ML20137J470

Submits List of Documents to Be Released to PDR Re DSI-9

ML20137J470
Person / Time
Issue date:	04/01/1997
From:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
To:	NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20137J085	List: ML20137J080 ML20137J094 ML20137J107 ML20137J131 ML20137J148 ML20137J163 ML20137J470
References
COMSECY-96-058, COMSECY-96-58, DSI-9, SECY-96-058-C, SECY-96-58-C, NUDOCS 9704040028
Download: ML20137J470 (13)

Text

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1 April 1, 1997 SECY NOTE: The following documents are being released to the public at this time:

1. Text of DSI 9 (Decommissioning - Non Reactor Facilities)

2. Staff Requirements Memorandum dated March 31, 1997.

3. Views of Chairman Jackson dated January 16, 1997.

4. Views of Commissioner Rogers dated January 21, 1997.

5. Views of Commissioner Dicus dated January 22, 1997. l l

6. Views of Commissioner Diaz dated January 28, 1997.

1 7. Views of Commissioner McGaffigan dated February 18, 1997.

V 3

John C. Hoyle ,

Secretary of the Commission '

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Decommissioning - Non Reactor Facilities

, Sununary Analysis of Comments a . . . . . $. ,, , j 3.6 DECOMMISSIONING - NON REACTOR FACILITIES (DSI $% y

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a m 3.6.1 The Direction Setting issue and the Options casg-og j !

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What should be NRC's strategy to take advantage of new and different .o . I approaches to optimize site remediation of the Site Decommissioning Manager $nt- l Plan and other problem sites? .Q .

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Option 1: Continue Existing Program .g k l

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Option 2: Change the Decommissioning Review Process $g .

l Option 3: Change Residual Contamination Criteria and Review Scenarios .......e. 1 Option 4: Adopt the U.S. Environmental Protection Agency Superfund Approach l Option 5: Regulate Source Material Consistently With Naturally Occurring and Accelerator-Produced Radioactive Materials Option 6: Focus on Decommissioning Cases in Which Progress Can Be Made; J Transfer Stalled Sites to the Environmental Protection Agency's Superfund Program Option 7: Take an Aggressive Position to Develop Relatory Frameworks for Lower Cost Decommissioning Waste Disposal Options Option 8: Develop a Streng Litigation Strategy l

Option 9: Seek Superfunc Authority 3.6.2 Commission's Preliminary Views The Commission's initial preference on this DSI is a combination of options, subject to the modifications specified below, including Option 2 (Change the Decomissioning Review Process), Option 6 (Focus on Decommissioning Cases in which progress can be made; Transfer Stalled Sites to EPA), Option 7 (Take an Aggressive Position to Develop Regulatory frameworks for Lower Cost Decommissioning Waste Disposal Options), and Option 8 (Develop a Strong Litigation Strategy). In combination, these options would place appropriate responsibility on licensees to remediate their sites while giving NRC appropriate tools to deal with problem sites and licensees.

With regard to Option 2, the Commission believes that the option should be tested on a pilot scale for a few selected materials licensees to determine the potential success and effectiveness of this option if it were to be adopted on a broader scale. The pilot program participants should be volunteers that are found to be suitable for participation in the pilot program by the NRC. Based on the results of the results of the pilot program, the NRC cbald consider, at a later date, whether this option should be more adopted on a broader basis, i

Full implementation of Option 2 could significarily affect the way NRC licensees carry out their responsibilities for decommissioning and remediating sites. Some licensees might be in a poor position to hire and effectively use the contractors they would need to carry out these responsibilities.

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Decommissioning - Non Reaaor Facilities Summary Ana!ysis of Commerus 1

Accordingly, the NRC specifically seeks comment on whether NRC should hold a

seminars or workshops for licensees to make sure that they understand what NRC expects of them and what they, in turn, thould expect of their contractors. i Such training could help to assure that limited cleanup resources would be l effectively applied.

With regard to Option 6, the Comission i>elieves that rather than focusing only on the progress being made on the site review, the staff should also, consistent with DSI 12, examine the level of risk associated with each site. l The NRC could focus on both progress and risk in making determinations on the disposition of sites. The NRC could focus on the higher risk sites where progress is being made and place lesser emphasis on the lower risk sites.

Staff should consider the feasibility of transferring the low risk, stalled sites to the EPA's Superfund Program. Determinations on whether to send to EPA's Superfund Program a stalled, high-risk site or a low-risk sii.e where progress is being made should be made on a case-by-case basis.

The implementation process for Option 6 M M not preclude the Commission from reviewing a low risk, stalled sits f conditions warrant, nor should the process automatically send the cite to EPA's Superfund Program.

3.6.3 Summary of Comments A. Significant/laiportant Comments Directly Affecting the Preliminary Views or the Direction-Setting Issue in the written comments and the oral comments made at the stakeholder meetings, there was general agreement with most of the Commission's preliminary views.

Commenters (Organization of Agreement States (0AS), Conference of Radiation Control Program Directors (CRCPD), State of Illinois) indicated support for Options 2, 6, and 7. One commenter (0AS) indicated that some support for Option 8 exists, althouah some States questioned a need for further litigation. Commenters (0AS) generally stated that the current program was slow to resc've site decommis:,ioning issues and tlist adequate flexibility is needed in both policy and regulations to allow unique approaches in decommissioning and decommissioning funding. Other commenters (States of Georgia, Louisiana, Mississippi, New Hampshire, Utah, South Carolina) endorsed the OAS coments. One commenter (State of New Jersey) said that taking a little from each of four options does not produce a strategic plan for addressing decommissioning issues.

Option 2 Several commenters (State of Tennessee, Siemens, Doruff, Nuclear Energy I Institute (NEI), South Carolina Electric and Gas Company (SCE&G),

Mallinckrodt, ABB-CE, Council on Radionuclides and Radiophannaceuticals (CORAR), Westinghouse) supported the performance-based decommissioning l approach in Option 2 to allow licensees to proceed directly to I decommissioning. A commenter (ABB-CE) stated that the issue paper underestimates the benefit of removing the decommi::i: ming plan review from the process, and the proposed pilot project G ould be as broad as possible and be expeditiously conducted. One comm u er (Morton) supported the use of Option 2 for those licensees that a.e technically capable of undertaking Page M 8 Phase 11 Stakeholder Interaaion Report

Decommissioning - Non Reactor Facilities

, , Summary Analysis of Comments I

decomissioning. As a modification to Option 2, another commenter (Holmes) suggested an approach similar to the one used for reactor decommissioning. In l this approach, the licensee would submit a short description of the planned remediation options without a formal review by NRC, partial remediation could take place, and resolution of final radiation level issues would be addressed at a later date. An anonymous commenter wrote that extensive review of decomissioning plans is not needed and substantial industry and NRC resources l would be saved.

Several comenters (Erickson, States of Illinois, Michigan, Washington) I indicated that Option 2, if implemented, should be limited to those licensees  !

with demonstrable expertise and adequate funding. Commenters (CRCPD, States of Georgia, Louisiana, Texas) said that this option should apply only to sites that are minimally contaminated. These commenters considered that, for '

complex sites, improperly characterized sites could result in additional  !

expense to licensees and additional resources required from regulatory agencies One commenter (Thompson) stated that NRC needs to stay involved in site l characterization or questions could be raised at the time of final survey which could lead to site decommissioning or license termination being reopened. Another commenter (National Mining Association [NMA]) found it highly unlikely that licensees would proceed with decommissioning, and accept the risk of enormous resource expenditures, without NRC approvals. Ancther commenter (Weber) did not support this option for non-routine decommissioning actions because he felt that licensees will seek commitments from NRC in advance of investing limited resources to undertake decommissioning. This would be especially important for unlicensed responsible parties that are unfamiliar with NRC regulatory programs and radiation protection. A commenter (State of Michigan) did not support Option 2 because it considered that there will be extensive and costly repeat remediations if decommissioning plans are not approved in advance. Another commenter (State of Maryland) indicated that major licensees should be required to submit decommissioning plans, but the SDMP and SDMP Action Plan are too prescriptive and should be performance oriented. Another commenter (Environmental Coalition on Nuclear Power [ECNP])

strongly opposed this option.

Option 6 Several comenters (CRCPD, States of Georgia, Louisiana, Texas, Gregon, Washington) supported this option to defer difficult decommissioning cases to EPA. Comenters (CRCPD, States of Georgia, Louisiana, Texas) suggested that this option should also be available to Agreement States. One comenter (Erickson) stated that entities would move rapidly to remediate sites rather than to have jurisdiction transferred to EPA. Another comenter (Siemens) said it would support this option if a reasonable set of conditions is in place to set a threshold for transfers to EPA.

One commenter (State of Michigan) did not support this option, but suggested that by implementing Option 3 there would be less need for transferring sites to EPA. Another commenter (State of Colorauo) said that if sites are transferred to EPA, not all would meet the threshold for listing on the National Priorities List. This commenter (State of Colorado) indicated that some risk assessment would be needed and that implicit in this option is the need to establish a "below regulatory concern" level. The same commenter (State of Colorado) indicated that the State had worked cooperatively with EPA Page 3-59 Phase !! Stakeholder interaction Repe,

! Swnmary Ane& sis ofTcomments Decommissioning - Non Reactor Facilities I

in several remediation cases invobing hazar dous entes er thout completely ~

deferring regulatory jurisdittion to EPA Another rumenter (tiMA) did not support Option 6 unless there are no funds for decommissioning, but preferred resolving lack of funding enes by abtain-ing J:rert yptordat ions from Congress. This commenter also considered that 'trar< fu of sites to EPA's Two Superfund Program would be unlikely to achiese tF.c .ntended results.

' commenters (NEI, SCE&G) did not support this option and suggested that NRC strive to resolve cases rather than to pass them off to another agency.

Another comenter (ABB-CE) suggested that EPA needs to revamp the Superfund A commenter (State of Maryland) also Program before adding more sites.

disagreed with this option because it may add years to the effective remediation of sites. One commenter (Weber) stated that the viability of this option is unclear at this time. Weber also indicated that most contaminated sites would not score high enough under the EPA Hazard Ranking System to  !

qualify for the National Priorities List and that transfer to EPA could increase public and environmental risk as a result of limited EPA resources and low EPA priorities. Another commenter (ECNP) strongly opposed this option.

Option 7 Several commenters (NEI, NMA, SCE&G, Wyoming Mining Association, Siemens, l

States of Michigan, Oregon, and Washington) supported this option to establish '

a regulatory framework for lower cost disposal options. Several commenters (CRCPD, Weber, States of Georgia, Louisiana, Texas) supported this option and One commenter representing NEI (Morton) noted that it is already available.

supported the use of mill tailings disposal sites for soil contaminated with i

uranium and thorium. Another commenter (State of Colorado) suggested 1 exempting licensed natural uranium (although not enriched uranium or depleted l uranium) from 10 CFR Part 61 so that these wastes could be disposed of at mill I tailings facilities. The ECNP strongly opposed this option.

Option 8 Several commenters (CRCPD, States of Georgia, Louisiana, Texas) supported this option for developing a stronger l'tigathn strategy', indicating it would force licensees to decommission sites before money can be funnelled out of corporations. The ECNP also supported this option. Another commenter (State of Michigan) cunported this option, but considered that through aggressive implementation of Options 3 and 7, there would be a diminished need for stronger litigation tools.

Two commenters (States of Oregon, Washington) did not support this option.

Washington said that there is already too much litigation and NRCOne should commenter emphasize reasonable options for licensees to act responsibly.

(Thompson) stated that stronger litigation strategies should not include changes that restrict the licensee's prerogative to propose different remediation methods where there is no imminent hazard. A commenter (NMA) indicated it would object to changing the basic NRC " audit" approach, which  !

relies on the licensee to have the primary responsibility for public health and safety. This commenter (NMA) did indicate it would support changes  ;

addressing concerns about licensee bankruptcies and nonperformance issues. i Siemens and NEI considered that NRC has sufficient authority to compel )

licensees to properly decommission sites. One commenter (Weber) stated that once the radiological criteria for decommissioning rulemaking is completed, 1

Phase 11 Stakeholder interaction Report l

Decommissioning - Non Reanor Facilities

, .summaWAnalysis of comments the regulatory framework should be in place to allow aggressive enforcement of the regulations to compel decommissioning. He added it is not clear that additional rules are required to provide strong enforcement.

B. Coments on Other Options Option 1 i There was general agreement that the current approach, proposed in Option 1,  ;

i was ineffective and time consuming. Several comenters (CRCPD, States of ,

Georgia, Louisiana, Texas) said that the current program is not working for all sites, but progress is being made at some sites. Another commenter i

(Siemens) indicated that the current program is acceptable, but a program that allows flexibility is preferable. A commenter (NEI) suggested that the current program be maintained, except that uranium- and thorium-contaminated '

sites should be addressed generically rather than on a case-by-case basis.

Another commenter (NMA) indicated that continuing the current program is a ,

viable option because it addresses issues in a meaningful site-specific basis.

This commenter (NMA) was, however, concerned that decommissioning actions might not be final actions in the event a General Accounting Office report or EPA initiative would reopen decomissioning decisi]ns. One commenter (Weber) stated that many of the options presented in the issue paper have al W y been considered or are already in use and can be seen as an affirmation of the j current program.

Option 3 l A commenter (State of Michigan) supported Option 3 to change the current decommissioning criteria and modeling scenarios, indicating that risk-based doses need to be practical and protective and that changes will result in less 4 costly remediations and lower waste volumes. That commenter also indicated that this option is more consistent with international and national radiation protection recommendations. Another commenter (State of New Jersey) also supported this option, particularly with the emphasis on " brownfield" or restricted development, land use plannin;, and having the option to use deed restrictions to make contaminated sites economically desirable. A commenter (ABB-CE) also suggested that a " brownfield" option be considered. Several commenters (Westinghouse, Siemens, NEI, SCE&G, Mallinckrodt, CORAR, ABB-CE, Doruff, States of Washington, Colorado) also supported Option 3.

Several commenters'(State of Maryland, Mallinckrodt, Siemens, ABB-CE, CORAR) noted that a 15-mrem /yr dose objective is arbitrary and needlessly conservative, and referred to a recent EPA report which suggested that a baseline value less than 75 mrem would produce large waste volumes and avert  ;

few cancer deaths. Another comenter (State of Tennessee) said that NRC needs l to define what is " clean" and establish precise limits below which regulation is not warranted. A commenter (Morton) stated that he is in favor of performance-based regulations as long as they are capable of being implemented. He indicated that residual contamination standards need to consider the efficacy of demonstrating compliance at levels that are within l

the' range of natural background. He and another commenter (NMA) suggested basing residual contamination criteria levels at 500 mrem /yr and allowing more realistic dose assessment scenarios. A cmnenter (Illinois) suggested using the 100 mrem /yr standard in 10 CFR Part 20 and the 25 mrem /yr standard in 10 CFR Part 40, Appendix A as being reasonable and protective. Three commenters (CRCPD, States of Georgia, Texas) indicated that there may be disagreement on Page 3-61 Phase !! Stakeholder interaalon Report

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the values used for residual contamination criteria, but that this approach should be implemented with different criteria f,r intruder and non-intruder scenarios. They also suggested sett ing reudual contani t rtion criteria using non-binding regulatory standds thet could N rocifi w on a case-by-case basis considering occupancy factor and deeJ mt rictin'a An NRC employee (Barkley) stated that NRC neet to deve!op re s ide t en tantination criteria that strike a balance between public health artf safet) st"1 cost effectiveness.

Other commenters (Doruff, Mallinckrodt, CORAR) suggesNd that NRC should focus on progress and risk in making decommissi m ing decis e s. A commenter (ECNP) strongly opposed this option and favoring a zero tolerance level above background as a decommissioning goal with no consideration of costs.

One commenter (Weber) suggested that, in light of the proposed radiological criteria for the decommissioning rule, which would authorize institutional control alternatives, there seems to be no technical justification for placing a cap on total dose as proposed in the option. He also did not support the use of less conservative dose scenarios because the existing approach is consistent with the policy of EPA and other agencies and is intended to be protective of existing and future populations and avoid debates about the probability of intrusion.

Several commenters (Mallinckrodt, CORAR, ABB-CE) supported the NRC position that an overall dose objective for radiological criteria for decommissioning prcvides sufficient protection without a separate standard for the groundwater pathway. A commenter (ECNP) supports the EPA position for having a separate, 4 mrem /yr groundwater standard.

Option 4 One commenter (State of Washington) said that EPA and NRC disposal requirements are not as far apart as stated in the issue paper, and supported adopting an EPA-like approach allowing greater residual contamination, but requiring active maintenance and monitoring. Several commenters (Siemens, NEI, SCE&G, Mallinckrodt, CORAR, Doruff) considered that the EPA approach would allow licensees more flexibility and result in lower costs. One commenter (Morton) suggested that NRC improve compatibility between government regulaticns and try to reconcile differences with EPA to accept more achievable decommissioning criteria.

A commenter (State of Michigan) did not support Option 4 because it does not ensure adequate consideration of long-term hazards and is inconsistent with international standards on radiation protection. One commenter (Mitchell) indicated that in the Superfund process, remediation technologies are often driven by the need to develop strong litigation positions rather than just to remediate a site. She suggested that appropriate cost-benefit analyses need to be performed so the right technologies are chosen for the right reasons.

Several commenters (CRCPD, States of Georgia, Louisiana, Texas) indicated that this option should be considered, probably on a low-priority basis, but that it would be extremely difficult to implement. One commenter (NMA) stated it would be inappropriate to adopt EPA's approach because the EPA criteria are inconsistent with current uranium recovery and low-level waste disposal standards. Another commenter (State of Illinois) also did not support this option. One commenter (State of Colorado) suggested that the NRC compile a document of institutional control options related to uranium mill tailings disposal, low-level wastes, high-level wastu, and decommissioning. A commenter (ECNP) strongly opposed this option.

Phase H Stakeholder Interaaion Report Page 3-62

Deconunissioning - Non Reactor Facilities

, , Swnmary Analysis of Comments Option 5 There was little support for this option to transfer jurisdiction of source material to EPA where it would be regulated similarly to naturally occurring or accelerator-produced radioactive raterials (NARM). Because this option  !

would increase the expenditure of State resources, several commenters (CRCPD, States of Louisiana, Georgia, Texas, Washington, Michigan) did not support this option . Another commenter (ABB-CE) also did not support this option because EPA has not yet set criteria for decomissioning. One commenter (NMA) strongly opposed the transfer of source material jurisdiction to EPA. Several commenters (Siemens, NEI, SCE&G, CORAR, Mallinckrodt, States of Tennessee, Michigan, Washington) recommended that Federal oversight of NARM be given to the NRC. One commenter (NMA) recommanded that authority for regulating discrete nARM be given to NRC. Another commenter (State of Colorado) indicated that, contrary to the discussion in the issue paper, there would be significant impact on Agreement State resources for this option if all sites  !

l contaminated with NARM require remediation since many have never been licensed. This commenter suggested that uranium NARM wastes containing uranium should also be allowed to be disposed at uranium mill tailings facilities. Another commenter (ABB-CE) suggested that low-enriched uranium l should be included with NARM because it presents a low environmental hazard.  !

One commenter (Morton) suggested that NRC improve compatibility between j

(

government regulations and try to reconcile differences with EPA to accept more achievable decommissioning criteria. l One commenter (Weber) indicated that regulating source material consistently with NARM raised a new direction-setting issue of how NARM should be regul ated. He said NARM regulation has broad and fundamental implications to the U.S. that encompass more than decommissioning.

Option 9 One commenter (State of Tennessee) provided comments on Option 9 to seek Superfund authority for the NRC and stated that the NRC decommissioning program relies on the viability of the licensee. The representative from Tennessee also suggested that NRC shot d seek authority to obtain funds from other parties. One comenter (ECNP) s pporh tTis option. Other comenters (States of Texas, Washington) indicatej such authority is unnecessary if problem sites can be transferred to EPA. One commenter (State of Michigan) does not support this option at this time, unless other options fail to achieve expected results. Several commenters (CRCPD, States of Georgia, Louisiana, Texas) said that this option appeared to be unnecessary and duplicative, especially if NRC can transfer problem sites to EPA. Other commenter (NMA, SCE&G) indicated that Congress is unlikely to give NRC Superfund authority, and suggested it would be better if authority was given to NRC to request appropriated funds for problem decommissioning cases.

Another commenter (NEI) stated that there is no value in NRC having Superfund authority because decommissioning of Superfund sites has resulted in additional delays and increased costs. Two other commenters (Siemens, Doruff) did not support this option. An NRC employee (Barkley) stated that, rather than use Superfund authority, NRC needs to ensure that licensees have adequate funding for decommissioning.

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Decommissioning - Non Reaaor Fatilitie.s S"""#9 M 'U N""""* l l

j Relevant Reactor Decommissioning Comments Several coments on the Reartor Deconodss uming issut r. ape , DSI 24, are also applicable to the mater.ials area.. Two commenters (Ctimes, Holmes) questioned the basis for the proposed B-mrem /yr reMual cont ait'inamn criteria.  :

Several commenters (Barkley, W;1mes.,1ollis) stated thM there is an l l

important need to establish residual contamination criteria that are practical to implement and that are tonsistent throughout the Agreement States. Two commenters (Collins, OAS) suggested that residual contamination criteria and review scenarios should be developed independent of EPA.

l I

Comenters (Holmes, Tipton, Floyd) also indicated that it is essential to make l completed decomissioning actions final actions so that licensees are not forced to remediate sites to future, more restrictive criteria. One comenter (State of Oregon) agreed with NRC's proposed new approaches to focus less attention nn the decomissioning process and more on the end result.

C. Coments on Important Omissions One commenter (0AS) indicated that the issue paper was deficient in that it did not adequately address NARM. This commenter also stated that the issue i paper should address tailings containing radioactive materials from those mills that process materials other that uranium. The commenter also indicated that resources needed for decomissioning NARM sites can be significant.

One commenter (Moeller) suggested applying the "open market trading rule" to l

decommissioning nuclear facilities. EPA allows the application of the "open f market trading rule" in certain applications involving discharges of hazardous pollutants. In this concept, all sources of radiation exposure would be identified and an assessment would be performed to reduce the exposures from sources most readily controlled, e.g., indoor radon and medical exposures. In l this manner, expensive site remediations could be eliminated by reducing l 1

exposures to other sources of radioactivity.

Several commenters (CRCPD, States of Georgia, Louisiana, Texas) indicated that ,

I the issue paoer focused primarily on source material licenses, but the same concerns apply to other major licensees such as broad-scope licensees, .

research and development facilities, and waste processors. These comenters l also said that States were only mentioned with respect to coordination of NRC decomissioning activities. They noted, herever, that the policies and processes adopted by NRC will also affect State radiation contrci programs.

Several comenters (CRCPD, State: of Texas, Georgia, Louisiana, New Jersey) '

noted that recycle of materials was not addressed in the issue paper.

One comenter (ABB-CE) indicated that risk ranking needs to be taken into consideration in decision-making and must contain all risk elements (i.e., i I

transportation, chemical, biological, and radiological hazards). This commenter suggested that the use of hazardous waste landfills for decomissioning waste should be considered. This comenter also recomended that industry be afforded an early opportunity to participate the formulation of proposed rules. The commenter stated that better government coordination needs to be addressed, including addressing overlapping jurisdiction in the mixed-waste area. Another commenter (NMA) stated that the NRC needs to take an aggressive posture to resolve mixed waste issues.

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Deconunissioning - Non Reaaor Facilities

, , knunary Analysis of Comments i

One comenter (Weber) indicated that the scope of the issue paper focused on l the Site Decommissioning Management Plan (SDMP) and " problem sites" and that by focusing on non-routine deccmmissioning cases, NRC may have missed an  !

opportunity to enhance the broad decommissioning program, which includes routine casework. He indicated that because routine decommissioning casework could be expected to grow in the future, the scope of DSI-9 should be expanded  !

and additional analysis should be performed to include routine decommissioning

. actions.

5 One commenter (Wyoming Mining Association) suggested that changes are needed to portions of 10 CFR Part 40 that are applicable to uranium recovery operations and to uranium recovery technical guidance documents.

D. Coments on Internal / External Factors One comenter (Doruff) stated that the issue paper did a good job in the assumptions and projections for internal and external factors. Several comenters (NEI, SCE&G, CORAR, Mallinckrodt) also indicated that the internal and external factors appear to be accurate. Two commenters (NEI,SCE&G) stated that the assumption that EPA's Superfund would be effective in decommissioning sites is not supported by the record. Another commenter (ABB-CE) stated that the Department of Defense should be added as an important external factor.

E. Comments on Staff Requirements Memorandum Questions i

In its preliminary view, the Commission requested specific comments on one issue. This issue and the comments provided are listed below.

NRC should hold seminars or workshops for licensees to make sure that l they understand what NRC expects of them and what they, in turn, should l l

j expect of their contractors.

One comenter (Doruff) indicated that workshops and seminars would be

! uset ul . Another comenter (State of Colorado) suggested that it may not be effective to hold seminars about decomissioning, unless a significant number of site owners attended and the sites were

! decommissioned before the ground rules are changed.

3.6.4 List of Commenters ,

WRITTEN COMMENTS

1. October 18, 1996, Dade Moeller & Associates (Dade Moeller)

2. October 21, 1996, Organization of Agreement States (Robert Quillin)

3. October 28, 1996, State of Washington, Department of Health (Terry Frazee)

4. October 28, 1996, Richard S. Barkley, U.S. NRC

5. November 3, 1996, Marvin I. Lewis

6. November 4,1996, State of New Hampshire, Department of Health and Human Services (Diana E. Tefft)

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Decommissioning - Non Reanor Facilities Summary Analysis of Comments.

7. November 4,1996, Organization of Agreement States (Robert M. Quillin) -

8. November 5,1996, State of Michigan, Department of Environmental Quality (Flint C. Watt)

9. November 7,1996, State of Mississippi, Division of Radiological Health (Robe t W. Goff)

10. November 8,1996, State of Tennessee, Department of Environment and Conservation (Michael H. Mobley)

11. November 13, 1996, State of Oregon, Office of Energy (David Stewart-Smith)

12. November 14, 1996, State of Oregon, Department of Human Resources (Ray D. Paris)

13. November 14, 1996, State of South Carolina, Department of Health and Environmental Control (M.K. Batavia)

14. November 21, 1996, State of Louisiana, Department of Environmental Quality (Ronald Wascom)

15. November 21, 1996, State of Georgia, Department of Natural Resources (Thomas E. Hill)

16. November 21, 1996, State of Utah, Department of Environmental Quality (William J. Sinclair)

17. November 22, 1996, South Carolina Electric and Gas Company (Gary J.

Taylor)

18. November 22, 1996, Siemens (L.J. Maas)

19. November 25, 1996, Westinghouse Electric Company (N.J. Liparulo)

20. November 27, 1996, Nuclear Energy Institute (Thomas D. Ryan)

21. November 27, 1996, State of Texas, Department of Health (Richard A.

Ratliff)

22. November 27, 1996, Conference of Radiation Control Program Directors, Inc. (William P. Dornsife)

23. November 27, 1996, Council on Radionuclides and Radiophannaceuticals (Roy W. Brown)

24. December 1,1996, Environmental Coalition on Nuclear Power (Judith H.

Johnsrud)

25. December 2, 1996, Michael Weber, U.S. NRC

26. December 2, 1996, Wyoming Mining Association (Marion Loomis)

27. December 2, 1996, State of New Jersey (Jill Lipoti) l Page 3-66 Phee 11 Stakeholder interaaion Repon  ;

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Decommissioning - Non Reaaor Facilities

28. December 2,1996, State of Maryland, Department of the Environment

, (Roland G. Fletcher) 4

29. December 2,1996, Mallinckrodt (Ashok Dhar)

30. December 2,1996, ABB Combusuon Engineering Nuclear Systems (Charles B.

Brinkman)

31. December 2,1996, National Mining Association (Richard L. Lawson)

! 32. Deember 2, 1996, State of Illinois, Department of Nuclear Safety (Thomas W. Ortciger) i 33. December 3, 1996, No Name

34. December 5, 1996, Morton Associates (Henry W. Morton) i ORAL COMMENTS l Washington, D.C. (October 24 - 25, 1996) pages 98 - 112

1. Steve Collins, Oas I 4

l 2. Tom Hill, CRCPD i

3. Henry Morton, Technical Consultant i 4. Tony Thompson, Shaw, Pittman representing National Mining Association l 1

5. Lynnette Hendricks, NEI (Misidentified as Lynn Fairobent)

! Colorado Springs, CO (October 31 - November 1,1996) pages 323 - 332) i l 1. Mike Holmes, Public Service Compan) of Colorado l

5 2. Tom Tipton, NEI ,

l 3. Steve Floyd, NEI

4. Ken Weaver, State of Colorado

! 5. Martha Mitchell, Roy F. Weston a

Chicago, IL (November 7 - 8, 1996) pages 189 - 206

1. Kristen Erickson, Michigan State University i Mark Doruff, Amersham 2.

I 3. Thor Strong, Michigan LLRW Authority

4. Gordon Appel, State of Illinois

! 5. Steve Collins, State of Illinois 1

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