Text

Transmits State Program Info (SP-97-035) Re Commission Approval of Final Rule Establishing New Radiological Criteria for Decommissioning of Lands & Structures at NRC-regulated Facilities
	ML20140B317
Person / Time
Issue date:	05/21/1997
From:	Bangart R; NRC OFFICE OF STATE PROGRAMS (OSP)
To:	; GENERAL
References
	SP-97-035, SP-97-35, NUDOCS 9706060168
	Download: ML20140B317 (16)
	v • d • e

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e MAY 2 1 1997 ]

' ALL AGREEMENT STATES AND NON-AGREEMENT STATES 1 STATE LIAISON OFFICERS l

TRANSMITTAL OF STATE PROGRAM INFORMATION (SP-97-035)

Your attention is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION......... l i

PROGRAM MANAGEMENT INFORMATION... XX FINAL DECOMMISSIONING RULE TRAINING COURSE INFORMATION............. l TECHNICAL IN FORM ATION........................

OT H E R I N FO R M ATI O N . . . . ... . . . . . . . . . . ... . . . . . . . . . . . i Supplementary information: I have attached a Staff Requirements Memorandum dated l May 21,1997, and a Press Release relating to the Commission's approval of a final rule ;

establishing new radiological criteria for decommissioning of lands and structures at NRC-regulated facilities.

We will provide you a copy of the final rule in early June when it is scheduled for publication in the Federal Reaister, if you have any questions regarding this correspondence, please contact me or the individual named below. {

POINT OF CONTACT: Tom O'Brien $

TEl.EPHONE: (301) 415-2308 FAX: (301) 415-3502 INTERNET: TJO@NRC. GOV DD%

RICHARD L BANGART Richard L. Bangart, Director Office of State Programs ;

' As stated Distribution:

DIR RF DCD (SP 03)

SDroggitis ;PDR.(YES1 NO_)

k TO'Brien AS File FAXED TO A/S AND NON-A/S: 5/21/97 DOCUMENT NAME: $P97035.PHL Ta receive a copy of this h indicate in the box: "C" = Copyhthout attachment / enclosure 'E" = Copy with attachment / enclosure 'N' = No copy i OFFICE O@Q OSP:DM "

l l NAME PHLohabsind RBangart !

DATE 05/Li/97 O!y1/ /97 i OSP lLE CODE: SP.-A-pj 053038 - .-

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9706060168 970521 '

PDR STPRG ESGGEN '

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ativ p* 4 UNITED STATES g ,{ NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20565 4001

,,,,,/' May 21, 1997 l

ALL AGREEMENT STATES AND NON-AGREEMENT STATES STATE LIAISON OFFICERS TRANSMITTAL OF STATE PROGRAM INFORMATION (SP-97-035)

Your attent:on is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION.........

PROGRAM MANAGEMENT INFORMATION... XX FINAL DECOMMISSIONING l RULE.

TRAINING COURSE INFORMATION.............

TECHNICAL INFORMATION........................

OTH E R I N FO R M ATIO N. . . . . .. . . . . . .. .. . . .. . . . . .. . . . ..

i Supplementary information: 11 ee attached a Staff Requirements Memorandum dated i May 21,1997, and a Press Re!n relating to'the Commission's approval of a final rule !

establishing new radiological critena for decommissioning of lands and structures at NRC-regulated facilities.

We will provide you a copy of the final rule in early June when it is scheduled for publication in the Federal Reaister.

If you have any questions regarding this correspondence,~please contact me or the ;

individual named below, i POINT OF CONTACT: Tom O'Brien TELEPHONE: (301) 415-2308 FAX: (301) 415-3502 !

INTERNET: TJO@NRC. GOV

'fjudad [ u } \

Richard L. Bangart, Direct r Office of State Programs /

Enclosures:

As stated

May 21, 1997 IN RESPONSE: PLEASE REFER TO: M970521 MEMORANDUM TO: L. Joseph Callan Executive Director for Operations FROM: John C. Hoyle /s/

SUBJECT:

STAFF REQUIREMENTS - AFFIRMATION SESSION, 9:30 A.M. WEDNESDAY, MAY 21, 1997, COMMISSIONERS CONFERENCE ROOM, ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND (OPEN TO PUBLIC ATTENDANCE) l I. SECY 97-046A - FINAL RULE ON RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION The Commission

approved a final rule which would revise 10 CFR Part 20 to provide specific radiological criteria for the decommissioning of lands and structures at NRC-regulated l facilities and to establish a clear and consistent regulatory l basis for determining the extent to which lands and structures must be remediated before decommissioning of a site can be l considered complete and the license terminated. In reaching its

decision to approve the final rule, the Commission addressed the I following specific issues

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Dose Criteria for Release of a Site to Unrestricted Use

( The Commission adopted a 25 mrem / year all-pathways dose l limit coupled with a requirement to reduce radiological l l doses resulting from residual radioactivity to levels l l that are as low as reasonably achievable. The Commission believes that these criteria are consistent with the recommendations of national and international bodies tasked with t he development of guidance for (

radiation protectica; are appropriately based on risk, cost-benefit, and socio-economic standards; provide the ;

needed flexibility to accommodate site-specific l conditio 3; and are sufficiently conservative to ensure l l

Section 201 of the Energy Reorganization Act, 42 U.S.C.

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Section 5841, provides that action of the Commission shall be determined by a " majority vote of the members present." Commissioner Diaz was not present when this item was affirmed. Accordingly, the formal vote of the Commission was 4-0 in favor of the decision.

Commissioner Diaz, however, had previously indicated that he would approve this paper, and had he been present, he would have affirmed his prior vote.

adequate protection of public health and safety and the environment.

Separate Groundwater Protection Standard The Commission did not adopt a separate groundwater protection standard as proposed by the Environmental Protection Agency (EPA) because the Commission believes that a separate single pathway standard for groundwater would not provide any significant enhancement of public health and safety and is unnecessary since the NRC final rule's all-pathways standard of 25 mrem / year plus ALARA should ensure adequate protection of public health and safety. Imposition of separate groundwater standards could also have the adverse effect of delaying cleanup I and increasing public risk. Moreover, the Commission was not convinced that EPA's separate groundwater l maximum contaminant levels were appropriately derived or soundly based from a technical standpoint.

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Alternate Criteria The Commission adopted the NRC staff's recommendation to l use alternate criteria for license termination for l certain difficult sites since codifying such an approach ,

in the text of the rule is expected to greatly reduce the likelihood that licensees will seek exemptions from the requirements of the regulation. Nevertheless, the Commission also approved a revision to section 20.1404 in the text of the final rule to require the NRC staff to obtain Commission approval for each application of the alternative criteria, to solicit comment from EPA during the public comment period required under section 20.1405 of the final rule, and to ensure a more substantive level of public participation. The i

Commission expects the use of such criteria to be relatively rare. (Specific, Commission-approved changes to section 20.1404 are contained in the attachment to this SRM).

Public Participation The Commission, in the absence of a provision that requires a Site Specific Advisory Board, which had been included in the proposed rule but not in the final rule, agreed to modify the final rule to require licensees proposing to decommission by restricting use of a site, or through the use of alternate criteria, to provide for participation by a broad cross section of community interests, an opportunity for a comprehensive discussion on the issues by participants, and to make public a summary of the results of such discussions. (Specific, Commission-approved changes to section 20.14 03 (d) of the final rule are contained in the attachment to this SRM).

Agreement State Compatibility Level The Commission adopted Compatibility Level 2, as proposed by the NRC staff. This will afford the Agreement States flexibility to account for local needs and conditions.

The staff is directed to incorporate the attached specific changes to the final rule and forward the Federal Reaister notice to the Office of the Secretary for signature and publication.

(EDO) (SECY Suspense: 6/03/97)

Attachment:

As stated cc: Chairman Jackson Commissioner Rogers Commissioner Dicus I

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- ,. s Commissioner Diaz Commissioner McGaffigan ;

OGC OCA OPA l

OIG Office Directors, Regions, ACRS,ACNW,ASLBP (via E-Mail)

PDR - Advance DCS-P1-17 f

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I SPECIFIC COMMENTS ON FINAL RULE ON RADIOLOGICAL CRITERIA

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. I FOR-LICENSE TERMINATION (SECY 97-046A) i

1. The rule is being completed on an expedited basis, and j as a result, guidance documents are not available for l

-Commission review. Since the guidance documents can have a significant-impact on-how this. rule is implemented,.the staff j should provide.all guidance documents to the Commission for -

review and approval prior to publication no later than February 21, 1928. l

2. The Statement o'f Considerations (p. 41) and the text of the -;

rule (p. 122) are in :onsistent in describing and defining the i term " Critical Grouph. The staff should resolve the <

L ; inconsistency and mak e appropriate changes to the final rule !

package prior to publication. :

3. The following changes to section 20.14 03 (d) (underlined) ,

should be incorporated .\n the final rule: ;

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(d) The licensee has ... advice.

lAl Licensec.s proposing to decommission by .

restricting use of the site chall seek advice from L such affected parties regarding the following i l matters concerning the proposed decommissioning--

(1) ....

(1) . . .

l (ii) ...;

l (iii) ...;

L (2) ...;

L (B) In seekina advice on the issues identified in Section 20.14 03 (d) ( A) . the licensee shall orovide _

for:

(1) carticioat5cn by representatJves of a broad cross section of community interests

.who may be affected by the decommissionino:

(2) an occortunity for a compr.ehensive. ,

collective discussion on the issues by_the__ ,

carticicants reoresented; and x_ ]

1 (3) a oublicly available summary of the

results of all such discussions, includino a

!- description of the indi sidual viewooints of j the carticicants on the issues arid the I i

extent of acreement and disaareement amonc l

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the participants on the issues; and (e) ....

4. The following changes to section 20.1404 (underlined) should be incorporated in the final rule:

20.1404 Alternate criteria for license termination (a) The Commission may ...

(1) Provides assurance that ...

(2) Has employed ...

(3) Reduced doses to ....

(b) Licensees proposino to decommission by use of alternate criteria to terminate a license oursuant to caraaraoh (a) of this sec*agn shall seek advice from affected parties recardina this accroach. In seekino such advice. the licensee shall orovide for:

(1) carticipation by representatives of a broad cross section of community interests who may be affected by the decommissionina; (2) an__occortunity for a comprehens4.ve.

collective discussion on the issues by the participants reoresented; and (3) a oublicly available summary of the results of all such discussions, includina <

a description of the individual viewooints of the participants on the issues and the ,

extent of acreement and disaareement amona I the participants on the issues; and 1g1 The use of alternate criteria to terminate a license recuires the accroval of the Commission after i consideration of the NRC itaff's recommendations i that will address any comments provided by the Environmental Protection Acency and any public comments submitted oursuant to section 20.1405.

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5. The following change (underlined) to section 20.1405(a) should be incorporated in the final rule-(a) Notify and solicit comments from the Environmental i Protection Acency, local and state ....

6. Conforming changes to reflect the revisions in 3 and 4 above are needed in other regulations that reference these sections. The staff should also modify the Statement of Considerations accompanying the final rule to indicate that the staff will receive and review public comments gathered by the licensee prior to final NRC action on the licensee's !

request for license termination. The Statement of !

Considerations should also describe the other opportunities i i

for NRC interaction with.the public on individual site decommissioning applications. i l

7. The public announcement should be modified to include a general discussion of the Commission's position, as described j in this SRM, on the 25 mrem /yr limit, groundwater protection, l alternate criteria, public participation, and compatibility.

In addition, the announcement should include additional l illustrations of an individual's average exposure to typical l sources of radiation (e.g., medical diagnosis at 53 mrem /yr) j to provide perspective for cne public on the conservatism in the 25 mrem /yr limit.

8. A note should be made in the analysis of comments that EPA's MCLs are based upon outmoded modeling that does not reflect current understandings of the uptake and doses resulting from ingestion of radionuclides through drinking water.

9. The Regulatory Analysis, on pages 3 and 4, states that the criteria would not apply to sites which have submitted a sufficient license termination plan or decommissioning plan within (6 months after the effective date of the final rule]

and such a plan is approved by NRC within [18 months after I the effective date of the final rule). These times are 12 and 24 months respectively in the Federal Register. Staff should clarify these times.

10. In the GEIS, p.3-3, citation of regulations, categorization of facilities, item 1, it is stated that sealed source users are licensed under Parts 30, 33, and 35, but did not include Parts 34, 36, or 39. In item 2, it cites Parts 30, 33, and I

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35 in discussion of short-lived byproduct radionuclides, but does not include Part 39 for I-131 use. The GEIS should list all the parts of the regulations, or state " licensed pursuant to Part 30" (such as in sections 30.31 and 30.34).

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11. The Commission is aware that there are peculiarities in the models used for site release in that there is area dependence j in the dose calculations. The NRC staff should develop comprehensive guidance on how previously released l portions of licensed sites may need to be revisited to address this issue. The Federal Reaister notice shoulr'. be

. revised to make clear such consideration may be necessary.

l 12. The guidance the staff develops to implement the public participation provisions in sections 20.14 03 (d) and 20.1404 (b) of the final rule should include criteria for I establishing and using Site Specific Advisory Boards (SSABs).

The criteria should be such that the expected starting point in providing an opportunity for public participation vould be the establishment of an SSAB; however, the criteria should delineate those situations in which an SSAB would not be i appropriate.

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! 13. Prior to submitting the text of the final rule to the Federal ,

Reaister, section F.6.3 of the Statement of Considerations i l should be revised to augment the basis for the Commission's l

' decision with respect to radon.

14. The scope of the final rule should be revised to exclude facilities that are currently subject to Appendix A to 10 CFR Part 40. The Commission has considered the difficulties associated with the decommissioning of these unique facilities, some of which are also subject to EPA standards under UMTRCA, and is concerned that the complexities of this issue may have been overshadowed by other provisions of the rule. Therefore, the Commission believes that this aspect of the rule warrants additional consideration by the NRC and the affected parties. Without prejudice to the approach j described in SECY 97-046A and on an expedited basis, the staff should develop a rule which addresses license termination for these facilities. In the interim, the staff should continue its current practice for decommissioning uranium and thorium mills and in-situ leach facilities.

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I'nited States Nuclear Regulatory Commission Office of Public Affairs Washington, DC 20555 .

Phone 301-415-8200 Fax 301-415-2234 '

Internettopa@nrc. gov No.97-083 FOR IMMEDIATE RELEASE l (Wednesday, May 21, 1997)

NRC APPROVES MAXIMUM PERMISSIBLE RADIATION LEVELS FOR LICENSE TERMINATION E

The Nuclear Regulatory Commission,has approved an amendment to its regulations to establish maximum permissible radiation '

levels when a nuclear facility permanently shuts down, is l released for other uses, and the license is terminated.

The new rules will require licensees of permanently shutdown facilities to reduce remaining radioactivity to sufficiently low !

levels to permit the license to be terminated safely. Release of the property may be either:

e Unrestricted, in which case it could be used for any ,

purpose, or '

Restricted, so that it could not be used for certain

purposes, such as residential housing.

l The Commission believes that the new standards are consistent with specific recommendations of both national and international bodies tasked with the development of guidance for radiation protection; are appropriately based on risk, cost-benefit, and socio-economic standards; provide the needed 1

flexibility to accommodate site-specific conditions; and are :

sufficiently conservative to ensure protection of public health and safety and the environment.

Unrestricted Release Under the new regulations, a site may be released for f

unrestricted use if the radiation dose from contamination remaining on the property will be as far below 25 millirems per year as is reasonably achievable. (Twenty-five millirems may be ,

compared to a dose of about 5 millirems of background radiation i from one round-trip cross-country airline flight; 50 millirems average per year from medical examinations; and 300 millirems per year average in the United States from natural background ,

radiation.)

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Restricted Release The new regulations permit release of a site for rastricted use provided that the dose from contamination remaining on site is as low as is reasonably achievable and that legally enforceable institutional controls (such as deed restrictions) will ensure that the dose does not exceed 25 millirema per year.

In addition, if a site is released for restricted use, the licensee must provide financial arrangements to allow an independent third party to assume and carry out responsibilities for any necessary control and maintenance of the site.

Further, a licensee that intends to decommission by restricting use of the site must seek advice--from individuals and institutions in the community who may be affected by the decommissioning--on whether the provisions for institutional controls proposed by the licensee (1) will provide reasonable assurance that the radiation dose from contamination remaining on site will not exceed 25 millirems per year, (2) will be enforceable, and - (3) will not impose undue burdens on the local community or other affected parties.

In obtaining this advice, the licensee must provide for participation by a broad cross-section of community interests,.

provide an opportunity for a comprehensive discussion on the issues by participants, and make public a summary of the results of such discussions.

The Commission expects that institutional controls will be very effective.in keeping doses to l'evels below 25 millirems per year. Nevertheless the Conaission has included an additional level of protection in the rule to protect against the situation where the 25-millirems-per-year level could be exceeded by requiring that licensees provide reasonable assurance that, if the institutional controls were no longer in effect, the maximma yearly radiation dose from contamination remaining on site would not exceed 100 millirems per year, and be as low as is reasonably achievable.

Licensees in rare circumstances could also propose that, in the event institutional controls were no longer in effect, the residual radioactivity could be as high as 500 millirems per year. .However, licensees who propose to use the 500-millirem criterion must (1) demonstrate that further reductions in remaining radioactivity are not technically achievable, would be prohibitively expensive, or would result in not public or environmental harm; (2) make provision for durable institutional controls, such as engineered barriers or government control or ownership; and (3) provide sufficient financial resources to enable an independent third party to carry out periodic rechecks of the site at least every'5 years to make sure that the 2

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$ institutional controls remain'in place, and to assume and carry

out responsibilities for any necessary controls and maintenance i j of those controls.

l' Alternate Criteria for License Termination i

The Commission expects the vast preponderance of licensees l- to reduce residual radioactivity to levels-that meet the new

criteria-for unrestricted or restricted release. However, the

commission is concerned about the possible presence of certain

] difficult sites that could present unique decommissioning

problems.

, Because it is preferable to have provisions in the rule to deal with these sites rather than have licer. sees seek an exemption process outside the rule, the rule contains provisions j under which the Cammission may terminate a license using alternate criteria, greater than 25 millirems per year, if the licensee provides assurance that public health and safety would

continue to be protected, and that it was unlikely that the radiation dose from all potential man-made sources combined would

). be more than 100 millireme per year. The licensee must also place restrictions on site use to the extent practical and reduce the radiation dose to levels that are as low as reasonably achievable.

4 1 i The Commission expects the use of alternate criteria to be '

! confined to rare situations. To ensure that this is the case, the Commission is requiring that licensees who propose to use

, alternate criteria must seek advice or comment from affected )

{ parties and, as in the case where restricted release is sought, '

l provide for participation by representatives of a broad cross-

! section of community interests who may be affected by the i decommissioning, an opportunity for a comprehensive, collective l

. discussion on the issues, and a publicly available summary of the i

! results of all such discussions. I 1 l

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In addition, the use of alternate criteria to terminate a ;

license will require the approval of the Commission, after i consideration of NRC staff recommendations'that address any comments provided by the Environmental Protection Agency and by the public.

Public Inout 4

To provide ample opportunities for public comment, when the Commission receives a license termination or decommissioning i plan, or a proposal for restricted release of a site or release j using alternate criteria, the agency will publish a notice in the Federal Register. In addition, it will provide local notification via a notice in local newspapers, letters to state or local organizations, or other appropriate means. It will also

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! notify the Environmental Protection Agency, appropriate local and j state governments and Indian Nations and solicit their comments.

i specific additional requirements for public input are

j. described above for the restricted use and alternate criteria j cases.

l Proposed and Final Rule l

l A proposed rule on this subject was published for public comment on August 22, 1994. The full text of-the final rule and

, a description of specific changes made as a result of the 4

comments received on the proposed rule, and additional NRC l

! analysis, will be contained in a Federal Register notice to be published soon.

The commission did not adopt a separate groundwater

!' protection standard, as recommended by the Environmental

} Protection Agency. NRC agrees with the need to control exposures i- fram drinking groundwater that is potentially contaminated and i agrees that the environmental integrity of the nation's j' groundwater needs to b'e protected. However, NRC has concluded that protection of public health and safety in the use of this valuable resource is achieved by limiting exposure to persons

< from all potential pathways of exposure (i.e., radiation from the ground, eating food from soil or fish from surface water, inhalation of dust, etc.), including the groundwater pathway, to i as far below 25 millirems per year as is reasonably achievable 1 j and that imposition of a separate standard for groundwater would

!. not provide any significant enhancement of public health and

! safety and is therefore unnecessary.

Yesterday Shirley Ann Jackson, Chairman of the NRC, det with i Fred Hansen, Deputy Administrator of the Environmental Protection '

l l Agency (EPA) , to discuss the proposed final rule. At that l meeting,-she discussed the features of the rule, and NRC's

! position on the adequacy of the 25-millirems-per-year all !

l pathways standard, the concept of "as low as is reasonably !

i achievable" (ALARA) included in the NRC's rule, and the NRC's i position that, in light of the all pathways standard and ALARA, j there is no need for a separate groundwater standard. Hansen 4

expressed EPA's interest in continuing discussions with NRC regarding timely notice to EPA of proposed NRC license

{ termination in some specific categories of cases. The commission j 'has agreed to continue a dialogue with EPA following finalization i of the rule.

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! The new cleanup criteria for decommissioning will not apply ;

to sites already covered by a license termination or decommissioning plan approved previously by the Commission or j approved within 24 months of the effective date of the rule l j (which will be announced in the Federal Register). '

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The final rules that the Commission has promulgated will '

generally apply to most NRC licensees and to most licensees regulated by Agreement States (which are states that have assumed, by mutual agreement, part of the NRC's regulatory

authority). An Agreement State may implement more stringent i standards if it finds a need to impose such standards for local conditions.

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TIME SENSITIVE INFORMATION U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF STATE PROGRAMS OFFICE OF STATE PROGRAMS FAX: (301)415-3502 NUMBER OF PAGES: 15 including this page DATE: MAY 21,1997 i

TO: RADIATION CONTROL PROGRAM DIRECTORS IN AGREEMENT STATES AND NON-AGREEMENT STATES NRC REGIONAL STATE AGREEMENTS OFFICERS NRC REGIONAL STATE LIAISON OFFICERS FROM: RICHARD L. BANGART, DIRECTOR OFFICE OF STATE PROGRAMS

SUBJECT:

SP-97-035 FINAL DECOMMISSIONING RULE l

1 VERIFICATION - 415-3340 1

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< TRANSACTION REPORT > 05-22-1997(THU) 06:57 C' TRANSMIT 3 NO. DATE Tit 1E DESTINATION STATION PO. DURATION t10DE RESULT 32178 5-22 06:49 NYSERDA J,g.gg 15 O'07*58" NORMAL OK Y 15 O'07'58" i

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< TRANSACTIONiREPORT > 05-22-1997(THU) 06:46 E TF2 AN SM I T J NO. DATE TIME DESTINATION STATION PO. DURATION MODE RESULT 32177 5-22 06:37 518 457 5545 15 0'08*50* NORM.E OK 15 0"08*50"

< TRANSACTION REPORT > 05-22-1997(THU) 02:31 I

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[ ES R O AOC A ST 3 l

NO. DATE TIME DESTINATION STATION PO. DURATION MODE RESULT 32164 5-22 00:55 0000000000000 15 0'06*45" NORM.E OK 32165 01:02 360 753 1496 15 0'06*37" NORM.E OK 32166 01:09 304 558 0524 15 O*06*40* NORM.E OK 32167 01:16 608 2674799 15 O'06*46" NORM.E OK 32168 01:23 WYOMING RCP 15 O*07'42" NORM.E OK

32169 01: 31 518 457 2225 15 0*07'02" NORM.E OK 32170 01:38 518 457 5545 13 0*08'35" NORM.E UO10 32171 01:47 NEW YORK C!TY . 15 0'06'47" NORM.E OK 32172 01:54 502 227 7862 iS O'07'35" NORMAL OK

32173 02: 02 WASHINGTON OC 15 O*06'36" NORM.E OK 32174 02:09 7996726 15 O'06'40" NORM.E OK 32175 02:16 512 239 6362 15 0'06'47" NORM.E OK 32176 02:23 8097566285 15 0'07*55" NORM.E OK 193 1*32'27" l

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< TRANSACTION REPORT > 05-22-1997cTMu> 00:54 C BROADCAST 3 NO. DATE TIME DESTINATION STATION PO. DURATION MODE RESULT 32139 5-21 21:41 6177272098 15 0*07'25" NORM.E OK 32140 21:49 517 335 8706 15 O'06'44" NORM.E OK 32141 21:56 612 215 0976 15 0*06'43' NORM.E OK 32142 22:03 601+354+6167 15 0'09'42' NORMAL OK

- 32143 22:13 314 751 6010 15 O'06'49' NORM.E OK 32144 22:20 406 444 2606 15 0*06'46' NORM.E OK 32145 22:27 402 471 9449 15 O'06'36" NORM.E OK 32146 22:34 7026875751 15 O'09*44* NORMAL OK 32147 22:44 603 225 2325 15 0'06'49" NORM.E. OK 32148 22:51 DEPE RADIAT!ON 15 0'06'50" NORM.E OK 32149 22:58 5058271544 15 0*09*21" NORMAL OK 32150 23:08 518 458 6434 15 0'06*47" NORM.E OK 32151 23215 919 571 4148 15 0'06'41* NORM.E OK 32152 23:22 701 326 5200 15 O*06*37* NORM.E OK 32153 23:29 OHIO 15 0*06'46" NORM.E OK 32154 23:36 405 271 8425 15 0'06*36* NORM.E OK 32155 23:43 503 731 4081 15 0*06'36" NORM.E OK 32156 23:50 PENNSYLVANIA 15 0'06'44" NORM.E OK 32157 23:57 401 277 2456 15 0'12'14" NORM.E OK 32158 5-22 00:10 8037377412 15 0*06'46" NORM.E OK 32159 00:17 605 773 6667 15 0'06*48" NORM.E OK 32160 00:24 615 532 7938 15 O*06'42" NORM.E OK 32161 00:31 5128346708 15 0'07'25" NORM.E OK 32162 -00:39 801 533 4097 15 O'07'43" NORM.E OK 32163 00:47 8028657745 15 O*07'25" NORM.E OK 375 3'05'19"

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< TRANSACTION REPORT > Os_21_1997<Ne0> 21:40 l

l C BROADCAST 3 l

l NO. DATE' TIME DESTINATION STATION PO. DURATION MODE RESULT 32114 5-21 18:15 610 337 5324 15 0'06'44" NORM.E OK 32115 18:22 404 562 4955 15 0*06'45" NORM.E OK i 32116 18:29 7085151096 15 0*13'15' NORM.E OK l 32117 18:42 817 860 8122 15 0'08'49" NORM.E OK 32118 18:51 5109750381 15 O'06'55" NORM.E OK 32119 18:59 334 613 5387 15 0'12'27* NORM.E OK 32120 19:12 9075861877 15 0'06'51" NORM.E OK

, 32121 19:19 6024370705 15 0'09'29" NORMAL OK l 32122 19:29 5016612468. 15 0*07'28" NORM.E OK

! 32123 19:36 0111916 3243610 15 0'06'40" NORM.E OK ,

l l 32124 19:43 303 343 3697 15 0'07'22* NORM.E OK 32125 19:51 CONNECTICUT 15 0'08'22" NORM.E OK !

I 32126 20:00 3027393839 15 O'06*38" NORM.E OK 32127 20:07 904 487 0435 15 0 06'50" NORM.E OK 32128 20:14 404 362 2653 15 0*06'45" NORM.E OK l 32129 20:21 HAWAII 15 0*06'58" NORM.E. OK f 32130 20:28 208 334 2382 15 0'09'43" NORMAL OK-l 32131 20:38 *217 524 4724 15 0*06'43" NORM.E OK

! 32132 20:45 INDIAN. 15 0'06*35* NORM.E OK 32133 20:52 515 242 6284 15 0*06'44" NORM.E OK 32134 20:59 913 296 0984 15 0'07'26" NORM.E OK 32135 21:07 502 564 6533 15 0*06*37* NORM.E OK 32136 21:14 LOUISIANA 15 0*08*38* NORM.E OK ,

32137 21:23 MAINE 15 0'09'19' NORMAL OK 32138 21:33 410 631 3198 15 0'07'25" NORMAL OK l 375 3'17'28" l \

I t

l u

. i

-m,-wr- r- -- w , -:i-

< TRANSACTION REPORT > 05-21-1997(WED) 17:32 C BROADCAST 3 NO. DATE TIME DESTINATION STATION PG. DURATION MODE RESULT 32110 5-21 17:02 PENNSYLVANIA 15 O*06'43' NORM.E OK 32111 17:09 405 271 8425 15 O'06'42' NORM.E OK 32112 17:16 6177272098 15 O'07*24" NORM.E OK 32113 17:25 OHIO 15 O'06*43" NORM.E OK 60 O'27'32"

< TIMER-COMMUNICATION CARD > OS-21-1997(WED) 16:43 .

i NO. RESERVED ITEM RESRV.DATE CALL DESTINATION STATION :

164333 BRO /OCAST 5-21 16:43 18:15 RO >

RONil' RONII! '

RON!V-RIVAJC ALABAMA ALASKA ARIZONA ARKANSAS