ML20151T232

SRP for Evaluating Power Reactor License Termination Plans

ML20151T232
Person / Time
Issue date:	09/02/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20151T229	List: ML20151T226 ML20151T232
References
PROC-980902, NUDOCS 9809090316
Download: ML20151T232 (16)

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STANDARD REVIEW PLAN FOR EVALUATING POWER REACTOR LICENSE TERMINATION PLANS i

September 2,1998 1

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U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards 9909090316 990902 - ATTACHMENT PDR ORG NOMA PDR l

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e CONTENTS A. I NTRO D U CTI O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. ................. .. 1 B LTP STANDARD REVIEW PLAN AND ACCEPTANCE CRITERIA . .. ...... , 3 .

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1. General lnformation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............ 3

2. ' Site Characterization. ........ . . ...... ................. .... 4 l r

3. Identification of Remaining Dismantlement Activities . . . . . . . ............ 4

4. Remediation Plans . . . . . . . . . . . ......... .... ................ .. 5

5. Final Radiation Survey Plan. . . . . . . . . . . . ........................ 6

6. Compliance with the Radiological Criteria for License Termination . . . . . . . . . 7 ,

7. Update of the Site-Specific Decommissioning Costs .......... ... .... 10 (

8. Supplement to the Environmental Report . . . . . . . . . . . . . . . . . . .... . .. 11 1

- C. EVALUATION FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . .. ................. 11 D. I M P LEM E NTATI O N . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 E. REFERENCES . . . . . . . . . . . . . . . . . . . . .. . ..... ............. . .... 1?

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A. INTRODUCTION  !

l On July 29,1996, the Commission published amendments to its regulations in 10 CFR Parts 2,50, and 51 (61 FR 39278) (Ref.1), prescribing specific criteria for decommissioning i nuclear power reactors, to be effective August 28,1996. This rule, by eliminating, revising, or extending operating reactor requirements commensurate with the importance to safety, ,

specifies requirements for reactors that are permanently shut down and have no fuel in the reactor vessel. Such rea,ctors present a significantly reduced risk to the public.

! Decommissioning activities for power reactors may be divided into three phases: (1) initial 1 activities; (2) major decommissioning and storage activities; and (3) license termination activities. Draft Regulatory' Guide DG-1067,' Decommissioning of Nuclear Power Reactors" (May 1997, Ref. 2), is being developed to describe methods and procedures that are

. acceptable to the U.S. Nuclear Regulatory Commission (NRC) staff for implementing the rules ,

i. that relate to the initial activities and the major phases of decommissioning. l c .

i For Phase 3,10 CFR 50.82(a)(9) specifies that an application for license termination must be <

accompanied or preceded by a License Termination Plan (LTP), which is subject to review and ,

approval by the NRC. According to 10 CFR 50.82(a)(9)(i), the licensee must submit an LTP at

-least two years before termination of the license. The LTP approval process is by license

. amendment. A public meeting must be held near the site; any hearing held in relation to the j LTP would fall under either Subpart G or Subpart L of 10 CFR Part 2. If the fuel has been j l

permanently removed from the Part 50 facility to an authorized facility, a hearing for the LTP l would be in accordance with Subpart L. Conversely, if an LTP were submitted while the spent 1 l fuel was stored within the Part 50 facility, Subpart G of 10 CFR Part 2 would apply.

Even after the LTP has been approved,10 CFR 50.59 continues to apply, to allow the licensee to make certain changes that do not result in an unreviewed safety question or changes to the technical specifications, and the changes must meet the requirements of 10 CFR 50.82(a)(6).

On July 21,1997, the Commission amended its regulations in 10 CFR Parts 20, 30,40,50,51,

' 70, and 71 (62 FR 39058, Ref. 3), prescribing specific radiological criteria for license termination. These radiological criteria, which were effective August 21,1997, apply to all sites except the sites that were " grandfathered" per 10 CFR 20.1401(b).

I Under the new regulations in the LTP, a licensee may propose either:

. . Release of the facility and site for unrestricted use; or

• Release of the facility and site under restricted use conditions.

' For the most part, the LTP will include a final site characterization, dose assecsment, remediation, and survey plan. The LTP must be submitted as a supplement to the licensee's Final Safety Analysis Report (FSAR) or an equivalent document. A licensee might submit the LTP concurrently with the post-shutdown decommissioning activities report (PSDAR), although NRC would not expect this.  ;

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l Currently, the Office of Nuclear Material Safety and Safeguards (NMSS), Division of Waste Management, Low-Lavel Waste and Decommissioning Projects Branch has responsibility for the revisw of the LTP, and the development of this Standard Review Plan (SRP).

The SRP provides guidance to staff reviewers in NMSS on performing safety reviews on LTP.

Although this document is intended to be used by the NMSS staff in conducting reviews, it can be used by interested parties responsible for conducting their own licensing reviews or developing an LTP. The principal purpose of the SRP is to ensure the quality and uniformity of staff reviews and to present a well-defined base from which to evaluate the requirements. It is also the purpose of the SRP to make the information about regulatory matters widely available to improve the understanding of the staff's review process by interested members of the public and the nuclear industry.

The review is primarily based on the information provided by an applicant in the LTP. The LTP must be sufficiently detailed to permit the staff to independently verify that the facility can be decommissioned safely, and the license terminated. The specific information that the staff needs in order to evaluate an LTP is identified in DG-1078, " Standard Format and Content of License Termination Plans for Nuclear Power Reactors"(Ref. 4). The individual SRPs are keyed to DG-1078.

The SRP is written to cover a variety of license termination conditions. Each SRP provides the acceptance criteria for all areas of review for license termination. For any given application, the I staff reviewers may select and emphasize particular aspects of each SRP as is appropriate. In i some cases, a facility feature may be sufficiently similar to a feature previously reviewed so that I a complete new review is not needed. The SRP identifies the matters to be reviewed, the basis l for the review, and the conclusions that are sought.

Each SRP is divided into the following sections: 1) Area of Review; 2) Acceptance Criteria;

3) Evaluation Findings; 4) Implementation; and 5) References.

1. Area of Review The beginning of each area in Section B, "LTP Standard Review Plan and Acceptance Criteria" summarizes the area of review that is described in detailin DG-1078, the purpose of the review, and the applicable NRC requirements .

2. Acceptance Criteria This section contains the technical bases fcr determining the acceptability of analysis or of the program. The technical bases may consist of specific criteria such as NRC regulatory guides, industry codes and standards, and branch technical positions. These approaches are codified in this form so the staff can take consistent positions on similar problems as they arise. Branch technical positions present approaches that are acceptable to the staff for demonstrating compliance with NRC regulatory requirements, but that are not considered as the only possible approaches. Applicants proposing approaches to problems other than those described in the branch technical positions may expect longer review times and more extensive questioning in these areas.

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3. Evaluation Findings This section presents the type of conclusion that is sought for the particular review area. For ,

, .each SRP, a conclusion of this type will be included in the Safety Evaluation (SE). The SE also  !

will contain a description of the review, including aspects of the review that were selected or emphasized, and the bases for any deviation from the SRP. '

4. Implementation  :

This section explains how and when the SRP and acceptance criteria will be implemented by the staff.

l S. References This section lists the references that are applicable to the review process.

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. B. LTP STANDARD REVIEW PLAN AND ACCEPTANCE CRITERIA i

1. GENERAL INFORMATION The LTP table of contents should address each of the following 10 CFR 50.82(a)(9) criteria, and the 10 CFR 20, Subpart E related radiological criteria for unrestricted, and restricted j

, release of the site, with any supporting information. The regulation applicable to this review is e 10 CFR 50.82(a)(9),10 CFR 50.82(a)(10), and 10 CFR 20. ,

ACCEPTANCE CRITERIA .

l The LTP is acceptable if it is submitted in the form of a supplement to the FSAR and i accompanied by or preceded by an application for license termination. .

l The LTP is acceptable if it is submitted at least two years before termination date of the license.

i The LTP is acceptable if it is submitted in form of a license amendment request.

The LTP is acceptable if it lists the licensee's name and address, license number, and docket J

number and the information agrees with the most recent license.

The LTP addresses each of the following 10 CFR 50.82(a)(9) criteria, and the 10 CFR Part 20, l Subpast E, radiological criteria for unrestricted and restricted release of the site:

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. Site characterization

.: Identification of remaining site dismantlement activities i

== - Plans for site remediation  ;

. ' Detailed plans for final radiation surveys for release of the site  !

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Method for demonstrating compliance with the radiological criteria for license termination l

For restricted release include a description of the site's end use, documentation on l public consultation, institutional controls, and financial assurance needed to comply with the requirements for license termination for restricted release or alternative criteria.

j Updated site-specific estimate of remaining decommissioning costs j Supplement to the environmental report, pursuant to 10 CFR 51.53, that describes any i new information or significant environmental changes associated with the licensee's proposed termination activities 1 l

2. SITE CHARACTERlZATION The purpose of providing site characterization is to determine the extent and range of radioactive contamination on site including structures, systems, components, residues, soils, l l and surface and ground water. Based on the site characterization, the final surveys are l conducted to cover all areas where contamination previously existed, remains, or has the l potential to remain. As part of the review, the NRC staff should review the licensee's site characterization plans and site records required under 10 CFR 50.75(g) to ensure that the site characterization provided in the LTP is complete and the data was obtained with sufficiently l sensitive instruments, using proper quality assurance procedures, to obtain reliable data l l

applicable to the required decommissioning limits. The regulation applicable to this area of j review is 10 CFR 50.82(a)(9)(ii)(A).

l ACCEPTANCE CRITERIA I The LTP identifies alllocations, in and outside of the facility, where events such as I mdiological spills, burials, or other radiological accidents / incidents that did result or could have l resulted, in contamination of structures, equipment, laydown areas, or soils (subfloor and outside area), have occurred. The description of historicalincidents such as past spills or operational occurrences (as documented in accordance with 10 CFR 50.75(g)(1)) is acceptable if the information is relevant to affecting unrestricted release of the facility.

The LTP describes, in a summary form, the original sautdown and current radiological and non-radiological status of the site.

The LTP site characterization is sufficiently detailed to allow NRC to determine the extent and range of radiological contamination of structures, systems, including sewer systems, waste plumbing systems, floor drains, ventilation ducts, piping and embedded piping, rubble, paved parking lots, groundwater and surface water, components, residues, and environment, including the loose and fixed (maximum and average) contamination levels and ambient exposure rate measurements of all relevant areas (structures, equipment, and soils) of the site.

The LTP should identify the survey instruments and supporting quality assurance practices used to obtain the data applicable to demonstrating that the site meets decommissioning limits.

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l l The LTP is sufficiently detailed to provide data, for planning further decommissioning activities, which include decontamination techniques, projected schedules, costs, waste volumes, dose 1 I

a'ssessrnents (including ground-water assessments), and health and safety considerations. l The LTP site characterization program is consistent with the guidance in NRC's " Draft Branch Technical Position on Site Characterization for Decommissioning," (Ref. 5), NUREG/CR-5849, ,

" Guidance Manual for Conducting Radiological Surveys in Support of License Termination,"

(Ref. 6) and NUREG-1575,

• Multi-Agency Radiation Survey and Site investigation Manual (MARRSIM)" (Ref. 7 ).

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3. IDENTIFICATION OF REMAINING SITE DISMANTLEMENT ACTIVITIES .

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The LTP describes the remaining site dismantlement activities. The regulation applicable to this area of reviewis 10 CFR 50.82(a)(9)(ii)(B).

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ACCEPTANCE CRITERIA The LTP discusses the remaining tasks associated with the decontamination and  ;

dismantlement, estimates the quantity of radioactive material to be released to unrestricted i

! areas, describes the proposed control mechanisms to ensure areas are not recontaminated, l and includes occupational exposure estimates, and radioactive waste characterization. l i

l The LTP describes in detail those areas and equipment that need further remediation to allow l the reviewer to estimate the radiological conditions that will be encountered during remediation l of equipment, components, structures, and outdoor areas.

l T*:e LTP describes the remaining dismantlement activities in sufficient detail for NRC to identify any inspection or technical resources needed during the remaining dismantlement activities.

The LTP includes a listing of the remaining activities that do not involve unreviewed safety l questions, or changes in a facility's technical specifications, and this list should be of sufficient l detail for the staff to confirm that remediated activities may in fact be carried out under 10 CFR 50.59.

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4. REMEDIATION PLANS The LTP discusses in detail how facility areas and site areas will be remediated to meet NRC

! re!aase criteria. The regulation applicable to this area of review is 10 CFR 50.82(a)(9)(ii)(C), )

l and 10 CFR Part 20, Subpart E (Ref. 3). l ACCEPTANCE CRITERIA l The LTP addresses any changes in the radiological controls to be implemented for the control of radiological contamination associated with remaining decommissioning and remediation activities.

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The LTP discusses in detail how facility areas and site areas will be remediated to meet the NRC criteria for license termination in Subpart E of 10 CFR Part 20 (Ref. 3) or the Site D'ecommissioning Management Plan (SDMP) Action Plan criteria (Ref. 8) if the site has been ,

grandfathered under 10 CFR 20.1401. Discussions should focus on any unique techniques or procedures used to evaluate the effectiveness of remediation, including any computer modeling programs.

1 If the end use of the site is for restricted release, the LTP should discuss, in detail, dose- j modeling projections and institutional controls to be put into place over the site. i

5. FINAL RADIATION SURVEY PLAN The LTP describes the final survey plan for confirming that the plant and site will meet the restricted or unrestricted release criteria. The regulation applicable to this area of review is 10 CFR 50.82(a)(9)(ii)(D), and 10 CFR 20.1501(a). The final status survey is the radiation survey performed after an area has been fully characterized, remediation has been completed, and the licensee believes that the area is ready to be released. The purpose of the final status survey is to demonstrate that the area meets the radiological criteria for license termination.

The final status survey is not conducted for the purpose of locating residual radioactivity; the historical site assessment and the characterization survey perform that function. This section of the SRP endorses the final survey status methods described in NUREG/CR-5849," Guidance Manual for Conducting Radiological Surveys in Support of License Termination,"(Ref.6) and NUREG-1575, " Multi-Agency Radiation Survey and Site investigation Manual (MARRSIM)"

(Ref. 7).

ACCEPTANCE CRITERIA The LTP is acceptable if the final survey plan addresses, in a manner consistent with NUREGICR-5849 or MARRSIM, the following items, which are not meant to be all-inclusive.

. The methods proposed for surveying all equipment, systems, structures, and soils (diagrams, plot plans, and facility layout drawings should be used to facilitate presentation), as well as a method for ensuring that sufficient data are included for a meaningful statistical survey;

• A description of the methods to be used to establish background radiation levels (variances in background radiation can be expected between structures constructed of different materials)(Ref. 8);

. A description of the Quality Assurance (QA) Program, to support both field survey work and laboratory analysis, that addresses the QA organization; training and qualification requirements; survey instructions and procedures, including water, air, and soil sampling procedures; document control; control of purchased items; inspections; control of survey equipment; handling, storage, calibration and response checks, and shipping and of survey equipment and laboratory samples; nonconformance items; corrective action; QA records; and the survey audits, including methods to be used for reviewing, analyzing, and auditing data (Ref. 9).

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• . Verification surveys used to support delineation of radiologically affected (contaminated) areas and unaffected (noncontaminated) areas; l e' The major radiological contaminants;  ;

• - Methods used for addressing hard-to-detect radionuclides; l

• Access control procedures. -

i The licensee's final radiation survey plan describes the scope of the survey, and the general  !

procedures followed, and how the plan will demonstrate that the plant and site will meet criteria l for release for license termination in 10 CFR Part 20, Subpart E (Ref 3).  !

The LTP is acceptable if the licensee has divided the impacted area into survey units. Both i NUREG/CR-5849 and MARSSIM contain methods acceptable to the NRC staff for dividing i impacted areas into survey units.

, i The LTP is acceptable if the final survey plan, consistent with NUREG/CR-5849 or MARRSIM,  !

identifies the scarining to be performed to locate small areas of elevated concentrations of l residual radioactivity to determine whether they meet the radiological criteria for license j!

termination; commits to perform scanning in each survey unit to detect areas of elevated concentrations; and establishes investigation levels for investigating significantly elevated concentrations of residual radioactivity.

The LTP is acceptable if the final survey plan address the presence of subsurface residual radioactivity. Subsurface residua! radioactivity is mainly determired by the historical site assessment, with knowledge of how the residual radioactivity was deposited.

The LTP final survey plan is acceptable if the licensee establishes, consistent with the guidance in NUREG/CR-5849 or MARRSIM, a reference coordinate system for the impacted areas. A :

reference coordinate system is a set of intersecting lines referenced to a fixed site location or benchmark. Reference coordinate systems are established so that the locations of any point in the survey unit can be identified by coordinate numbers. A reference coordinate system does not establish the number of sample points or determine where samples are taken. A single reference coordinate system may be used for a site, or different coordinate systems may be used for each survey unit or for a group of survey units

6. COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINA110N

' The licensee needs to clearly present in the LTP the radiological criteria proposed for license termination, if a licensee desires an unrestricted release per 10 CFR Part 20, Subpart E (Ref 3), or the SDMP Action Plan criteria (Ref. 5), if the site meets the requirements of 10 CFR 20.1401(b), the licensee should describe the methods to demonstrate compliance. If a licensee requests license termination under the restricted release criteria per Subpart E of 10 CFR Part 20 (Ref. 3), the LTP should desciibe in detail how the requirements of 10 CFR 20.1403, and 10 CFR 50.82(a)(9)(ii)(E) will be met. If a licensee requests license termination under the attemative radiological criteria in 10 CFR 20.1404, the LTP should describe how the requirements in 10 CFR 20.1301(a)(1),10 CFR 20.1404, and 10 CFR 50.82(a)(9)(ii)(E) will be met.  !

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l . 1 ACCEPTANCE CRITERIA For unrestricted release, the LTP is acceptable if; The licensee demonstrates that the residual radioactivity that is distinguishable from background radiation does not exceed 25 mem. (0.25 Mev) per year to an average member of the critical group over a 1000-year period, including from drinking water, j The LTP also demonstrates that residual radioactivity has been reduced to levels that  !

are as low as is reasonably achievable (10 CFR 20.1402). The LTP should describe in detail the methods and assumptions used to demonstrate compliance with the 25-mem.

per year criterion. Draft Regulatory Guide DG-4006, " Demonstrating Compliance with the Radiological Criteria for License Termination"(Ref.10) provides additional guidance, I acceptable to the NRC staff, on how to demonstrate compliance with the unrestricted release criteria. Draft DG-4006 provides guidance on conducting dose modeling, use of l generic screening methods, use of site specific parameter values and altemate mode's, ,

use of computer models, and methods for conducting a final survey. l For unrestricted release of the site under the " grand fathering" provisions per 10 CFR 20.1401(b), the LTP should describe in detail the methods and assumptions that demonstrate compliance with the SDMP Action Plan criteria (Ref.11).

1 For restricted release, the LTP is acceptable if it addresses the criteria identified below. In addition to the criteria identified below, draft Regulatory Guide DG-4006, " Demonstrating Compliance with the Radiological Criteria for License Termination" (Ref.10) provides additional guidance, acceptable to the NRC staff, on how to demonstrate compliance with license termination restrici.ed release criteria.

. The licensee demonstrates that further reductions in residual radioactivity necessary to l release the site for unrestricted use (1) would result in net public or environmental harm j or (2) were not being made because the residual levels are ALANA (20.1403(a)). j

. The licensee describes in detail the methods and assumptions that will be used to demonstrate that the licensee will provide reasonable assurance that the dose from residual radioactivity, distinguishable from background, will not exceed 25 mem. per year to a member of the critical group, over a 1000-year period, with the restrictions in place (10 CFR 20.1403(b)). l

. The licensee has made provisions for legally enforceable institutional controls that would limit the dose to the average member of the critical group to 25 mem. (0.25 Mev) per year (20.1403(b)).

. The licensee has provided sufficient financial assurance to enable an independent third party to assume and carry out responsibilities for any necessary control and maintenance of the site (20.1403(c)).

. The licensee has submitted to the NRC a license termination plan that indicates the licensee's intent to release the site under restricted conditions and tells how advice from 8

individuals and institutions in the community who may be affected by the decommissioning has been sought and incorporated, as appropriate, following analysis 1 of that advice (20.1403(d)).

. The residual radioactivity levels have been reduced so that, if the institutional controls were no longer in effect, the annual dose to the average member of the critical group would not exceed either 100 mem. (1 Mev) or, under certain conditions,500 mem. (5 Mev). If the 500 memlyr (5 Mev/yr) value is used, the licensee must (1) demonstrate achieving 100 memlyr is prohibitively expensive, not technically achievable, or would result in net harm, (2) make provisions for durable institutional controls, and (3) provide sufficient financial assurance to allow an independent third party to carry out rechecks of the controls at least every 5 years (20.1403(e)).

. If the annual dose to the average member of the critical group would not exceed 100 mem. (1 Mev) if the institutional controls were no longer in effect, a private individual, organization, or State or local govemment may be chosen as the party responsible for enforcing the institutional control.

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. If the annual dose could exceed 100 mem. (1 Mev) but be less than 500 mem. (5 Mev),

if the institutional controls were no longer in effect,10 CFR 20.1403(e) requires that a ,

more durable institutional control be used. To meet the requirement in 10 CFR i 20.1403(e), an institutional control that involves government ownership of land would be generally acceptable or an institutional control on privately owned land with a State or local govemment as the party responsible for enforcing the restriction could also be acceptable depending on the circumstances at the site.

. The licensee identifies the affected parties. According to 10 CFR 20.1403(d)(2), the licensee must provide for participation by representatives of a broad cross-section of community who may be affected by the decommissioning. Affected parties may include:

any state, local, or a federal govemment agency, other than the NRC, that has jurisdiction or responsibilities with respect to the site to be decommissioned; local community, civic, labor, or environmental organizations with an interest in the decommissioning, and whose members would be affected by the decommissbning;  ;

adjacent landowners whose property abuts the site or portions of the site to be released under restricted conditions; and any Indian tribe or other indigenous people who have relevant treaty or statutory rights that may be affected by the decommissioning of the site.

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. The licensee describes the site end use for any areas proposed for restricted l release (50.82(a)(ii)(E). I l

For license termination using attemate criteria, the LTP is acceptable if it addresses the criteria l identified below. In addition to the criteria identified below, draft Regulatory Guide DG-4006,

" Demonstrating Compliance with the Radiological Criteria for License Termination" (Ref.10) provides additional guidance, acceptable to the NRC staff, on how to demonstrate compliance with the license termination using altemate criteria.

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t The licensee proposing to use attemative criteria would have to provide a complete and comprehensive analysis of such possible sources of exposure.

l 3 The licensee would employ, to the extent practical, restrictions on site use for minimizing exposure at the site, using the provisions for institutional controls and financial assurance in 10 CFR 20.1403.

. The licensee would reduce doses to ALANA levels, based on a comprehensive analysis of risks and benefits of all viable attematives.

. The licensee would seek advice from affected parties regarding the use of attemative criteria at the site. In seeking this advice, the licensee would conduct the activities for seeking advice required by 10 CFR 20.1404(a)(4), including providing for participation by a broad cross-section of community interests who may be affected by decommissioning; providing an opportunity for a comprehensive collective discussion of the issues related to the alternative criteria by the affected parties; and providing a publicly available summary of all such discussions. As part of this process, the licensee would submit a decommissioning plan or LTP indicating how advice of individuals and institutions in the community who may be affected by the decommissioning has been sought and addressed.

. The licensee would obtain the specific approval of the NRC for the use of altemative criteria. The NRC would make its decision after considering the NRC staff's recommendations that would address any comments provided by the Environmental Protection Agency and any public comments submitted regarding the decommissioning plan or LTP. The licensee proposing to use alternative criteria has provided a complete and comprehensive analysis of such possible sources of exposure.

. The licensee describes the site end use for any areas proposed for restricted release (50.82(a)(ii)(E).

7. UPDATE OF THE SITE-SPECIFIC DECOMMISSIONING COSTS The LTP must provide an estimate of the remaining decommissioning cost for unrestricted or restricted release of the site. The LTP should compare the estimated cost with the present funds set aside for decommissioning, and how decommissioning financial assurance instruments required under 10 CFR 50.75 will be increased, if necessary. If there is a deficit in current funding, the LTP must indicate the means for ensuring adequate funds to complete decommissioning. The regulation applicable to this area is 10 CFR 50.82(a)(9)(ii)(F).

ACCEPTANCE CRITERIA The LTP decommissioning cost estimates are acceptable if they include an evaluation of the following cost elements identified below, in addition, Regulatory Guide 1.159, " Assuring the Availability of Funds for Decommissioning Nuclear Reactors"(Ref.12) provides detailed 10

8 e explanation of methods for estimating decommissioning costs, as well as accepted financial assurance mechanisms.

Cost Elements

. Cost assumptions used, including a contingency factor

. Major decommissioning activities and tasks

. Unit cost factors

. Estimated costs of decontamination and removal of equipment and structures

. Estimated costs of waste disposal, including applicable disposal site surcharges

. Estimated final survey costs

. Estimated total costs The LTP focuses on detailed activity-by-activity cost estimates.

The LTP compares the available funds for the decommissioning with the calculated total cost from the licensee's detailed cost analysis.

The LTP cost estimates for decommissioning are based on credible engineering assumptions, and the assumptions are related to all major remaining decommissioning activities and tasks.

The LTP cost estimate is acceptable if it includes the cost of the remediation action being evaluated, the cost of transportation and disposal of the waste generated by the action, and other costs that are appropriate for the specific case. The current version of NUREG-1307,

" Report on Waste Burial Charges"(Ref.13) provides guidance on estimating waste disposal ,

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8. SUPPLEMENT TO THE ENVIRONMENTAL REPORT The licensee must submit a supplement to the Environmental Report describing any new information or significant environmental change associated with the site-specific termination activities. The regulation applicable to this area of review is 10 CFR 50.82(a)(9)(ii)(G), and 10 CFR Part 51.53.

ACCEPTANCE CRITERIA The Supplement to the Environmental Report describes proposed termination activities resulting in significant environmental changes not bounded by the site-specific decommissioning activities described in the PSDAR, previously issued environmental assessment, or environmental impact statement. The Supplement to the Environmental Report will be acceptable if the discussed proposed impacts are bounded by the impacts in NUREG-0586, the PSDAR, previously issued environmental assessment, or the environmental impact I statement.

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The Supplement to the Environmental Report describes the impacts associated with those site-specific termination activities; compares the impact with previously analyzed termination activities; and analyzes the environmentalimpact of the site-specific activity.

The Supplement to the Environmental Report describes changes to the data since the issuance of the PSDAR and the updated Environmental Report - Operating License stage related to the site location, climate, demography and socioeconomic data, land use, surface water, ground water, and iota.

C. EVALUATION FINDINGS The licensee's termination plan demonstrates that the remainder of the decommissioning activities will be performed in accordance with the regulations in 10 CFR 50.82, will not be inimical to the common defense and security nor to the health and safety of the public; and will not have a significant effect on the quality of the environment.

The conclusions are:

1) The licensee has submitted the LTP as a supplement to the facility's FSAR or equivalent per 10 CFR 50.82(a)(9)(1).

2) The licensee has met the objective of providing an adequate site characterization (radiological and non-radiological) as required by 10 CFR 50.82(a)(9)(ii)(A).

3) The licensee has identified the remaining dismantlement activities that are

wcessary to complete the decommissioning of the facility / site, as required by 10 CFR 50.82(a)(9)(ii)(B).

4) The licensee has adequately identified all site areas requiring remediation and has in place an organization to safely perform the remediations as required by 10 CFR 50.82(a)(9)(ii)(C). The licensee has met the requirements of 10 CFR Part 20, and the applicable disposal site license conditions for processing, transport, and disposal of low-level radioactive waste.

5) The licensee has conformed to 10 CFR 50.82(a)(9)(ii)(D) in that the final radiation survey plan in the LTP provides assurance that residual radioactive contamination levels will meet 10 CFR Part 20, Subpart E (Ref. 3).

6) The licensee has met the requirements of 10 CFR 50.82(a)(9)(E), with respect to providing a description of the end use of the site,if restricted.

7) The licensee has met the requirements of 10 CFR 50.82(a)(9)(F), with respect to providing an updated site-specific estimate of the remaining decommissioning costs, and plans for ensuring the availability of adequate funds for decommissioning 12 l

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8) The licensee has conformed to 10 CFR 20.1402 in that the LTP demonstrates that the radiological criteria for unrestricted release will be met.

9) The licensee has conformed to 10 CFR 20.1403(a) in that the LTP demonstrates that l

further reductions in residual radioactivity necessary to release the site for unrestricted use (1) would result in net public or environmental harm or (2) were not being made because the residual levels areALANAA.

10) The licensee has conformed to 10 CFR 20.1403(b) in that the LTP demonstrates that l the dose criteria for restricted release, with the institutional controls in place, will be met.

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11) The licensee has conformed to 10 CFR 20.1403(c) in that the LTP demonstrates that l

the sufficient financial assurance is available if a third party had to assume and carry out any necessary maintenance of the site. l l

12) The licensee has conformed to 10 CFR 20.1403(d) in that the LTP demonstrates that the requirements related to public involvement criteria for license termination for restricted release have been met.

13) The licensee has conformed to 10 CFR 20.1403(e) in that the LTP demonstrates that )

the dose criteria for restricted release when the institutional controls will be met.

( 14) The licensee has conformed to 10 CFR 20.1404(a) in that the LTP demonstrates that the dose criteria for license termination using altemate criteria will be met.

15) The licensee has conformed to 10 CFR 20.1404(a)(4) in that the LTP demonstrates that the requirements related to public involvement criteria for license termination using 1 attemate criteria have been met.

16) The decommissioning attemative provides for completion of decommissioning within 60 l years, as required by 10 CFR 50.82(a)(3). If the decommissioning attemative results in j delay of completion of decommissioning for greater than 60 years, the license has i justified the delay in accordance with 10 CFR 50.82(a)(3).

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17) The licensee has met the requirements of Part 51 by providing acceptable updates to the " Environmental Report - Post-Operating License Stage."

D. IMPLEMENTATION This SRP will be used to provide information to licensees regarding the staffs plans for evaluating conformance of LTP submittats--including submittals in acceptable attemative formats-with Commission regulations.

l The provisions of this SRP apply to submittals made after the date of issuance of this SRP.

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3. - i E. ' REFERENCES

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1. U.Si Nuclear Regulatory Commission, " Decommissioning of Nuclear Power Reactors" )

(10 CFR Parts 2, 50, and 51), Federa/ Register, Vol. 61, pp. 39278-39304 (61 FR 39278), l July 29,1996. '

2. U.S. Nuclear Regulatory Commission, Draft Regulatory Guide DG-1067, " Decommissioning

' of Nuclear Power Reactors," June 1997. 1

3. U.S. Nuclear Regulatory Commission, " Radiological Criteria for License Termination"  !

(10 CFR Parts 20, 30, 40, 50, 51, 70, and 72), Federal Register, Vol. 62, pp. 39058-39092 ' i

' (62 FR 39058), July 21,1997. i

4. U.S. Nuclear Regulatory Commission, Draft Regulatory Guide DG-105 8, " Standard Format  ;

and Content of License Termination Plans for Nuclear Power Reactors," April 1998.

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5. ' U.S. Nuclear Regulatory Commission, " Draft Branch Technical Position on Site l

Characterization for Decommissioning," dated November 1994.

6. U.S. Nuclear Regulatory Commission, NUREG/CR-5849, " Guidance Manual for Conducting Radiological Surveys in Support of License Termination," June 1992. l

-1 7.~ ' U.S. Nuclear Regulatory Commission, NUREG-1575, " Multi = Agency Radiation Survey' and  !

Site Investigation Manual,". December 1997.

8. U.S. Nuclear Regulatory Commission, D' raft NUREG-1501, " Background as a Residual Radioactivity Criterion for Decommissioning," August 1994.

9. U.S. Nuclear Regulatory Commission, NUREG-1500, " Working Draft Regulatory Guide on

' Release Criteria for Decommissioning: NRC Staff's Draft for Comment," August 1994.

' 10. U.S. Nuclear Regulatory Commission, Draft Regulatory Guide DG-4006, " Demonstrating $

Compliance with the Radiological Criteria for License Termination," August 1998.

11. U.S. Nuclear Regulatory Commission, " Action Plan to Ensure Timely Cleanup of Site Decommissioning Management Sites," FederalRegister, Vol. 57, p.1338S (57 FR 13389),

April 18,1992.

12. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.159, " Assuring the Availability of Funds for Decommissioning Nuclear Reactors."

13. U.S. Nuclear Regulatory Commission, NUREG-1307, " Report on Waste Burial Charges."

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