviewed, or (4) violate the terms of the existing license. Also.

licensees may be permitted to use their decommissioning funds for ap] roved decommissioning activities. even though their decommissioning plans lave not yet been approved by the NRC.

In accordance with NRC guidance, in November and December 1993 Yankee Atomic Electric Com3any (YAEC) shipped the four steam generators and the pressurizer from the Yancee Rowe plant to the low level waste' burial site in Barnwell, South Carolina. Between March and June 1994. YAEC conducted a second phase on early component removal in which it shipped the reactor coolant pumps, and contaminated piping to Barnwell.

During the early component removal process, the Citizens Awareness Network (CAN), a group in the Rowe. Massachusetts area, filed a complaint in the Massachusetts District Federal Court claiming the NRC did not follow the National Environmental Protection Act (NEPA) in its review of the licensee's early component removal 3rogram. The court denied the complaint on jurisdictional grounds: lowever, CAN appealed to the U.S. Court of Appeals for the First Circuit in Boston. On July 20. 1995, the Court issued its decision, which found that the NRC erred when it rejected CAN's request for a hearing on the component removal program, that CAN was entitled to a hearing under section 189a of the Atomic Energy Act, and that the NRC had violated NEPA by permitting YAEC to initiate the component removal program before the agency had prepared an environmental assessment or impact statement. The Court remanded the case to the NRC for further action.

In the September 6.1995, Federal Regfster, the Commission provided notice to the public of the Court of Appeals decision, solicited public comment regarding the Commission's legal authority to allow or forbid further '

decommissioning activity at Yankee, and stated the NRC's intention to issue a future Federal Register notice that would offer an opportunity for a hearing on the Yankee decommissioning plan. On October 12. 1995, the NRC issued an Order that forbid the licensee for Yankee. Yankee Atomic Electric Com)any, from conducting further " major" decommissioning actisities at the Yan(ee facility until the hearing is completed.

bf

I BP24 (03/96) '

I On October 27, 1995, the NRC provided public notice of the opportunity for a hearing regarding reapproval of the Yankee decomissioning plan. On November

30. 1995. CAN and the New England Coalition on Nuclear Pollution (NECNP) submitted a joint petition to intervene on the Yankee decomissioning plan.  !

On January 16. 1996, the Comission turned over the petitioners

• pleadings to I the Atomic Safety and Licensing Board (ASLB). The Comission provided guidance to the ASLB that requests that if the ASLB determines a hearing is I required, the Comission would have it start in mid-April 1996.

In November 1994, the licensee for the Trojan Nuclear Plant. Portland General Electric, comenced its large component removal project (LCRP). The project included the removal and shipment of the Trojan steam generators and pressurizer to the U.S. Ecology low-level waste repository at Hanford.

, Washington. On September 6.1995, in a Federal Register notice separate from, but similar to, the Yankee notice, the Commission announced its intention to issue a Federal Register notice offering an opportunity for a hearing on whether to approve the Trojan decomissioning plan. In addition, it solicited public coment on the decommissioning activity at Trojan. Following publication of the Federal Register notice, the Don't Waste Oregon Council filed lawsuits in the Oregon State Supreme Court and the U.S. Court of Appeals for the Ninth Circuit requesting suspension of the LCRP activities. In response to the injunctions, the two courts imposed stays that they subsecuently lifted due to the courts' determinations that they lacked jurisciction over the matter. On October 12. 1995. the NRC issued an Order to Portland General Electric that stated that NRC would not require PGE to halt LCRP. but expected PGE to take no further decomissioning actions involving major dismantling at Trojan until final NRC approval of the decomissioning

>lan. The LCRP was completed on November 1.1995, when the final component to

)e shipped the 3ressurizer, was buried at Hanford. On December 22. 1995, the NRC staff publis1ed a Federal Register notice offering an opportunity for public comment on the Environmental Assessment and Safety Evaluation for the decomissioning plan.

Dresden Incident and NRC Followuo Actions Dn January 25, 1994 Comonwealth Edison Company (CECO) workers at the Dresden Unit 1 site discovered about 55.000 gallons of water in the containment building. The source of the water was a service water line that had frozen and ruptured within the unheated containment. The water was pumped from the containment building for processing by the site radwaste system. The NRC conducted a two-week special team inspection to review and evaluate the circumstances and significance of this event. The inspectors identified a pattern of declining management oversight at the facility after the unit was permanently shut down in 1978. The NRC imposed a civil penalty of $200.000 on CECO for its failure to maintain required systems and the staffing of Dresden Unit 1 in accordance with the Dresden Unit 1 decomissioning plan. CECO is taking corrective actions to resolve the identified deficiencies.

The incident at Dresden Unit 1 prompted an NRC review of the likelihood of similar events at other facilities in the decommissioning process. The staff issued Bulletin 94-01 on April 14. 1994 to each of the licensees of the permanently shutdown nuclear power reactors with spent fuel in the spent fuel 7o

BP24 (03/96) 3001 to inform them of the results of the special NRC inspection at Dresden Jnit 1 and to request that they take actions to ensure that the cooling and 4

shielding for fuel in the spent fuel pool were not compromised. The NRC J

com)leted team inspections in 1994 confirming adherence to the bulletin by eac1 of the eight affected facilities.

4 Rulemakina Throughout fiscal year 1995 the NRC staff continued work on revisions to NRC regulations to clarify their applicability and to make certain changes in decomissioning policy regarding permanently shut down reactors. On July 20, 1995, the Comission issued a " Notice of Pro)osed Rulemaking on

! Decomissioning of Nuclear Power Plants." T1e proposed rule redefines the 3 decomissioning process, defines terminology related to decommissioning.

requires licensees to provide the NRC with early notification of planned i

decomissioning activities at their facilities, and explicitly sets forth the

a)plicability of certain NRC requirements to permanently shutdown reactors.

q T1e Commission believes the proposed amendments would enhance efficiency and uniformity in the decomissioning process for nuclear power reactors. The proposed amendments would allow for greater public participation in the decomissioning process and furnish the licensed comunity and the public a

, better understanding of the process as the operating personnel at a nuclear

. power reactor facility undergo the transition from an operating organization to a decommissioning organization. Public comments have been received and are being analyzed by the staff. A final rule will be considered by the Comission in the next few months.

i A new rule, entitled " Safeguards for Spent Nuclear Fuel or High-Level i

Radioactive Waste - 10 CFR Parts 60. 72, 73. and 75" (SECY-95-104), addresses

, physical protection requirements for the storage of spent fuel and high level radioactive waste in a permanently shutdown reactor. independent spent fuel

storage installation, monitored retrievable storage installation, or a

geologic repository. The Comission published the proposed rule on August 18, i 1995. The public coment period expired on November 13. 1995, and a final rule is scheduled to be issued in Sumer 1996.

1 Other rulemakings that are anticipated in the decommissioning area include a

, revision of regulations to address spent fuel cooling periods and indemnity issues: decomissioning costs, funding, and financial assurance.

Bia Rock Point Although Consumers Power Company plans to continue to operate Big Rock Point until its current license expires on May 31, 2000, the licensee submitted its proposed SAFSTOR decomissioning plan for the plant on February 27. 1995.

This submittal of a decommissioning plan was made several years earlier than required by NRC regulations to allow for early NRC review of the plan as the plant continued to operate. Review activities are ongoing and are expected to be completed in February 1996.

71

i

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BP24 (03/96) 1 NRR/NMSS Memorandum of Understandino on Decommissionina j On March 15, 1995, the Office of Nuclear Reactor Regulation (NRR) and the Office of Nuclear Material Safety and Safeguards (NMSS) reached agreement on a realignment of certain responsibilities regarding power reactor decomissioning. In the future. NRR will maintain project management responsibility for power reactor facilities until fuel is permanently

transferred from the spent fuel pool. Consistent with the new

responsibilities, project management responsibilities for the Humboldt Bay Power Plant Unit 3. Lacrosse Boiling Water Reactor, and Vallecitos Boiling Water Reactor nuclear facilities were transferred from NMSS to NRR.

I i  !

CONTACT: 1 Seymour H. Weiss, Non-Power Reactors and Decommissioning Project Directorate,

Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, i Washington, DC 20555, (301) 415-2170 '

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1 BP24 (03/96)

TABLE 1 DECOMMISSIONING HIGHLIGHTS INDIAN POINT UNIT 1 e October 31. 1974 plant was r ntly shut down because its emergency core cooling system did not ns current regulatory requirements.

e January 1976 reactor was defueled.

e June 19. 1980. NRC order revoked authority to operate plant.

e October 17. 1980. licensee submitted proposed decommissioning plan. NRC review has been ongoing since then and has prompted numerous supplemental licensee submittals.

e January 1996. the proposed decommissioning plan was submitted to Commission for approval.

HUMBOLDT BAY POWER PLANT UNIT 3 e July 2. 1976, plant was shut down due to seismic issues.

e July 30. 1984 Decommissioning Plan submitted.

e July 19, 1988. SAFSTOR Decommissioning Plan approved. Spent fuel (390 assemblies) will remain onsite in the spent fuel pool until a federal repository is available for it. ~^

DRESDEN UNIT 1 e October 31, 1978. plant was shut down to meet new federal regulations and to perform chemical decontamination of major piping systems.

e January 7.1986, while plant was still out of service, licensee announced its decision to decommission the plant rather than comply with regulations imposed in response to the March 1979 accident at Three Mile Island Unit 2.

e July 23, 1986, license was amended to possession only license (POL) status.

e September 3.1993, decomissioning plan was approved.

e January 25. 1994 licensee personnel discovered about 55.000 gallons of water in the containment building. The source of the water was a service water line which that had frozen and ruptured within the unheated containment. The water was pumped from the containment building for processing by the site radwaste system. The NRC responded by conducting a two-week special team inspection that identified rumerous discrepancies that the licensee had to address.

e July 13, 1994, licensee submitted a check for $200.000 in response to the NRC-imposed civil penalty for its failure to maintain required systems and to staff unit in accordance with Dresden Unit 1 decommissioning plan.

FORT ST. VRAIN e August 18, 1989, plant was permanently shut down because of failure of the control rod drives and degradation of the steam generator ring 73

a BP24 (03/96) header.

e May 21,1991. lict I was amended to possession only license (POL) status. '

e June 11, 1992, all fuel was placed in an onsite independent spent fuel storage installation (ISFSI).

e November 23. 1992. NRC issued order approving licensee decommissioning plan.

e September 1.1993, removal of the prestressed concrete reactor vessel top head was completed.

e A)ril 1.1994, all of the graphite reflector blocks had been removed from t1e reactor vessel and shipped to the low level waste burial site at Hanford. Washington.

SHOREHAM j

e June 28. 1989, licensee's shareholders approved agreement with the New York State to not operate the facility.

e August 24, 1989. reactor vessel was defueled.

e June 14, 1991. license was amended to POL status, e February 29, 1992, license was transferred to Long Island Power Authority for decommissioning of plant.

e June 11. 1992. NRC issued order approving licensee decommissioning plan.

e September 1993, transfertofofuel.to Limerick began. Fuel transfer was completed June 1994.

e October 1994. the licensee announced completion of the dismantlement.

Confirmatory surveys conducted.

e April 11.1995, decommissioning complete. POL terminated.

RANCHO SEC0 e June 7. 1989. )lant was shut down because voters approved non-binuing referendum pro 11 biting licensee from operating facility.

• December 8. 1989. reactor vessel was defueled.

e March 17, 1992, license was amended to POL status.

• Environmental and Resources Conservation Organization (ECO) was active intervenor in regards to proposed decommissioning plan.

e June 16, 1993. NRC issued safety evaluation and environmental assessment of proposed decommissioning plan.

e November 30, 1993, the Atomic Safety and Licensing Board (ASLB) admitted for hearing certain contentions associated with decommissioning funding and costs of Rancho Seco independent spent fuel storage installation.

e August 1. 1994. EC0 reached settlement with Sacramento Municipal Utility District and filed notice of withdrawal: ASLB terminated proceeding. i e September 2.1994 Commission order (CLI-94-14) authorized NRC staff to issue decommissioning order.

• March 20. 1995. NRC approved the decommissioning plan for SAFSTOR by issuing the decommissioning order.

BP24 (03/96)

YANKEE R0WE o October 1. 1991, plant was shut down and vessel defueled because of concerns about reactor vessel integrity.

e February 27. 1992, licensee announced permanent cessation of operations because of inability to address uncertainties associated with the safety margin of the reactor vessel.

e August 5. 1992. license was amended to POL status, e July 15. 1993. NRC stated it had "no objection to early component removal activities" proposed by the licensee.

e November 16 to December 8.1993, as part of the early component removal activities, the four steam generators and pressurizer were shi) ped from the plant to the low level waste burial site in Barnwell. Sout1 Carolina.

e March 11. 1994 NRC stated it had "no objection" to use of decommissioning trust funds for proposed second phase of activities associated with early removal of components. including reactor coolant pumps, contaminated piping, and asbestos. Activities were completed by June 30. 1994.

e March 31, 1994 Citizens Awareness Network (CAN) filed a complaint in the Massachusetts District Federal Court claiming the NRC did not follow National Environmental Protection Act (NEPA) in its review of licensee's early component removal 3rogram. The court denied the complaint on jurisdictional grounds: lowever. CAN appealed to the U.S. Court of Appeals for the First Circuit in Boston.

e February 14. 1995. NRC approved the decomissioning plan for SAFSTOR.

e March 23. 1995. Yankee Atomic applied for a (10 CFR 71) license to enable shipment of the reactor vessel. The vessel will not be shipped before summer 1996.

e July 20. 1995. First Circuit found that the Commission erred when it rejected CAN's request for a hearing on the component removal program, that CAN was entitled to a hearing under section 189a of the Atomic Energy Act, and that the NRC had violated NEPA by permitting YAEC to initiate the component renoval program before the agency had prepared an environmental assessment or impact statement. The Court remanded the case to the Commission for further action.

e October 27, 1995. in response to the July 1995 Court of A> peals decision.

the NRC staff issued a Federal Register notice offering t1e public an opportunity for hearing.

e November 30. 1995. CAN and the New England Coalition on Nuclear Pollution submitted a joint petition to intervene on the Yankee decommissioning plan.

e January 16. 1996, the Commission turned over the petitioners' pleadings to the Atomic Safety and Licensing Nard (ASLB). The Comission 3rovided guidance to the ASLB that requests tut if the ASLB determines a learing is required the Comission would have it start in mid-April 1996.

THREE MILE ISLAND UNIT 2 e March 28, 1979, accident occurred in the plant that caused permanent cessation of operations.

i

BP24 (03/96) e January 30, 1990, reactor was defueled.

e August 12. 1993, processing of accident generated water was completed.

e September 14. 1993. POL amendment was issued.

e December 28, 1993, post-defueling monitored storage technical specifications were issued.

! SAN ONOFRE UNIT 1 i

i e November 30. 1992. based on settlement agreement with California Public Utilities Commission licensee permanently shut down plant rather than bring it into compliance with current NRC safety requirements.

I e October 23. 1992. POL amendment was issued. Amendment became effective l March 9.1993, when reactor vessel was certified as completely defueled.

l e December 28, 1993, permanently defueled technical specifications were I

issued.

e November 3, 1994. licensee submitted proposed decommissioning plan for NRC review.

TROJAN e Januaryt4.1993, licensee announced permanent cessation of operations.

e January 27, 1993. reactor was defueled.

e May 5. 1993. NRC. issued POL amendment.

I e November 1994, licensee consnenced removal of steam generators and pressurizer for shipment to the U.S. Ecology low level waste burial site at Hanford. Washington, e January 26. 1995. licensee submitted proposed decommissioning plan.

• September 6.1995, in a Federal Register notice the Commission announced -

its intention to issue a future Federal Register notice offering an opportunity for a hearing on whether to approve the Trojan -

decommissioning plan.

e November 1.1995, licensee completed the large component removal project.

• December 22. 1995, NRC staff published Federal Register notice offering opportunity for Jublic comment on Environmental Assessment and Safety Evaluation for t1e decommissioning plan.

BIG ROCK POINT e May 31, 2000, is expiration date of current license, o February 27, 1995. licensee submitted SAFSTOR decommissioning plan for early NRC review. Review is ongoing and expected to be completed in February 1996.

76

TABLE 2 REACTOR DECOMMISSIONING STATUS SHUTDOWN POWER REACTORS DOCKET NO. THERMAL SHUT PRESENT FUEL REACTOR POWER LOCATION DOWN STATUS ONSITE?

50-3 Indian Point 1 615 MW Buchanan 10/31/74 Possession Yes (PWR) New York Only Lic.

50-10 Dresden 1 700 MW Morris 10/31/78 SAFSTOR Yes (BWR) Illinois Approved 50-16 Fermi 1 200 MW Monroe Co. 9/22/72 SAFSTOR No (Fast Breeder)* Michigan Approved ,

150-18 GE VBWR 50 MW Alameda Co. 12/9/63 SAFSTOR No (BWR) Cal.ifornia Approved 50-29 Yankee Rowe 600 MW Franklin Co. 10/1/91 SAFSTOR/ Yes (PWR) Massachusetts DECON Approved 50-114 CVTR (Pressure 65 MW Parr 1/67 Byproduct No Tube Heavy Water) S. Carolina Lic. (St.)

'I 50-130 Pathfinder 190 MW Sioux Falls 9/16/67 DECON No (Nuclear Superheat BWR)* South Dakota NRC Part 30 50-133 Humboldt Bay 3 200 MW Eureka 7/2/76 SAFSTOR Yes (BWR) California Approved 50-171 Peach Bottom 1 115 MW York Co. 10/31/74 SAFSTOR No (HTGR)* Pennsylvania Approved 50-206 San Onofre 1 1347 MW San Clemente 11/30/92 Possession Yes (PWR) California Only Lic. -

50-267 Fort St. Vrain 842 MW Platteville 8/18/89 DECON Yes (HTGR)* Colorado Approved 50-312 Rancho Seco 2772 MW Sacramento 6/7/89 SAFSTOR Yes (PWR) California Approved 50-320 Three Mile 2772 MW Middletown 3/28/79 Possession No (PWR) Island 2 Pennsylvania Only Lic.**

50-322 Shoreham 2436 MW Suffolk Co. 6/28/89 License No (BWR)* New York Terminated 50-344 Trojan 3411 MW Portland 11/9/92 Possession Yes (PWR) Oregon Only Lic.

50-409 Lacrosse 165 MW Lacrosse 4/30/87 SAFSTOR Yes (BWR) Wisconsin Approved Project management assigned to Office of Nuclear Material Safety and Safeguards.

• • Post-defueling monitored storage (PDMS).

77

4 D$COMMISSIONINGTIMELINE 1

: PHASEIN  :

O PHASEI  : PHASEN

, Few Months to SeveralVeere Few Mencia to SeveralVeere 0 Days to Many Decades SER

& EA l SAFSTOR Diesnentionient Dec:  ; AcewMu PrehlMead Site "" _ z; VerteMe Tiene Ported l

+30 % + Public Notencation Pubilc Subpert L 4---90 DaysW W EPR Post Shutdown k

Acum W Certitication Licenee Tenninellon b

of FuelResnowed Plan & Federal front Reactor Regleter Notice 59.50 50 50 Operatior *N Shutdown Besed

- ' ; Acewides s 20% Dec: _ ; Actowattee > 23%

P---

E- _; E ;53%

4 c AOeneston-ea-w.a aag Cost Eel of Genestc Decosasnieelening Coot Eat (VesteWe Tinto Portod) (VerteenoTiene Portod) ucense

ennenent one Spcenc Tenninetton Dec -i_

Ceeestion Coot Estisstate "

el Operatione Sutnetitled o

0

Decommissioning Planning When There's No Place to Put the Waste SNF and LLW Disposal um-By L Rurland. S.M. Stoller Corporation SNF will remain on-site until away- 4 -

from-reactor storage / disposal becomes v' - Rudmadis theMan-IntroducilOn available. ne federal repository for SNF j T'

=-* sing Services ne delay in the federal waste man- is projected to be available in the year d* Corponanon. He in agement system to begm accepting spent 2010, at the earliest. A monitored retnev.

nuclear fuel (SST) and the contmuing un- able storage (MRS) facility to fill the gap , most of availability of off site low-level radioac- is not likely to be completed even long waste use waste (LLW) disposal affect nuclear after January 31,1998, the date when the n paw er plant (NPP) decommissioning plan- DOE was to begin accepting commercial has been rung. ne status of SNF and LLW disposal, NPP SNF (under the provisions of the . and Wasse current waste management ahernaoves,and Nuclear Waste Policy Act of 1982, as . ofAe Ameri-the projected schedule for disposal facili- amended in 1987). ne timetable for off- . Neirshcensed ties becoming operational are imponant site disposition of SNT must await future is #cw /cr-factors for those NPP's. developments. is chenucal Until a repository for SNF becomes Most states, either individually or as Cigdhiiversity and a Jt:S;.in nucleTr operauonal, affected NPP's can use dry parties to compacts, have plans to pro- ,,

storage technologies, which will be com- vide access to a licensed LLW facility by, ~ . de Polytechnic 4

patible with the transportation and disposal or before, the year 2001, The end of that ,

features of the evolving federal waste man- period corresponds to the beginning of agement system. For LLW, strategies are the period when the operating licenses prepared for the possibility of considerable available to reduce the volume of LLW (OL) for the oldest NPP's start to expire. delay. Until SST and LLW disposal be-from nuclear plant operations and decom- nerefore, the number of NPP's with an come available. decommissioning planning nissiorung activities. Furthermore, plant operating license (OL) that will expire and preparacons must account for the wastes areas such as the radioactive waste and while LLW disposal facilities are being that will remam on-site.

turbtne buildings may be suitable with mini- developed should be small. No OL's will mel modifications to accommodate ex- expire before the year 2000. Thereafter, SNF and LLW tended storage of LLW. there will only be one in each of the years DeCOmmlSloning Even if a NPP is not actively en- 2000,20(M. and 2006. However, most gaged in decommissioning, at least the NPP's that have shut down did so before SNF Management financial planning for decommissioning license expiration. It may be anticipated SNF is normally stored in the spent should be updated to account for the that several NPP's will shut down in a fuel pool until the pool capacity is ex-changing LLW waste and SNT disposal penod when LLW disposal is not avail- hausted. Additional SNF can be accom-situation. For plants that are actively able. De NPP's that will be affected modated in on-site dry storage facilities.

planning or engaged in decommission- most are those that have already shut an increasing number of which are ap-ing the reality is that a NPP's license down and those that will shut down be- proved by the site specific or general cannot be terminated until the SNF and fore LLW disposal again becomes avail- license provisions of Title 10 of the Code LLW have been removed. A vanery of able. For those plants, the time until the of Federal Regulations Pan 72 (10 CFR NRC approved on-site dry storage tech- end of the decade will be eventful. It will 72), Licensing Requirements for the Stor-nologies for SNF are now available for be a tire when: age of Spent Nuclear Fuel snd High Les el use when the capacity of the spent fuel + the DOE comnutment to begin ac- Waste. Even if all the SNF 'ere con-pool is exceeded. or to benefit from the ceptmgcommercialSNFin 1998 will tained in the spent fuel pool when the more simple. passiv e mode of operation. be clanfied plant is shut down, a transition fro n wet The options for management of LLW are e an MRS could become available as a storage to dry storage could be beneficial.

not so straight-forward. This presenta- governmentorcommercialoperation Decommissioning operations are tion pnmarily considers how decommis- + plans and schedule for the operacon more complicated with SNF in the spent sioning planning is affected when access of the federal repository are defined fuel pool. With SNF in the spent fuel to a LLW disposal facility is not avail-

• state / compact LLW disposalfacili- pool the license technical specifications able. Of particular mterest is the signifi- ties are planned to be operanonal include stnngent safety related secu-cant storage space that the radioactive for most NPP's nty, procedural, operational, and re- ,

waste building (RWB) can provide for Past experience has shown that road- porting requirements. Howeser, SNF l extended storage of accumulated LLW. blocks exist for the eventual availabibty of LLW and SNF disposal. NPP's should be (Continued on page 18) ,

16 Nuclear Plant Journal, January February 1996

1 l

a NPP could be used to store LLW, as license conditions or technical specifications.

DecomnliSSIOning...' may be required to support decommis-

• does not create an unreviewed Contmuedfrom page 16 sioning. Also, many of the features noted in the following discussion for safety question.

+ does not exceed the LLW genera-use of a RWB may be found as wellin tion from five years of operation.

the turbine building to provide even LLW storage operations must not must remain in the spent fuel pool for at more LLW storage space. Available least five years (10 CFR 961, Appendix storage space in the RWB could be affect the demonstra E). The removal of the SNF from the increased by selectively events suchremoving as high winds,in- building to withstand earthquake.

spent fuel pool is on the critical path for terfering contaminated systems, struc-decommissioning operations. One al. tures and components. That removal fire and flooding. Operation m ternauve to avoid the high cost associ- would be most beneficial if the items comply with the principles ated with maintaining the spent fuel removed to increase storage capacity and the existing license. O were items that would be eventually tion doses must demonstrate compli-pool, and resulting more complex op- removed in the subsequent distriantle- ance with 40 CFR Part 190.

erations for decommissioning, is to For use as an interim storage facility, ment work. Storage capacity on the transfer the SNF to an independent spent the RWB should satisfy the design objec-fuel storage installation (ISFSI) using order of 100,000 cubic feet, or more, would not be unusual Accommodat- tives and criteria in guidance documents, dry storage technology.The capitalin- ing a five year generation of LLW from including:

NRC Generic Letter 8138, Storage vestment for an ISFSI would eventu- + a f

ally be offset by the lower cost to main- a typical operating BWR would ofrequire Low-levelRadioactive Wastes at tain an ISFSI, and lower costs for sub- storage for about 28,000 cubic feet of Power Reactors l sequent decommissioning operations LLW, and only a small fraction + of NRCInformation that Notice No.90-09, that would no longer be affected by the (perhaps only 5000 cubic feet) after Extended Interim Storage of Low-i presence of SNF in the spent fuel pool. return from an off-site volume reduc- level Radioacuve Waste by Fuel tion facility. Typically, LLW genera-tion from a PWR would be less by a Cycle and Matenals Licensees f ,

LLW Management + NUREG-0800, Standard Review Even if LLW disposalis not avail- factor of 3, or more. If the state /com- Plan,Sectioni1.4 SolidWasteMan-able at the start of decommissioning, pact LLW disposal facility for the plant ageinen~t Systems T ~ L.* ,

the DECON (prompt decommission- becomes operational without signifi- + NRC Regulatory Guide 1.143 De-cant delay, the above mentioned typical l signGuidanceforRadioactiveWaste l ing) alternative can remain as a pos- volumes of LLW expected from plant sible alternative. In that case, LLW M=unmmrSystems.Stmetures,and could be stored on-site until access to a operation in the interim should easily Camanamts. i I

LLW disposal facility becomes avail- be accommodated within the RWB. Operation of a RWB for the storage able. Under these conditions, strate- A RWB often can be suitable for of LLW also must satisfy:

gies to reduce the volume of LLW to be storing decommissioning LLW + because license conditions stored on-site become especially im- the design basis typically was to per- + 10 CFR Part 20 standards for radia- (

portant. The following are exarr.ples of form the functions of a LLW storage tion protection approaches that are routinely used to and shipping facility as well* as 10CFRPartS0licenserequirements a LLW reduce the amount of LLW for interim treatment facility. Use of a RWB for. 10 CFR Part 61 waste fonns forland storage of LLW then can be considered on-site storage: disposal contaminated. equipment can be of- as a continuation of its original func-+

a 10CFRPart71 and49CFRParts170 fered as sarplus material for use by tion. RWB's were typically designed to 178 packaging and transportanon with features to fully support handling others requirements, a contammated metals can be melted and storage of LLW containers with If storage is to extend for lon ger than and recycled for use as shielding ma- high levels of radiation. The existing five years. a license amendm tenal.to fabncate contamers for l1W. features, such as, radiation shielding and monitoring, material handling, CFR Part 30 must be submitted before the (

or to be stored on-site as billets end of the five year period. The NRC I

• burn contammated waste oils on-site lighting, HVAC, fire detection /protec- review of the license amendment will (NRCregulationshavebeenchanged tion, and floor drains and sumps, are consider container integrity and to pemut this) generally suitable to support the stor.

a off-site volume reducconfacility used age ofLLWin accordance extended storage, with ALARA retrievability, and '

to decontammate, compact or incin- principles. LLW waste forms and packaging for erate LLW (NRC regulat ons have The use of a RWB for interim stor- intenm on-site storage should be consis-been changed to permit volume re- age of decommissioning LLW may re- tent with eurtent or draft requirements for duced LLW to be retumed to a NPP quire the licensee to perform a written disposal at the state /cornpacl I from an off-site volume reduction safety evaluation in accordance with 10 posal facility for the NPP.

facility) CFR 50.59. The evaluation is to ascer-Instead of building an interim on- tain that the plannedwaste storage in the RWB: returned to the pla treatment contractor also should be site LLW storage facility, the RWB of + is not prohibited in the existing Nuclear Plant Journal, January-February 1996 18 20

l t

i i compatible with long term storage re- sion, and radiation and effluent moni- large volume of decommissioning

) quirements. toring are normally adequate for utili- waste. If the state / compact disposal fa-j Utilization of a RWB for interim zation during the storage period. cility for a shut down NPP does not j storage of decommissioning LLW proceed on schedule,then the two NRC q should include planning in the follow. CONCLUSIONS decommissioning alternatives, 1 ing areas: An ISFSImay be necessaryifspent SAFSTOR(safe storage)andENTOMB

+

1 prepare a safety evaluation accord- fuel pool capacity is exceeded. Even if (entombment), both of wtach do not ing to 10 CFR 50.59 the capacity is not exceeded, the ben- depend on off-site disposal for LLW,

+ prepare station modifications efits of an ISFSI couldjustify the capi- may become the only decommissioning initiate a 10 CFR 30 license appli- talinvestment especially when the SNF alternatives that remain.

a cation,if storage will be for more storage duration becomes protracted.

! than five years With all fuel removed from the spent Contact 1 .

specify material handling equip- fuel pool, decommissioning planning Forderails. contact L Rutland. S.Af.

ment and implementation would benefit from Stoller Corporation. 48S Washington develop building security and pro- the resulting simpler procedures, op- Avenue. Pleasantulle. NY 10570; rele-l tection provisions erations and security, phone (914)741-1200. E j .

specify waste forms and contain- LLW generated during NPPopera-

) ers for extended storage tion while LLW disposal is unavailable Errata a

! specify fire detection / protection can be niinimized using available meth- The contact phone number in the equipment ods to reduce on-site storage require- technical paper titled Segmentation of

+

specify computer software stor- ments. Without LLW disposal, prompt the Yankee Reactor Internals by Cedric j age data tracking decommissioning (DECON alternative) L. Child, Yankee Atomic Electric

+

select a treatment system forLLW must be delayed or LLW from decon- Company,andMichaelS.McGough and i generated from storage activities tamination and dismantlement activi- Gregg Smith, PCI Energy Services, i in general, modifications would be ties must be accommodated on-site. If September-October 1995 issue, was j involved mostly with equipment re- interim on-site LLW storage space is incorrect. The correct telephone number i

moval. Existing lighting, HV AC, drains needed, the RWB may be suitable to of Michael S. McGough, PCI Energy j and sumps, fire detection and suppres- provide extended storage for even a Services, is (847) 680-8100.

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i l Circle 126 on Reeder Service Form Circle 110 on Reeder Service Form j Nuclear Plant Journal, January February 1996 19

Decommissioning and Decontamination Report UTILITY DEREGULATION BILL PROVIDES NUCLEAR UTILITIES SOME PROTECTION Sen. Bennett Johnston (D-La.), rankmg minority member by Sen. Don Nickles (R-Okla.) (S. 708); Rep. Edwsrd of the Energy and Natural Resources Committee, intro- Markey (D-Mass.) (H.R. 2929); Rep. Clifford Stearns duced Jan. 25 comprehensiw legislation proposing to (R-Fl.) (H.R. 2562); Sen. Alphonse D'Amato (R-N.Y.)

deregulate the electric power industry. Included in the bill (S.1317); and Rep. Jack Fields (R-Texas), whose bill has is a provision that will essentially require state utility not yet been assigned a number.

commissions to allow utilities with nuclear power plants to roll " standard costs" such as the expense of facility Johnston's bill is designed to encourage price competition decommissioning into their rate base. The provision is and access to the electricity market. In introducing the bill necessary, according to Johnston, because in an unregu- on the Senate floor Johnston declared that competition lated market nuclear utilities would not be able to must be met "on a level playing field," which he said can compete with other electric generators giwn such stan- only occur when utilities have the ability to recover dard costs, particularly decommissioning. The senator stranded costs, such as nuclear investments or decommis-said he wants to " level the playing field" so utilities that sioning costs.

own nuclear power plants can compete with other elec-tricity providers who are not burdened with the high costs " Nuclear decommissioning costs are an extremely large of decommissioning. percentage of many utilities' embedded costs," argued Johnston. "The law of the land should be that all nuclear Two key laws regulating the utility market now under decommissioning costs are recoverable. Moreover, no debate are the Public Utility Holding Company Act nuclear licensee should be able to amid decommissioning (PUHCA), passed in 1935 and amended under the Energy liability."

Policy Act of 1992, which grants states regulatory authority and restricts mergers and acquisitions, and the , Public Interest , Group Opposes Measure Public Utilities Regulatory Policy Act of 1978, which requires utilities to purchase electricity from independent Nancy Hirsh, of the Environmental Action Foundation, power companies at their avoided cost. said her organization does not suppon "a 100 percent stranded cost recovery" provision, which is called for Johnston Bill a Comprehensive Approach under Johnston's bill. "His approach would have rate-payers pay for everything," she said, adding that the costs Johnston's bill (S.1525) offers the most comprehensive should be split between the shareholders, consumers and package of reforms introduced in the Senate. In the ratepayers.

House Rep. Dan Schaefer (R-Colo.) is expected to introduce a proposal soon after completing a series of But Nuclear Energy Institute spokeswoman Leigh Ann public hearmgs on electricity industry restructuring. Marshall said the bill would safeguard a commonplace Various degrees of reform are included in bills offered practice. "It mMe*= that utilities can collect what they need for decommissioning in a deregulated market."

PORTLAND GENERAL SEEKS LICENSE FACILITY FOR SPENT FUEL, GTCC WASTE Portland General Electric Co. is seeking approval from ready to take the waste for permanent disposal. In their the Nuclear Regulatory Commission to store spent fuel petition for rulemaint Ponland General assens that the and greater-than-Class-C (GTCC) waste in a proposed proposal would result in savings " associated with prepara-onsite independent spent fuel storage installation (ISFSI) tion of multiple requests for handling GTCC by licensees ,

included in the decommissioning plan for the Trojan and the review of those requests by the NRC."

Nuclear Plat.t. Ponland General officials said approval of the request would clarify interim storage procedures The petition, published in the Feb.1 Federal Register, and allow spent uuclear fuel and radioactive wsste attempts to amend ISFSI issuance licensing requirements exceeding Cla.0 C radionuclide concentrations to be (10 CFR pan 72) to " explicitly provide for storage of stored in dry casks until the Department of Energy is February 16,1996 Radioactive Waste Exchange 4 E.xchange/ Monitor Publications, Inc. 11 7L

GTCC waste produced from reactor operations pending safety requirements muld not be compromised. The its transfer to a permanent disposal facility." petition emphasims the " proposed amendments would provide identical public health and safety, and environ-NRC has taken the position that GICC waste is not mental protection as required for spent fuel located in an suitable for near-surface disposal and, lacking another ISFSI."

alternative, can only be disposed ofin the HLW reposito-ry "unless the NRC authorias disposal at another Portland General believes the proposed amendments licensed site " wuld avoid duplicative NRC reviews of GTCC disposal requests and " avoid the costs associated with preparation Proposal Would StreamHne Regulation of multiple requests for handling GICC by licensees and the review of those requests by the NRC."

Michael Lackey, general manager of engineering and de-commissioning for Trojan Nuclear Plant, said the petition Comments will be accepted until April 16 and should be for rulemaking muld streamline the storage procedure submined to: Secretary, U.S. Nuclear Regulatory governed by Part 72 regulations and wuld amid main- Commission, Washington, D.C. 20055, Attention:

taining " parallel programs" for storing the spent fuel and Docketing and Service Branch. Or for further informa-GTCC waste. Lackey argues that emergency planmng and tion, call Michael Imar at 301-415-7163.

NRC SEEKS PUBLIC COMMENTS NRC is seeking public ca==nena on draft environ: zen- The NRC will hold a public hearing at Star Hall in Moab tal and technical reports on Atlas Corp.'s proposal for on Feb. 28. Written comments can be sent to: Chief, the cleanup of uranium mill tailings at Moab, Utah. High-Level Waste and Uranium Recovery Projects The preferred alternative appears to be a proposal to Branch, Division of Waste Management, Odice of Safety stabilim the tailings in place at the Moab site. NRC staff and Safeguards, U.S. Nuclear Regulatory Commission, found this acceptable. Another, more expensive, option Washington, DC 20555.4 proposed is to move all the tailings and contaminor A material to an alternate site, removing the waste from close proximity to the Colorado River.

12 Radioactive Waste Exchange

• Exchange / Monitor Publications. Inc. Februan 16.1996

f. .. .,,,

United States

(&)

'- - Nuclear Regulatory Commission l

Overview of NRC's Decommissioning Program .

and Responsibilities .

I i

i t

Division of Waste Management March 1996 i

[

i a

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OVERVIEW e Program Responsibilities e Materials ' Decommissioning Program e Site Decommissioning Management Plan e Remaining Challenges i

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PROGRAM RESPONSIBILITIES NRR

• Licensing power reactor decommissioning prior to permanent removal of fuel

• Licensing non-power reactor decommissioning NMSS f

• Licensing power reactor decommissioning after fuel removal

,

• Licensing materials and fuel facility decommissioning

• Site Decommissioning Management Plan  !

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G, f l

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! l PROGRAM RESPONSIBILITIES (Continued) i Regions e Inspection and enforcement of licensee decommissioning e Licensing materials facility decommissioning RES l l

e Rulemaking to establish and update decommissioning requirements I

l

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l STATUS REPORT l DECOMMISSIONING Subiect: Background on current NRC decommissioning related activities.

Purcose: To: 1) provide cursory background information on the latest status of decommissioning activities for both reactors and non-reactors; 2) update the status of the decommissioning rule previously reviewed (1995) by the ACRS; and 3) review proposed residual contamination levels for decommissioning and provide subcommittee with a review of comments received to date (proposed rule previously discussed with the ACNW).

Additionally, this session is intended to have the joint subcommittee (as representatives of their parent Committee) increase their familiarity with the broader l issues associated with the topic of decommissioning and thereby determine whether there is sufficient interest  ;

to further pursue the subject, either as a joint l subcommittee effort or as a topic divisible into each of the parent Committees' area of expertise - and responsibility.

Jt. Subcommittee Lead Member: Dr. B. J. Garrick Jt. Subcommittee Staff Lead: H. J. Larson NRC Staff Leads: 1) Non-Reactor Decommissioning Update Report; NRC Decommissioning Responsibilities and Organization-M. Weber, NMSS

2) Reactor Decommissioning Update Report -

S. Weiss, S.Bawja, NRR

3) Decommissioning Rule - Power Reactors-C.A. Trottier, RES

4) Residual Contamination Rule Report-J. E.

Glenn, F. Cardile, RES Action: As determined by the subcommittee. Could consist of a letter to the staff, a report back to each parent Committee with recommended action (s) or a determination that the presentation was for information only and did not require followup.

The subcommittee may:

1) be interested in determining if the agency's organization (as presented by Mr. Weber) does provide an overall, integrated plan for approaching this topic in a manner that will provide assurance to the public that its health and safety concerns are being addressed in an orderly, technically competent and consistent fashion.

Z

i I

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2) wish to comment on the EDO response to the ACRS letter on the proposed decommissioning rule.

Backaround: The subject of decommissioning is one that transcends the interests and responsibilities of both parent Committees, and yet is one that has not received significant attention by either Committee. As will be seen from the presentations, there is much activity underway at present in both the reactor and non-reactor I arenas, with various facilities in various stages of decommissioning activity.

This is an area that will continue to grow in importance as older facilities are phased out due to any one of a number of reasons-major aging problems; no longer economical to operate; uneconomical repair or replacement or maintenance of plant systems or components; public pressures; legislative actions; etc.

The Committee may also be interested in determining if there have been lessons learned from the D&D efforts to date that can be applied to future D&D undertakings, albeit regulatory, construction practice, or dose related.

The decommissioning rule status will be updated. The ACRS letter, along with the untimely (significant delay) response from the EDO are included in the referenced / attached information.

The presentation on residual contamination levels for decommissioning will be one that briefly discusses the proposed l rule and the comments received to date. Neither a proposed final resolution of comments nor a final proposed rule will be presented.

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DEFINITION Decommission means to remove (as a facility) ,

safely from service and reduce residual radioactivity to a level that permits release of the property for unrestricted use and termination of license.

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---_-_---__---------_------_____--_--_---_--------_-_----_-----n

MATERIALS DECOMMISSIONING

• NRC terminates about 300 licenses each year

• Most license terminations are routine with limited potential for re.sidual radioactivity

• Less than 10% are non-routine terminations

/ Fuel cycle facilities

/ SDMP sites

• NRC is also reviewing formerly terminated licenses i

i

DECOMMISSIONING PROCESS Cessation of Operations 4

Site Characterization Plan 4

Site Characterization I

Site Characterization Report 4

Decommissioning Plan and Environmental Report 4  ;

NRC Environmental Review Process 4

License Amendment 4

Decommissioning 4

Final and Confirmatory Survey 4

t License Termination and Site Release t

[

SITE DECOMMISSIONING MANAGEMENT PLAN e Program Management Plan ,

/ Objectives

/ Responsibilities j

/ Resources  :

o Contaminated Sites

/ Listing /Delisting Criteria i

/ Site Descriptions  ;

/ Status e Policy Issues I

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POLICY ISSUES Problem Solution Poor recordkeeping Decommissioning recordkeeping rule - 1993 i

Formerly terminated licenses review - 1991 to present Manual Chapter on Decommissioning (draft under '

review)

No schedule constraints SDMP Action Plan - 1992 License conditions and orders Decommissioning timeliness rule - 1994  ;

No residual radioactivity standards SDMP Action Plan - 1992 Enhanced Participatory Rulemaking - 1993 to present  !

(Proposed rule in August 1994; final rule in 1996)

Inadequate financial assurance General decommissioning requirements - 1988 .

License renewals and conditions Financial assurance clarification rule - 1994 ,

Orders and enforcement Inadequate procedures for Survey procedures (NUREG/CR-5849) - 1992 termination and surveys Standard Review Plan - 1993 Inspection Procedures - 1995  ;

Decommissioning Manual Chapter - in process l Multi-Agency Radiological Site Investigation Manual -

m process i

-Q

REMAINING CHALLENGES o Codifying radiological criteria for license termination - "how clean is clean" I

• Upgrading financial assurances for decommissioning

• Streamlining review process and confirmatory surveys o Completing review of formerly terminated licenses (1950s to  !

present) e Maturing and implementing the program

/ Program guidance - licensing and inspection

/ Licensee guidance - modeling, surveys, restricted use

/ Program oversight - ongoing and periodic reviews i

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OMw a

,*~s\ UNITED STATES i

NUCLEAR REGULATORY COMMISSION i wasamoron. o.c. meme

..... March 15, 1995 MEMORANDUM T0: James M. Taylor Executive Director for Operations FROM: William T. Russell, Director /A)/Y=d Office of Nuclear Reactor Regula , .

Robert M. Bernero, Director ~

Office of Nuclear Material Sa ety and Safeguards

SUBJECT:

REALIGNMENT OF REACTOR DEC009tISSIONING PROGRAM The attached " Memorandum of Understanding Between NRR and MSS" (MOU) defines the realignment of reactor decommissioning program management. This

~

paperdefinesth'e program responsibilities of NRR and MSS, both urbr urrent regulations and under the proposed regulations, and specifies distinct areas of mutual support expected from NRR and MSS. The MOU outlines the major I

actions to implement decommissioning program realignment.

Attachment:

As stated g

Contact:

Anthony W. Markley, ON00/NRR 415-1169 (f Y f

Memorandum of Understanding Between NRR and NMSS (MOU)

The Office of Nuclear Reactor Regulation (NRR) and the Office of Nuclear Material Safety and Safeguards (NMSS) have completed a review of the decommissioning program responsibilities as reflected in SECY-88-355,

" Transfer of Regulatory Responsibility for Power Reactor Decommissioning from NRR to MSS" (abbreviated title), and the challenges experienced during its implementation. This review also included evaluation of.the respective capabilities of both NRR and NMSS and the opportunities to utilize the strengths of each organization effectively and efficiently. This MOU use.9 a matrix approach to indicate the staff possessing the requisite expertise during the various phases of the decommissioning process.

Furthermore, this MOU is responsive to the requirements of the proposed rule to amend 10 CFR Parts 2, 50, and 51 related to the decommissioning of nuclear reactors. This MOU also defines the interactions, licensing program management responsibilities, and support functions for the decommissioning of nuclear reactors. This MOU supersedes in toto the assignment of responsibilities identified in SECY-oa-355.

Manaaement of the Power Reactor Decommissionina and Soent Fuel procrams ograms will be manag'ed as The power specified reactor below. Thedecommissioning overall objective isand spent to elini

~

fuel p 'nat'e dual Of'fice responsibilities for regulatory oversight. This process is designed to utilize the experience and expertise of both NMSS and NRR and indicates the specific areas of expertise and support of each office.

1. NRR will maintaineregulatory project management, oversight, and inspection support responsibilities, including the spent fuel physical protection program, for a reactor undergoing decommissioning until all spent fuel is permanently transferred from the spent fuel pool. For operating reactors, NRR will retain responsibility for the spent fuel physical protection program until the spent fuel is removed from the site.

2. For decommissioning and for operating reactors, NRR will maintain cognizance over and provide inspection oversight for spent fuel pool operations, spent fuel cask loading, and transfer and unloading activities until the fuel is safely placed in an ISFSI, or moved to available space in another Part 50 licensed spent fuel pool, or shipped directly from the spent fuel pool to an offsite storage facility.

3. For decommissioning and for operating reactors, MSS will, except for ,

the physical protection program at operating reactors, maintain cognizance over and provide inspection support for facilities related to i fuel storage in an ISFSI, for spent fuel shipment from the ISFSI to an offsite storage facility, and for any dry fuel handling facilities at the ISFSI.

/>

\ -

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4. M55 will assume regulatory project management and oversight of a reactor undergoing decommissioning, transferred from the spe:

after the spent fuel is permanent y j pool.

5. NRR will provide technical support, as requested by MSS, for structural and seismic issues associated with.both the reactor facility and the i

4 ISFSI.

l l 6. MSS will continue to maintain cognizance over the' review of ISFSI i i

5 casks, facilities, and their construction, vendors, and respective l inspections. MSS will also continue to maintain cognizance over i topical reports and generic design approvals related to dry fuel' I l

• handling facilities. MSS will keep the cognizant NRR project manager informed of any Part 72 licensing matters pertaining to the Part 50 i license and will coordinate with the NRR project manager prior to the issuance of correspondence regarding issues and inspection findings i under MSS purview. MSS wil' also coordinate onsite visits and i

inspections through the cognizant NRR project manager in accordance with

Field Policy Manual, FPN No. 12.

1

7. NRR will be the primary NRC contact for the public and the media until license project management responsibilities are transferred to NMSS.

i 8. NRR will oversee all early component removal programs.

~

i 9. NRR will assume responsibility for reviewing any cost estimates and I

financial or funding assurance plans submitted by licensees, either with the decommissioning plan or pursuant to 10 CFR 50.54(bb) regarding j financial assurance for interim storage of spent fuel.

i 10. NRR will review any decommissioning plan or report discussing planned i

j activities following plant shutdown and will prepare, as necessary, any environmental assessment, safety evaluation report, or decommissioning j j order or amendment. . <

1 11. NMSS will continue to provide technicalLinput to NRR for environmental

) radiological surveys and site characterization issues associated with j the decommissioning plan reviews and as requested by NRR.

1 l 12. NRA will maintain responsibility for evaluation of all insurance or

! indesmity issues until termination of the Part 50 license even at those i i sites where project management has been transferred to MSS.

t

13. NMSS will review the license termination plan and prepare the safety i evaluation report, the environmental assessment, and the license

termination order or amendment. MSS will be responsible for all j confirmatory survey and license termination activities, including j assurance that appropriate site release criteria are met.

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14. MS$ will maintain responsibility for reviewing any cost estimates and financial or funding assurance plans that licensees submit with the i license termination plan. l

15. NRR will provide primary support for State and local meetings to discuss  !

i decommissioning plans and Post-Shutdown Activity Reports. MSS will i i

provide support in transportation and other areas, as requested by NRR.

i NNSS will provide primary support for State and local meetings and hearings to discuss license termination plans.

! Mana-: T.t of Non-par Reactor Dec-issionina i

The realignment of responsibility does not include non-power (researchi test, l or training) reactors. The Non-Power Reactor Decommissioning Program will remain under the cognizance of NRR. '

Transition plan and Tasks i I

! The realignment of decommissioning program responsibilities would take place during the first calendar quarter of 1995. The major actions accomplished and anticipated during the transition period before publication of the new rule in

, final form are as follows:

j 1. Transfer of Reaulatory Protect Manac-- nt,.

i The transfer of regulatory project management responsibility from NMSS to NRR for the following shutdown reactors with wet spent fuel storage 3

began on December 14, 1994, and was completed during the first week of i January 1995: Humboldt Bay Unit 3 and La Crosse. The Vallecitos i

boiling water reactor, which no longer has fuel, was transferred to NRR to make more effective use of resources because there are two shutdown j and one operating non-power reactors on this site under NRR cognizance.

NMSS will maintain regulatory project management for the following shutdown reactors that do not have wet spent fuel storage: Fort St.

Vrain, Shoreham, Fermi Unit 1 Peach Botton Unit 1, and Pathfincer facilities, i

j 2. Decommissionina Plan Reviews

MSS has completed the decommissioning plan review for the Yankee Rowe plant. Decommissioning plan reviews for the Trojan, San Onofre, and Big Rock Point plants will be completed by NRR. NRR will review the decommissioning plans at the level of review envisioned for the Post-Shutdown Activities Report under the proposed rule and will prepare th.e i

environmental assessments, the safety evaluation reports, and the decommissioning orders.

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post-thutMt M. of Standard Activity ReoortsReview Plans for Dec-issionino Plans and

NRR will assume responsibility for developing appropriate guidance for the preparation and evaluation of decommissioning plans and Post-i Shutdown Activity Reports. This guidance will be consistent with the levelproposed the of reviewrule.

envisioned for the Post-Shutdown Activities Report under 4.

Develoosent of Standard Decommissienina Technical Soecifications NRR will maintain responsibility for developing appropriate standard decommissioning technical specifications for permanently shutdown reactors.

5.

Develonnent of Standard Review Plans for License Termination Plans NMSS will assume responsibility for developing appropriate guidance for preparation and evaluation of license termination plans.

Resources No resource transfers between NRR or NMSS are contemplated to implement the proposed realignment as described in this MOU. r aa i - -

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