ML20149H401

Informs of Completion of Review of Draft Regulatory Guide DG-1071, Std Format & Content Guide for Post-Shutdown Decommissioning Activities Rept. Staff Comments Marked on Encl Copy of Draft DG-1071

ML20149H401
Person / Time
Issue date:	07/08/1997
From:	Jim Hickey NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Weiss S NRC (Affiliation Not Assigned)
References
REF-WM-3, RTR-REGGD-01.XXX, RTR-REGGD-1.XXX, TASK-*****, TASK-RE NUDOCS 9707240372
Download: ML20149H401 (12)

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July' 8,1997o HEMORANDUM T0:: fSeymour:H.. Weiss. Director;..

Non-Power Reactors and Decommissioning j

Project: Directorate

-Division of Reactor Program Management John W, Hickey, Chief

'FROM:

. Low-Level. Waste and Dec[ommissioning0riginal signed by]'

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. Projects Branch-Division of. Waste Management,-NMSS y

SUBJECT:

REVIEW OF-THE DRAFT REGULATORY' GUIDE DG-1070 We have completed our review of the ' draft Regulatory Guide DG-1071, " Standard Format and Content. Guide for Post-Shutdown Decommissioning Activities Report."

Our comments are marked on the-enclosed' copy of draft DG 1071.

]

'Attachmenti As stated i

Contact:

Larry Pittiglio. LLDP/DWM

-(301) 415-6702 TICKETi LLDP-7/ p3 j

Distribution: -Central File NMSS r/f LLPD r/f MBell l

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C - COVER-E - COVER & ENCLOSURE N ='N0 COPY ACNW: YES N0 X IG

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July: 8,1997 MEMORANDUM TO:

Seymour H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Man ement

,3 FROM:

John W.. Hickey l Chief h

/

Low-Level Waste and Decomm loning Projects Branch Division of Waste Management, NMSS

SUBJECT:

REVIEW OF THE DRAFT REGULATORY GUIDE DG-1070 We have comoleted our review of the draft Regulatory Guide DG-1071, " Standard Format and Content Guide for Post-Shutdown Decommissioning Activities Report."

Our comments are marked on the enclosed copy of draft:DG-1071.

Attachment:

-As stated

Contact:

Larry Pittiglio. LLDP/DWM (301) 415-6702 I

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July 8, 1997 MEMORANDUM TO:

Seymour H. Weiss. Director Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management FROM:

John W. Hickey, Chief [0riginal. signed by]

Low-Level Waste and Decommissioning Projects Branch Division of Waste Management, NMSS

SUBJECT:

REVIEW OF THE DRAFT REGULATORY GUIDE DG-1070 We have completed our review of the draft Regulatory Guide DG-1071. " Standard Format and Content Guide for Post-Shutdown Decommissioning Activities Report."

Our comments are marked on the enclosed copy of draft DG-1071.

Attachment:

As stated

Contact:

Larry Pittiglio. LLDP/DWM (301) 415-6702 TICKET: LLDP-Distribution:

Central File NMSS r/f LLPD r/f M8 ell 0Gillen PUBLIC RNelson LBell DOCUMENT NAME: S:\\DWM\\LLDP\\CLP\\PSDAR

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DATE 7/,M/97 7/ F/6 7/f/97 7/

/97 0FFICIAL RECORD COPY C = COVER E = COVER & ENCLOSURE N = NO COPY ACNW: YES NO X IG YES NO ~A Delete file after distribution:

Yes No LSS YES NO

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June is:ii ps%q U.S. NUCLEAR REGULATORY COMMISSION -

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g OFFICE OF NUCLEAR REGULATORY RESEARCH 9,

Draf t DG-1071-

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DRAFT REGULATORY GUIDE

Contact:

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DRAFT REGULA ORY GUIDE DG-1071 STANDARD FORMAT AND CONTENT FOR POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT

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A. INTRODUCTION Decommissioning esiearu permanently removin'1 e nuclear facility from service and a

radioactive materials on the licensed site to levels that would permit termination of the Nuc 29,1906 a hnal rule was published in the Federa/

e Regulatory Commission (NRC) license. On Jufy Register (61 FR 39278) amending the NRC's regulations nn the decommissioni lead to termination of an operating license for nuclear power reactors and release of the prope

~ This final rule included changes to 10 CFR Parts 2,50, and 51.

j The f evised regulation,10 CFR 50.82(a)(4)(i), requires that prior to or within two years r

following permanent cessation of operations, the licensee will provide the NRC with a decommissioning activities report (PSDAR). The PSDAR must include a description of the 4

planned decommissioning activities, a schedule for the accomplishment of signific an estimate of expected costs. The PSDAR should also document the results of the licensee evaluation of the environmentalimpacts associated with site-specific decommissioning a evaluation should result from a comparison of the site specific environtnentalimpacts of decommissioning and those impacts identified in previously issued environmental statem Generic Environmental Impact Statement (GEIS) on Decommissioning, NUREG-058r 'Ref.1),

The purpose of the PSDAR is to provide the NRC and the public with a general overviaw of the licensee's proposed decommissioning activities. The PSDAR serves to inform Thee regulatory guide is bemg issued er.3fraf t form to mvolve the pubhc m the eartv stages of the d stee. It hee not received complete staff review and does not represent en official NI4C stati position.

Public commente are being sohcited on the draft guide hnuludmq any impleme 20555-0001. Copies of cornments value/ impact statement.

and Directivee Branch, office of Administration, u S. Nucteer Regulatory Commission, Washington, DC d

received may be enemmed at the NRC Pubhc Document Room. 2120 L Street NW., Washmgton, DC. C by

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.ometic deetnbution list for single copies Requests for single copies of active or desft guides inh;ch may be reproduced) or for p 0555 0001.

Printing, Graphics, and oistnbution Branch; or by f ax to f 3011415 5272.

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~ he NRC staff of the licensee's expected activities and schedule, which f acilitates The PSDAR is also a mechanism t

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. inspections and decisions regarding NRC oversight activ t es,

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for informing the public of the proposed decommissioning activities before the

' decommissioning activities are conducted.~

The purpose of this regu!atory guide is to identify.the type of information to be PSDAR that is acceptable

. contained in th'e PSDAR and establish a standard format for the d format to.

to the NRC staff. The NRC staff suggests that licensees use this standar facilitate the preparation of PSDARs. This regulatory guide is being develope conjunction with Draft Regulatory Guide DG-1067," Decommissioning of Nuclea p/N i i ning Reactors" (June 1997), which also c Sg-developed in support of the decomm ss o

- rule (61 FR 39278).

Regulatory guides are issued to describe and make available to the public information as methods acceptable to the NRC staff for implementing specific p

" Commission's regu'ations, techniques used by the M3 f in evaiuating specific proble f

postulated accidents, and guidance to applicants, Standard format and content RC staf f in submittats

. developed to describe and delineate the information needed by the N from lice sees. Regulatory guides are not substitutes for regulations, and comp n

j regulatory guides is not required. Regulatory guides are issued in draft form f d

comment to involve the public in the early stages of developing the regulatory pos Draft regulatory guides have not received complete staff review and do not represent official NRC statf positions.

The information collections contained in this draf t regulatory guide are covered the requirements of 10 CFR Part 50, which were approved by the Office of Manage The NRC may not cc-iuct or sponsor, and a and Budget, approval number 3150 0011.

'spond to, a collection of information unless it displays a person is # 9 quired to currently valid OMB control number.

B. DISCUSSION According to 10 CFR 50.82(a)(5), the licensee is prohibited from performing any major decommissioning activities until 90 days af ter the NRC has received th PSDAR submittal and until the certifications of permanent cessation of operations permanent removal of fuel from the reactor vessel have been submitted. Major 2

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decomrnissioning activities are defined in 10 CFR 50.2 as ".

any activity that results in permanent removal of major radioactive components, permanently modifies the structure the containment, or results in dismantling co iganemfghipment containingghyg d" Major radioactive components 3 ;

class C waste in accordance with 6,61.55 are defined in 10 CFR 50.2 as ", the reactor vessel and intemais, steam generators, pressurizers,large bore reactor coolant system piping, and other large components that are radioactive to a comparable degree."

Upon receipt of the PSDAR, the NRC will docket the PSDAR ar'd place a notice regarding its receipt in the Federc/ Register to solicit comments on the PSDAR from the public pursuant to 10 CFR 50.82(a)(4)(ii). A copy of the PSDAR will be made available to the public at the local public document room. The NRC will schedule a public meeting in the vicinity of the site to describe planned activitie; and to hear public comments. To the extent possible, the public meeting should be held within 90 days of the NRC's receipt of the licensee's PSD.TR submittal; it normally would to held about 30 days before the 90-day

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period onds, The NRC will determine wl. ether the licensee's PSDAR complies with the informational requirements of the regulation. Major decommissioning activities must not be started until 90 days af ter the _NRC receives the PSDAR. NRC approval of the PSDAR is not required; however,if the NRC determines during the review that the information provided by the licensee in the PSD AR does not comply with the requirements in 10 CFR 50.82(a)(4)(i),the NRC willinform the licensee in writing o" the deficiencies and require the deficiencies to be corrected before major decommissioning activities are begun. A list of f actors that could cause the NRC to find the PSDAR deficient are given in Section 5 of this guide.

The above provicior for SDARs apply to licen"ees who do not have an NRC-28,1996, which is the effective date of the approved decommissioning plan by August final rule. Decommissioning plans normally contain sulficient information to satisfy the requirements of the PSDAR. For licensees that have a decommissioning plan approved 28,1996, the approved decommissioning plan and the associated before August environmental review are considered to be the PSDAR submittal (see 10 CFR 50 licensee had submitted a decommissioning' plan before August 28,1996, and the NRC staff had not taken final action on the plan, the staff considers the decommissioning plan to be 4

the PSDAR submittal. The-sGIs woun.i navo icw.ed the R-.m

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Licensees with an approved decommissioning' plan me setidted to whmit an update to,the PSDAR for activities that were not considered in thea dect.tmtrnssine, rag plan. Because of' the amount of material contained in the decommissioning vans and the requirement to update thisinformation, and because of the potential for a misunderstanding as to what -

must be updated l licensees are encouraged to replace their decommissioning plans with a

-PSDAR update that uses the format and content specified in this document.

C, FORMAT AND CONTENT OF THE POSTSHUTDOWN DECOMMISSIONING ACTIVITIES REPORT The purposes of the PSDAR are to i ) inform tne public of the licensee's planned i

decommissioning activities, (2) assist in the scheduling of NRC resources necessary for the

' appropriate oversight. activities. (3) ensun th-censee has considered the costs of the

planned decommissioning actnnous and cons'dered the funding for the decommissioning process, and (4) ensure the environmentalimpacts of the planned decommissioning activities are bounded by those considered in existing environmental impact statements.

1 The PSDAR submittal precedes any significant decommissmoing activities as they are defined in 10 CFR 50.2. The rule in 10 CFR 50.82(a)(4)(i) requires that the PSDAR include (1) a description of the licensee's planned major decommissioning activities, (2) a schedule for completing 'ihese activities, (3) a site-specific estimate of the expected decommissioning costs, and (4) a discussion that provides the reasons for concluding that the environmentalimpacts associated with site-specific decommissioning activities will be bounded by appropriate previously issued environmentalimpact statements. Each of these items is discussed in further dt.tailin the following sections and the content expected by 4

the NRC staff is described.

DESCRIPTION OF LICENSEE *S PLANNED DECOMMISSIONING ACTIVITIES 1.

The PSDAR should include a description of the licensee's planned activities for l

decommissioning.' The purpose of the description is to inf orm the NRC and the public of the planned decommissioning by providing a general overview of no proposed decommissioning ' process and identifying specific activities in the process.

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j The licensee should describe (in general terms) the method or combination of

- methods selected for decommissioning (i.e., long term storage followed by decontamination and dismantlement (SAFSTOR), or prompt decontamination and dismantlement (DECON), or 5

partial decontamination and'dismantiement followed by long-term storage and then final-decontamination and dismantlement). The licensee should also list and describe the major

't activities and tasks related to decommissioning ~ The activities and tasks should be j

identified and discussed briefly in the ordt.r n which they will occur. The amount of i

j description providad for each of the actisities will depend, in part, on the nature of the I,

activity, although normally it would be limited to approximately a paragraph ' Activities that

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- either were not considered in the GEIS or are specific and unique to the facility, and thus would require additional NHC staf f oversight, should be described in greater detail than-

,7g ra vel routine activit;es. For example, a chamical decontamination of contaminated system using : mild acid would only require a state

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on a system containing large amounts of contaminatio.1 (for instance, the primary system) t would result in a more detailed description of the process for the staf f to ascertain the level I:

of oversight that would be required. Likewise, a program that was not specifically addressed in the GEIS, such as the removal, processing, and storage of fuel debris contained in a system or in the spent fuel pool, would need to be discussed in greater v

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detail, f

For a prompt dismantlement (DECON) process or for a storage period of f

. approximately 5 years followed by dismantlement,it is expected that activities such as the following would be described.

4 Removal of the reactor vessel and intemals Removal of other large cornponents Removal of the balance of the primary system j

General activities relating to the removal of other significant radioactive components and any structures 4

Decontamination of radioactive components, including the use of chemical t

decontamination techniques

' Decontamination of structures or buildings, such as the auxiliary and fuel ha'ndling I

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s Special or unusual programs (for instance, removal and processing of fuel debris

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from the spent fuel pool) that were not considered in the GEIS (these activities would need to be described in some detail)

Onsite storage of components

. Removal of the low level radioactive waste', including any anticipated compaction or

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incineration of the waste

Location of the ultimate disposal site.for the low level radioactive waste I~*-

Storage or removal of the spent fuel and greater than-Class-C waste, including the use (if planned) of an independent spent fuel storage installation (ISFSI) or wet -

storage facility Removal of hazardous radioactive (mixed) wastes.

If long term storage (longer than approximately 5 years)is selected as a decommissioning ontion, the activities related to preparing the facility and site for stcrage should be listed and described, Activities and tasks for maintaining the facility and site in safe storage should also be mentioned, it is expected that the description of the preparation process and the storage phase would specifically call out activities such as the a

following, Draining of specific systems and removal of resins from ion exchangers Decontamination of specific high-dose areas Removal of low level waste that is ready to be shipped Removal or storage of the fuel and greater than-Class-C waste De energizing or deactivating specific systems ventilation systems and fire protection s/ sterns for use durirm the Rw. figuration storage period Inspection and monitoring plans during the storage period Security plans during the storage period Maintenance of any systems critical to final dismantlement during the storage period.

'The activities relating to the transition from long term storage to decommissioning j-

. and activities relating to the final decommissioning of the f acility shou:d also be described to the extent known. According to 10 CFR 50.82(a)(3), decommissioning'will be d

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completed within 60 years of permanent cessation of operation unless a longer erm h and safety.

coriipletion is approved by the NRC as necessary for public he t meant to be allinclusive or These lists are provided merely as examples and are to imply that a given licensee must include each of the acti ities in the decommission process. The description of the licensee's planned decommissioning activities is mea be broad, but specific to the facility; however, it should Ife complete and should include those activities occurring frorn the time of certification of permanent removal of the fuel the anticipated termination of the license.

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Details regarding the estimated waste volume, esti(nated occupational doses, licensee's organization, or discussions on quality assurancgh A) related to owever, this information may decommissioning are not required or expected in thn P90Afi-NM be required in periodic updates to the Final Safety Analysis Repory

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W SCHEDULE OF 'LANN DE MMISS{QNING ' CTIVITIES The purpose of the schedule is to prcvide information to the NRC and the public on the anticipated timing of decommissioning events, as well as to allow the NRC to sche

-q resources necessary for appropriate oversight activities. The temporal relationship between the activities should be shown f or the major activities described in Section 1, so the read understands the sequence of events as well as the timing of the events.

Schedules or diagrams should clearly indicate the estimated initiation and completion of specific tasks identified in Section 1. Any activities that will require a significant NR licensing effort should be identified, including the start and desired end dates for acti such as the submittal of defueled technical specifications, the approval and licensing of om iance for ISFSI, or the licensHg acti ities - ssociated with a cert' icat N1W transportation of major components.Old Lh sc.

u I owing issuan e o PSDAR are addressed in Section 6 PSDAR Updates.

The level of detail of the schedule will depend on the timing of the activity and on the degree of oversight required by the NRC. The schedule for major activities in the nea term should be given to the nearest month and year. Activities that will follow a storage period of at least 5 years may be scheduled to the closest year.

ESTIMATE OF EXPECTED. DECOMMISSIONING COSTS 3.16cft 50.8pla ok m

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e PSDAR should includa ^ "-Mic estimate of the expected decommissioning costs The licensee will have alreadyjLyhmittM = ent.eltimate for establishing a fund for' de'c mmissioning'as required by 10 CFR 50.75(b). This estimate will have been revised periodically during operation. Licensees may also update their preliminary cost estimates required by 10 CFR 50.75(f)(1) and use the updated estimate in preparing the cost estimate required by 10 CFR 5 a)(4)(i). The updated cost estimate required by 10 CFR r a site specific cost en)imate thaLis. based ofwYtivities and the

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t schedule discussed in Sections 1 and 2 aboveer tual costs at similar facilities that have

'v' ies)or neric cost estimates. The licensee's 2

undergone similar decommissioning a include in the PSDAR should be based on specific decision on which type of estimate t plans for decommissioning, if a licensee has chosen extended safe storage of the facility followed by decontamination and dismantomnt, generic information would be acceptable to the NRC staff as cost estimates of final dismantlemer.t would occur far in the future.

The licensee mJst, however, still use sitt sp : fic data or estimates for near term activities such as large component removal and preparation for long term storage.

For generic cost estimates, see NUREG/CR-0672 (including Addenda 1 through 4),

" Technology, Safety and Costs of Decommissioning a Reference Boiling Water Reactor i

' Power Station" (June 1980)(Ref. 2); NUREG/CP-0130 " Technology, Safety and Costs of Decommissioning a Reference Pressurized Water Reactor Power Station" (June 1978)(Ref.

3): NUREG/CR-5884," Revised Analysis of Decommissioning for the Reference Pressurized Water Reactor Power Station" (November 1995)(Ref 4); and NUREG/CR 6174," Revised Analyses of Decommissioning for the Reference Boiling Water Reactor Power Station" (July 1996)(Ref. 5); and NUREG 0586," Final Generic EnvironmentalImpact Statement on Decommissioning of Nuclear Facilities" (August 1988)(Ref.1).

The cost estimate could be a combmation of any of these or other methods. The cost estimates should be described briefly (e.g., site specific, generic cost estimates, based

- on similar f acilities), but cost estimates need not be provided for the detailed lists of l

activities. The costs should be described in relation to radiological decommissioning (further broken down into large-component removal, planning, decontamination activities, low-level radioactive waste disposal, and decommissioning finance costs) for the appropriate level of detail for the cost estimate section. 'The submittal for this section could be as simple as a list of the above items w th the cost estimate for each task, a total cost CARMA,,

estimate, and a shsst parag ;68I)'nc Joie.gt "= dct1rils how the cost estimates w

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The licensee's plan for decommissioning could not be completed as described (for example,if the plan called for immediate decontamination and dismantlement of the

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facility and there were no waste disposal facilities available for the facility to use).

The schedule included a decommissioning process that could not be completed l

l within 60 years of the permanent cessation of operations as required by 10 CFR 50.82(a)(3), unless it were shown this action is necessary to protect public health and safety (if so, approval would be made on a case-by-case basis).

1 The licensee's decommissioning plans, as presented in the PSDAR, included a decommissioning process that could not be completed for the estimated cost using the generic guidelines in the GEIS and using previous facility decommissioning costs.

The PSDAR inJadp:' a tivities-that would endanger the he.ahb andp of the,J.'

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^ cmc t6e NRC's health and saf 4(y regulations or would result in a,Cw, 1

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major detrimentalimpact to the environment that is not bounded by the current environmen.al impact statements.

1 6.

PSDAR UPDATES According to 10 CFR 50.82(a)(7),the licensee must notif y the NRC,in writing with a copy to the affected States, before performing any decommission:ng activity that could 4

be considered to be inconsistent with or a significant schedular change to the actions or schedules described in the PSDAR. Although not specifically stated in the rule, changes that result in any type of environmentalimpact not previously analyzed sh(.,uld also be teported to the NRC with a copy sent to the affected States. Changes that significantly increase the decommissioning costs also require notification to the NRC with a copy sent to the affected States.

The PSDAR may be changed by the f ollowing process. Significant changes in major mijeggnes., schedules, or the cost estimate require written notification to the NRC.

Changes to the milestone schedule will be used by the NRC staff to' schedule NRC inspections of the licensee's activities and to provide assurance that decommissioning is being conducted safely and in accordance with regulatory requirements. Examples of changes in activities and schedule include, but are not limited to, changing from long-term storage to active dismantlement, changing the method used to remove the reactor vessel or steam generators from cutting and segmenting to intact removal, or changing the schedule to affect major milestones. Examples of significant increases in cost associated with 11

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