ML20154N592
| ML20154N592 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1977 |
| From: | Casey Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| References | |
| TASK-TF, TASK-URFO NUDOCS 9810220031 | |
| Download: ML20154N592 (48) | |
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TESTIMONY BEFORE THE -
ENVIRONMENT, ENERGY AND NATURAL l
RESOURCES SUBCOMMITTEE OF THE !
-HOUSE GOVERNMENT OPERATIONS COMMITTEE 1
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REGARDING - l l
l DECOMMISSIONING OF NUCLEAR FACILITIES 1 l
l PRESENTED BY OR. CLIFFORD V.' SMITH, JR.
DIRECTOR, OFFICE OF NUCLEAR I MATERIALS SAFETY AND SAFEGUARDS USNRC SEPTEMBER 13, 1977 1
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I am pleased to be here today to discuss with you the Nuclear Regulatory Commission's (NRC) role in the decommissioning of nuclear facilities.
The Nuclear Regulatory Commission (NRC) is an independent agency created in 1975 by the. Energy Reorganization Act of 1974, as amended, for the purposes of regulating nuclear facilities and materials. It is charged with the mission of assuring that activities involving nuclear facilities and materials, including d'ecommissioning of facilities and termination of licenses, are conducted in a manner consistent with the protection of the public health and safety and the common defense and security of the United States. NRC also has important environmental review responsi-bilities placed on it by the National Environmental Policy Act of 1969 (NEPA)'and certain antitrust review responsibilities placed on it by the Atomic Energy Act.
Briefly I will summarize NRC's program regarding decommissioning dwelling on three aspects of that part of our activity: 1) present NRC practices in the decommissioning of nuclear facilities; 2) studies underway to refine and improve the decommissioning process; and 3) funding arrangements for decommissioning. Attachment A to this testimony contains details of reactor decommissioning with respect to regulations, acceptable alterna-tives, costs for each alternative and procedures to assure that a licensee can and will pay decommissioning costs. Because there are some limits on the NRC regulatory authority in the area of decommissioning and
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because~ present NRC practices have evolved over a number.of years, I am also including for the record brief. materials regarding the limits of NRC authority (Attachment B) and the history of: decommissioning, (Attach-ment.C).
CURRENT DECONTAMINATION ANO DECOMMISSIONING PRACTICES Pursuant to the Atomic Energy Act of 1954 as amended, the NRC regulates
' the production, use, reprocessing,. storage and disposal of source,
- byproduct and special nuclear materfals. The types of nuclear plants or facilities that are licensed by NRC include nuclear power reactors, uranium mills,'UF6 cbnversion plants, fuel fabrication plants and fuel reprocessing plants. The term " decommissioning" has been applied to the taking out of service those facilities which were licensed, or. regulated-by the NRC.
[ Costs as well as pote'ntial hazards associated with the decontamination and. decommissioning of a nuclear facility can vary by several orders of magnitude depending on the nature of the facility to be decommissioned.
-Each type of facility requires a different decommissioning approach and the final disposition of the facility will vary. For example, the relatively minor hazards associated with decommissioning of uranium fuel
. fabrication facilities requires only decontamination and disposal of equipment'for the site to be released for unrestricted use. Decommissioning
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i of a uranium mill involves long term management of radium and radon !
hazards associated with mill tailings. Decommissioning reactors or fuel reprocessing plants, on the other hand, deal with significant quantities
.of hazardous radioactive materials and therefore require considerably more effort and long term control before the site can be released for ;
unrestricted use. '
l At the end of a facility's design life or when operations cease, one of three steps may be taken: 1) all radioactive material can be removed and the site and facility released for other uses, 2) the facility may be converted to other nuclear uses, or 3) the operation may cease but amounts of radioactive material may remain which make the facility unfit for unrestricted use. For these events to take place the NRC must take one of three actions with regard to the license. They are respectively:
- 1) termination of the license with no further license in force, 2) amendment of the license for a new operation, or 3)'the licensee may request the facility license be converted to a license authorizfng possession of the inoperative facility or the remaining radioa::tivity or both. Any one of these events requires a separate and complete NRC review of the decommissioning or conversion plan of the licensee.
NRC does require that the licensee address his plans for decommissioning of the facility at the time of the initial licensing of the operation.
The specificity of the license conditions regarding decemmissioning vary
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4-somewhat depending on the type of facility, the nature of the operation and the license, the options available, the costs and the environmental impacts. , i
' Reactors The decommissioning of nuclear reactor facilities has been relatively well developed and is routinely considered in the licensing process.
The NRC presently examines various decommissioning plans, costs and environmental impacts prior to the issuance of an _ operating license for a reactor facility. Decommissioning alternatives presently acceptable to NRC include, mothballing, entombment, prompt removal / dismantling or a combination of any of the three. Mothballing involves removal of all ;
fuel and source material, the disposal of all liquid and solid waste and placing the facility in a state of protective storage. Entombment requires similar treatment and additionally the radioactive materials and components are encased (usually in concrete). Removal and disman-l tling requires that all radioactive structures, components and systems l
be disposed of such that the site can be released for unrestricted use.
In each licensing case NRC must be satisfied that feasible decommis-
- l. sioning alternatives do exist and that the applicant possesses or has the capability to provide the necessary funds to completc the task.
i' j At termination of nuclear reactor operation it may be advantageous to the licensee to request of the NRC a possession-only license to allow l
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time- for radioactivity remaining in components to decay. This type of license permits possession.of the facility and remaining radioactive ,
materials but continues to impose requirements upon the licensee to ensure that proper surveillance and procedures are followed to maintain the non-operating facility in a safe condition is used for cases such as this. The licensee remains responsible for.the safe disposition of fuel, radioactive components, and other radioactive source material. !
Radiation monitoring, environmental surveillance, and appropriate plant ;
security procedures are required to ensure the public is not endangered.
I Fuel Cycle Facilities I Nuclear. fuel cycle plants that support reactors require some form of l
decommissioning before the facilities or the sites can be released for !
alternative'uses. The licensed fuel cycle facilities in question are i uranium mills, UF .
6 conversion plants, fuel fabrication plants and fuel !
reprocessing plants. Because of the low hazards associated with uranium i
contamination of components and systems of the front end of the fuel cycle, the standard procedure for-decommissioning is decontamination of the facility and disposal of unusable equipment in accordance with the NRC staff's guidelines for release for unrestricted use. (See Attachment D.)
I The NRC is currently preparing a Generic Environmental Impact Statement i
(GEIS) on uranium milling. Management of : nill tailings, after milling l
operations cease, about 600,000 tons /yr of low specific activity (see l
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10 0 Attachment ~B), is the major consideration in decommissioning of these I*
. facilities. The GEIS will-assess the environmental impact of uranium
- milling operations, including management of uranium mill tailings, and provide an opportunity for public' participation in decisions concerning any proposed changes in NRC regulations or regulatory authority based on
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this assessment.
The draft GEIS is scheduled to be issued in August 1978.
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l until the GEIS is issued aiid new regulations implemented, NRC is = taking a conservative approach with respect to renewing licenses and granting !
new licenses for uranium mills.
For new applications, NRC is requiring l applicants to develop and commit to a tailings management plan as a R
license condition. Implementation of the tailings management plan is... _ .
tintended to reduce the impact of the tailings to essentially the same
' impact as occurs at that site with the material in its natural state.
- l. In addition, NRC is requiring that the applicant provide a financial
. surety arrangement to assure that the tailings management plan will be i
carried out.- With regard to existing licenses, NRC is requiring that a L. tailings management plan and financial surety arrangement be committed l-to before license renewal as a license condition. (See Attachment E for I details.)
For ' fuel cycle facilities, other than mills, the staff is requiring as a license condition that new major fuel cycle applicants and applicants u -
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for license renewals provide decommissioning. plans and financial arrange- I
-ments'for: defraying these expenses. -Additionally, the staff is exploring what-statutory or regulatory changes are needed to formalize these arrangements. The NRC does not plan to codify details of financial
- arrangements until after a study on financial surety arrangements now being carried out as part of the G.EIS on uranium milling is completed, I since most'of the considerations dealt with in that study.will also be applicable to fuel' cycle licenses.
CURRENT STUDIES REGARDING DECOMMISSIONING l
'Although we believe that present practices of decommissioning are. adequate to' protect the public health and-safety, the NRC'has initiated a number of studies of the environmental effects, radiological effects, costs, and appropriate radioactivity limits for.each of the currently accepted methods of decommissioning nuclear reactor and fuel cycle facilities.
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.Present studies include:
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- 1. A contract with Battelle Memorial Institute-Pacific Northwest l Laboratories (PNL) entitled, " Safety and Costs Related to Decommis-sioning Light Water Reactors." The principal objective of this
' study is to provide information on the technical status, safety, c'osts and radiological. hazards associated with the decontamination and decommissioning of pressurized water reactors and boiling water L !
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reactors. ~A final report on the decontamination and' decommissioning of pressurized water reactors is scheduled for completion in 1978.
A similar study for boiling water reactors is expected to be completed approximately one year later.
2.' PNL also has a contract with NRC entitled, " Safety and Costs Related to Decommissioning Nuclear Fuel Cycle Facilities." The principal purpose of this study is to develop comprehensive engineer-
, ing information on the environmental effects, radiological effects, .
. costs and appropriate radioactivity limit for each of the currently ,
accepted methods of decommissioning n'uclear fuel cycle facilities.
The following types.of nuclear facilities will be studied:
a .' Light water reactor fuel reprocessing plants.
- b. Small mixed oxide fuel fabrication plants.
- c. Uranium mills,
- d. Uranium fuel fabrication plants. >
- e. Low-level waste burial grounds.
- f. Uranium purification and UF 6 e nversion plants.
A final report on the first of these, decommissioning of fuel reprocessing plants, is scheduled for completion shortly.
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- 3. The Division of Environmental Impact Studies at Argonne National Laboratory is assisting NRC in the preparation of a' Generic Environ- I mental Impact Statement on Uranium Milling. This study will: ,
- a. ' assess the environmental impacts of uranium milling; i i
- b. provide information on which to determine the need for addi- !
tional regulatory requirements for uranium mills with the emphasis on management of mill tailings; and
- c. . support any rule making __and/or modifications of statutory ~
authorities-which may be determined to be necessary by the Commis'sion.
1 Additional studies on decommissioning are in the planning stage.
-One proposed study would evaluate nuclear facility design concepts l
that could facilitate' decontamination and decommissioning. The l purpose of the study would be to identify design changes that might reduce environmental impacts, radiological effects, and costs associated with decommissioning of nuclear facilities, i
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FUNDING FOR DECOMMISSIONING 1
. Estimated Costs for' Decommissioning Reactors I In a statementM otthe Advisory Committee on Reactor Safeguards (ACRS) submitted by the NRC,-the staff has shown that if a sinking fund were )
set up with annual payment.of $255,000 (for mothballing a BWR), sufficient-funds would be generated in 30 years to cover decommissioning and long term maintenance. This cost is equivalent to .04 mills /kw-h and equates to about 0.1% of the cost of generating electric power which would have a levelized cost of 4 40 mills /kw-b for the period 1985-2015. For the entombment and dismantling options the annual costs would be $377,000
.and $1,126,000,;respectively, which equates to 0.15% of power costs for entombment"and 0.5% for. dismantling. 'For delayed dismantling after.
about.100 yrs, the 30 year annual sinking fund' payments Would be adequate to cover the costs of removal and dismantling of radioactive structures.
It should be mentioned that advancements in technology might improve the economics of decommissioning.
Ee Thstatement to the ACRS was based upon a study by the Atomic Industrial Forum (AIF) entitled "An Engineering Evaluation of
' Nuclear Power Decommissioning Alternatives." The AIF study, based upon 1975 dollars, estimated decommissioning costs from
$2.3 million to over $30 million.
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i Fuel Cycle Facilities .
Fuel cycle costs account for a substantial portion (28-36%) of the total- -'
cost of generating electricity.
Decommissioning costs are estimated at less than $4.0 million for LWR fuel fabrication plants, UF 6e nversion plants and uranium mills. Costs
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for decontaminating and dismantlement of fuel reprocessing plants are -
i estimated at approximately $60 million. Decommissioning costs of fuel !
cycle facilities should add only a small percentage (less than 1%) to H the cost of the fuel.
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Funding Mechanisms The NRC is seeking to insure that the costs of decommissioning commercial nuclear facilities does not place unfair burdens on future generations..
The Commission is committed to a program that will insure that decommis-sioning costs are not inadvertently left to the responsibility of the local, State or. Federal government. Current NRC practice is to require bonds for uranium mills. The GEIS on uranium milling will include an evaluation of alternative financial arrangements for mill tailings waste management. The objective is to develop viable means to assure that the costs of decontamination, reclamation and environmental monitoring are
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provided for. -It is expected that.results from the study of uranium mills will be applicable to decommissioning other types of licensed facilities.
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O O i We were asked-to address in today's testimony the Public Interest Research Groups petition for regulations on funding decommissioning. On July 5, 1977 the six citizen and environmental groups involved filed a i
petition for rulemaking with NRC. The petition requests NRC "to initiate {
rulemaking to promulgate regulations for nuclear power plant decommis-sioning, which would require plant operators to post bonds, to be held in escrow, prior to each plant's operation, and would insure that funds will be available for proper and adequate isolation of radioactive material upon each plant's decommissioning."
The Commission published a notice of receipt of the petition for rule-making in the Federal Register on August 8,1977 in order to obtain public commentes. Since the time period for public comments is still in effect, the Commission has not made a decision to accept or deny' the petition. NRC certainly agrees that plans for decommissioning must be included in the decision making process at the time of the review for the initial operating license for all nuclear facilities. The petition request to require the posting of bonds prior to issuance of a license is consistent with present uranium mill licensing practices. However, for reactors, the NRC believes that the imposition of specific financial plans and/or technical plans at the time of, licensing might not always be warranted. What is warranted is the assessment that the licensee is both technically and financially capable of a safe and sound decommissioning procedure before the license is granted.
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' ACTIVITIES RELATING TO ABANDONED SITES ,
l- ' Another area'of major concern realtes to those former Government owned facilities on' previously licensed facilities that are no
- longer operating and which were decontaminated and decommissioned prior to establishment of present NRC guidelines and policies.
Attachment F describes these activities, their status and the 4
requirements that may be necessary to assure the public health and safety.
Summary !
To summarize, the NRC'is cognizant of the issues associated with decommis-
' sioning nuclear facilities. The existing regulations and licensing E. practices require licensees to' provide adequate protection to the health t
and: safety of the public' from a decommissioning action, and to provide j for the necessary funding if required. Studies are ongoing to further assess' our approach to decommissioning.for all types of facilities.
, The l principal objectives of these studies is to identify and develop any additional decommissioning criteria with respect to engineering, radio-L _ logical effects, environmental impacts and costs that may be needed.
i Funding studies indicate that decommissioning costs add very little (probably less than 1%) to the cost of generating electricity. A funding study is presently ongoing to evaluate alternative financial
[ . arrangements to provide funds for decommissioning actions and thus
' reduce future financial burdens.
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.Upon completion of the PNL studies, the GEIS on uranium mills and the '
funding. study, we will be in a position to develop more specific regula-tory requirements (and seek additional legislative authority if necessary) regarding decommissionings with respect to assuring the public health and safety and the cost effectivenes of funding mechanisms.
Abandoned sites are being investigated to determine if further decontami-natio'n is warranted. This will be accomplished by a review of existing
. documentation and if necessary onsite inspections.
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- Radioactivity Concerns l
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The final dispositon of a facility, such that it may be abandoned and the site released for unrestricted use, is accomplished when the '
radioactive materials have either been removed or the radioactivity has decayed to levels that pose no danger to the public. Until the j site.f s determined to be free of radiological hazards to the .public the~ possession-only license is in effect, and the responsibility for the site remains with the licensee. Radioactivity may be present as surface contamination of plant components and structures, or as internal )
activation of components and structures.
I When considering the decommissioning of light-water cooled nuclear !
l u plants the most significant radionuclide is cobalt-60, an activation' product which emits gamma ray energy from the stainless steel cladding l
of the pressure vessel and core components. The intensity of these !
l l emissions detennines the remote operations and personnel shielding I requirements for cutting the vessel and internals into pieces for shipping to burial locations. Radioactive isotopes of nickel and iron, from the vessel and internals, are also sources of gamma ray energy as well as beta particles and x-rays. Cobalt is, however, the overriding gamma ray source, and the other emissions introduce no particular shielding problems. After about 100 years the total !
j- dose to workers and shielding requirements are minimal during I
disassembly and removal of the vessel internals. Shippage of l
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REACTOR DECOMMISSIONING l
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The NRC regulations require that each license to construct and operate a reactor facility be issued for a specific period. This !
period of time may not exceed 40 years from the date of issuance of ;
i the construction permit. Upon expiration of the operating period, I or at a prior time, the licensee may request either an extension or termination of the license. An application for extension would be assessed on both a safety and environmental basis in essentially the same manner as an application for license of a new reactor unit.
At termination of nuclear reactor operation it maybe financially
, advantageous to the licensee to request of the NRC a possession-only license. A possession-only license continues to impose requirements upon the licensee that ensure proper surveillance and procedures are followed to maintain the'non-operating facility in a safe condition.
The licensee is responsible for the safe disposition of fuel, radioactive l components, and other radioactive source material. Radiation monitoring, environmental surveillance, and appropriate plant security procedures are required to ensure the public is not endangered.
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dismantled and cut up material to a burial facility at that time should present no radioactivity-related problems.
The elapse of an indefinite period of time is required for the unrestricted use'of certain activated components of a shutdown facil ity. This is due to the long-lived, easily shielded, radiation
- from isotopes of nickel. -
Decommissioning Al ternatives Regardless of the route taken for the retirement of a nuclear power reactor the following steps would be taken during the decommissioning activities:
- 1. Unused and spent fuel, and all in-core nuclear source material
.would be removed from the site and shipped to off-site locations !
for. storage or disposal. This is part of normal reactor operations, 1
and poses no unusual technical. problems. '
- 2. Spent resin materials, solidified radioactive liquid waste, and other {
non-fixed radioactive materials such as contaminated scrap would be packaged for shipment to off-site facilities. This ;
is also part of normal operations, and poses no unusual technical problems. I l
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- 3. . Surface decontamination of radioactive components by using appropriate _ chemical agents may be-undertaken as necessary. Since the components would probably be dis-carded, as low level radioactive weste or as nonradioactive
. waste, strong chemical agents can be used and effective surface decontamination achieved. )
- 4. All non-contaminated systems of the plant would also be drained of fluids.
The major issue in decommissioning, as discussed previously, is the disposition of fixed materials and components of the facility, which have,become radioactive by neutron activation. If it is desired, even r
the most highly radioactive components of the primary system (the pressure vessel and ts internals) could be dismantled and shipped off-site for disposal . There are, however, economic considerations and other factors, which will be discussed later, which may make it desirable to postpone the ultimate dismantling. Some development work may be required for this phase of the decommissioning operation if early dismantling is desired. However, past experience in decommission-ing the Elk River facility, the only nuclear power plant to be completely
- dismantled, provides evidence that such methods could be used on modern, larger, reactor facilities. The 22 MWe boiling water facility was shut-l down' in 1968, and dismantled during the period 1971 to 1974.
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for 'small government-owned demonstration plants. Permanent entombment I or' permanent mothballing do not appear to be viable alternatives for
'large nuclear ~ power plants.
. Dismantling' This alternative involves the removal of all radioactive !
components and structures from the site. ' The site.would then be released for unrestricted use and the possession-only license tenninated. 1 The' future. disposition of the remainder of the plant- the non '
radioactive systems - and the general plant site is the prerogative of the' owner.
Assessment of Alternatives Since 1960 about 50 research-type reactor facilities have been i
decommissioned. Thesel low power units have usually been dismantled ,
shortly after shutdown. A few are in a mothballed status and probably will ultimately be dismantled at a relatively small_ cost.
Fifteen small power and test reactor facilities have been decommissioned. Four of these units were government owned demonstration
- plants; three were entombed and one was dismantled. Of the eleven
-licensed units, ten'were mothballed and one was dismantled. ,
The NRC does not currently require that a specific decommissioning alternative be selected at the time of licensing,' but an examination is made of various decommissioning' plans, costs, and environmental impact prior to ~ issuance of an operating license for a commercial power reactor or test reactor. We assure in each case that feasible
- decommissioning alternatives, including complete dismantling, exist
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- An outline of the three basic decommis.cfoning alternatives is discussed ' bel ow.
Mothballing - Under this alternative, -subsequen to the steps . itemized previously, the facility is left effectively in as "as is", intact, condition and-put-in a state of protective storage. Access control-must be provided. The plant security fence may be mair.tained; the NRC '
has accepted various arrangements of barriers, intrusion alarms, and security guards for control of plant access. Additionally, posting
- must be made of radiation areas within the facility. Locked barriers,
- -welded closures, or the necessity to remove heavy structures would be used to hinder any person from gaining access to a radiation area. I The licensee is required to perfonn periodic inspections, radiation q
surveys of the- facility, and environmentai sampling.
Entombment - This alternative is also a state of protective storage.
This approach involves encasing all radioactive materials within the containment structure.
1 To allow future access to the equipment, the entombing enclosure may be constructed of reinforced, formed, concrete using original-plant concrete shielding walls and foundation as part of the entombment 4 barrier.
Periodic inspections, radiation surveys, and environmental sampling :
are required, similar to the mothballing option. Security guards would probably .not be required. Entombment has only been used in the past
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I and that the applicant either possesses or has reasonable assurance of. obtaining the necessary funds. We do not require bonds or setting L 'asidelof. any contingency funds; and we do not impose any particular plan as a. condition of the operating. license.
The NRC currently has studies . underway to independently evaluate the environmental and safety aspects, and costs of the various decommissioning l al ternatives. For large nuclear electric facilities it I L.
L appears that it may be desirable to postpone the removal of the highly radioactive components to allow time for substantial decay. This j
.would preclude ~ the need for. using remote handling and dismantling _
. equipment, and special personnel shielding techniques..
A recent study sponsored by the Atomic-Industrial Forum ( AIF) provided cost estimates for the three decommissioning alternatives, and. for initial protective storage for about 100 years prior to
-. dismantling. At that time manual disassembly and removal of the radioactive materials could be done.
l The NRC. staff has-conducted a preliminary economic analysis using-the basic cost data from the AIF study. These economic assessments will be revised, as appropriate, upon completion of the on-going
..NRC ' sponsored studies on decommissioning.
i The economic analysis by the staff was based on the following l primary assumptions.
- l. 1. The cost estimates for the various decommissioning alternatives were adjusted by an escalation of 5% per year from the 1975 cost base of the AIF study.
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- 2. For those options involving dismantling.the non-radioactive equipment was not removed.
- 3. A 1200 MWe' nuclear unit, started up in 1985, was
' decommissioned after 30 years, in 2015.
- 4. Sinking funds were used during the 30 year period to acquire the needed decommissioning cost.
.5. The interest rate on sinking funds was 10%.
- 6. - A security force was used for' the mothballing option. .
- 7. For those decommissioning options involving delayed dismantling, a 100-year period was allowed for radioactive decay; dismantling is assumed in the year 2115.
In summary, the 'results of the analysis for the cost of decommissioning l a single boiling water facility, which is projected to cost more-than a pressurized water unit, are as follows for each of five options or
. combinations:
1 L Mothballing - This option involves decommissioning in 2015, after 30
- years of operation, assumes perpetual surveillance including manned security.
Annual payments to a sinking fund of $255,000 for the 30 year period would be required. This cost is equivalent to 0.04 mills (0.004 cents) per kilowatt-hour (kW-h) . This equates to about 0.1% of the cost of generating electric power excluding distribution and marketing cost.
The levelized cost of generating electricity is about 40 mills per kil owa tt-hour.
Entombment-- This option, after 30 years of operation, assumes I perpetual surveillance and maintenance without continuous manned security. 'The yearly sinking fund payments, for thirty years, are about $377,000. This is equivalent to 0.06 mills (0.006 cents) per l kW-h or about 0.15% ~of the cost of generation.
Dismantling - Immediate dismantling requires an estimated $185,000,000 1
projected cost in the year 2015 using, as stated earlier, a 5% yearly cost escalation. Sinking fund payments over 30 years, assuming a 10% investment return, are $1,126,000 yearly. This equates to a cost of 0.18 mills per kW-h or about 0.5% of the generation cost.
4 Mothball-Delayed Dismantling - This involves removal of the radioactive
- equipment in 2115 after 100 years, with manned security from 2015 to 2115. The yearly sinking fund payment of $255,000 for perpetual i surveillance (mothballing) is sufficient to pay for dismantling. The cost is about the same as the first option of permanent mothballing.
Entombing-Delayed Dismantling --The costs are essentially the same as the entombing option - about 0.15% of the 30 year generating costs.
These staff analyses are, as stated, quite preliminary. They do however indicate that the cost of decommissioning is quite nominal.
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O o Future Evaluations & Plans L . .. .
l The cost to decommission'is a small fraction of the total cost of the generation:of nuclear-electric power. Decommissioning could include L
complete restoration of the site. This would include removal of all nuclear and non-nuclear equipment, demoliton and removal of all above-grade concrete and metal .- structures. Non-radioactive metal would have.
salvage value; structures could be used as earth-fill material.
Radioactive equipment must be cut-up and shipped to' burial sites - this would be required of reactor vessel materials even after 100 years of decay i because of long-lived isotopes of nickel.
About 35 years elapses from the issuance of an operating license until I I
i decommissioning. Requiring a specific plan at the licensing stage would j
- not be realistic because other more desirable methods and procedures will probably be developed due to improvements in technology in the 35 years.
It' appears that our present practice of assuring that various alternatives
. have been considered provides for the necessary assurance that economically viable methods of decommissioning.will be available when needed. l The-NRC reviews every application for a reactor license to determine j whether there is reasonable assurance that the applicant has the financial
- ability to operate the reactor facility and to shut down the facility and main-tain it in, a safe condition. A nuclear power plant licensee must also file an l
annual financial report with the NRC until we have determined that the
. license may be terminated.
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Federal and State regulatory commissions have historically treated plant decommissioning and maintenance costs as recoverable expenses through rates chargeable to customers. It is reasonable to assume that the decommissioning and subsequent maintenance costs would be charged to operating expenses either in the year they are incurred or amortized over a period of years according to the policy of the rate making regulatory authorities.
The NRC has a program underway that will establish more explicit' decommissioning costs and requirments. The program will provide a basis for establishing any new procedures or requirements needed for greater assurance that adequate reactor decommissioning funds will be available. This program includes the :ollowing elements.
-1. . An independent study of the environmental and safety aspects, and allied costs of each alternative is in progress. The effort is expected to be completed in 1979.
- 2. Further review and analysis of the study by the Atomic Industrial Forum is in progress. To date, our studies, in general, support t
the conclusions of this evaluation.
- 3. Studies are expected to be completed later this year that will serve as baseline dose information to establish criteria for unrestricted re-use of equipment and materials containing limited radionuclide contamination.
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L O O Summary The past practices of the NRC have provided both reasonable assurance I
of'the availability of funds for decommissioning and options for the safe :
l 1/
retirement of nuclear-electric p' ants. We believe that it is prudent to provide flexibility to plant's sners for future disposition of facility hardware and structures, and site use or restoration. With the exception ,
of tne activated materials which do pose unique disposal problems the issues related to the ultimate dispositon of the facility and site are similar to: those of other industrial process facilities. Over the long I tenn, perhaps 2 to 5' generations hence, technological advancements, land values, and other economical and environmental facts may very well dictate courses of dispositon or use that differ greatly from those that may be deduced by today's perspective.
From our ongoing studies and . assessments, which includes work at the Battelle Laboratories and the Oak Ridge National Laboratory, we expect to establish new procedures and guidance on reactor decommissioning. Our on-going work will also be supplemented by studies by ERDA related to the decomnissioning of government facilities.
Our evaluations will include more refined economic analysis thao R
. possible at this time. We plan to consider in our cost studies l
~
f/ " Statement to the Environment and the Atmosphere Subcommittee of the House Committee on Science and Technology Regarding Nuclear Reactor Decommissioning," USNRC, June 15, 1977. ,
O o 1 i
the availability ~ of specific means, such as bonding or trusts, to ,
1 further assure that adequate funding is provided for ultimate disposition i
~
of reactor facilities. Such an escrow was suggested in a recent petition by the Public Interest Research Group and other related organizations.
In about 2 years the results of our evaluations with expanded criteria and requirements are expected to be available. We should tailor our requirements so that over the long term, as periodic l
reassessments are made, we can readily adjust our course to accommodate a changing technology, a changing environment, and societal needs.
9 l
O O Naturally Occurrina And Accelerator-Produced Radioactive Material (NARM)
The NRC currently has jurisdiction over byproduct material, source _ material and special nuclear material as defined in the Atomic Energy Act of 1954, as amended. However, there is another group of radioactive materials over which NRC does not presently exercise licensing _ authority. This group is
- referred to as naturally occurring and accelerator produced radioactive material'or NARM. NARM includes the following subgroups: ,
- 1. Primordial and cosmic ray induced radionuclides (e.g., 226Ra, I4C, "K),and i.
- 2. Radioactive materials produced as a result 'of nuclear interactions in accelerators. .
i In March of 1976, the NRC formed a-Task Force to review the regulation of NARM. The Task Force report, published and distributed for public comment i on July 20, 1977, recommended that NRC seek legislation which would give it the authority to-regulate naturally occurring radioactive material not pre- l sently regulated by NRC and radioisotopes produced in accelerators. Comments were solicited and raceived on the report, and are being analyzed before i
final recommendations are made.
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.O O ATTACHMENT B EXCEPTIONS TO NRC REGULATORY AUTHORITY RELEVANT TO DECOMMISSIONING The NRC does not regulate most ERDA facilities, naturally occurring and accelerator produced radioactive materials and facilities and materials licensed under the Agreement State program authorized by Section 274 of the Atomic Energy Act.
ERDA Facilities .
~ERDA and its prime contractors remain exempt from NRC regulatory authority except under Section 202 of the Energy Reorganization Act of 1974 which gives NRC specific authority to license ERDA demonstration reactors and facilities used primarily for the receipt or storage of high-level radioactive wastes resulting from licensed activities. In addition, NRC has authority to license " Retrievable Surface Storage Facilities and other facilities authorized for the express purposes of subsequent long-term storage of high-level radioactive waste generated by the Administration which are not used for,-or a part of, research and development activities." NRC has no regulatory authority over decommissioning of other ERDA facilities.
l
O O Agreement State Programs In Agreement States, the NRC has relinquished and the State has assumed regulatory authority over byproduct, source and small quantities of special nuclear material. -The fuel cycle facilities which would be subject to Agreement States regulation under the agreements are uranium mills and UF6 e nversion plants. Presently no UF conversion plants are located in 6
the Agreement States and there are no present plans to do so. Under the Agreement States program, the' States apply regulations and criteria generally consistent with those applied by NRC and the Agreement States generally follow NRC guidance relating to decommissioning of uranium mills. Also, in the case of decommissioning of nuclear reactors and other NRC licensed facilities which are not released for unrestricted use, the Agreement -
States could issue a byproduct license for residual radioactive material i in the structural components of an inoperative facility.
. . . ~ . . - . . . - . . _ - _ . . . - - - - . . - - - _.- - .- .-.
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ATTACHMENT C i
' HISTORICAL ASPECTS OF DECONTAMINATION AND DECOMMISSIONING Reactors j' Since 1960, 5 licensed nuclear power plants,'4 demonstration plants and l
-6 licensed tesc reactors have been decommissioned. . Table 1 (attached)
. based'upon information supplied by the NRC Staff summarizes the status of these' plants. . Additionally, about.50-research type reactors have been decommissioned mostly by the dismantling alternative. The alternatives that'have been employed for decommissioning are mothballing, entombment b or dismantling. Typically the choice of the alternative was based upon l
cost and environmental- considerations. Much of the experience generated
!. from these decommissionings is directly; applicable to current plant 1
- l. des' i gns. After. termination'of the license to operate a reactor, a license l may be issued for the possession.of-the facility and residual radioactive l . material in the. reactor components or both. This type of license is termed. a possession-only" license. -
L Fuel Cycle Facilities
- 1. Uranium Mills With respect to' uranium milling _ operations, the large volume of mill tailings (approximately.600,000 tons) cnr.stitute the major decommis-
~
l Lsioning problem. 1The concentration of radioactivity in the tailings is f
.e. s .-.,,nm, , , , , , , . , , , , . - . , - .
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i low, about 0.0006 Ci of Ra 226 per ton of ore.. However quantities of i
1 tails involved are large and the decay of Radium-226 results in the l 1
. emission of Radon-222. If tailing piles are not properly stabilized and j controlled, small quantities of radioactivity can enter pathways to man.
The management of mill tailings has received increasing attention and i interest in recent years from Federal and State agencies and from environ-mental conservation groups and increased efforts are being made to reduce exposure to radioactivity. However, the risk involved from uranium mill tailings, particularly with regard to the long-term considera-
.tions, has not yet been fully or adequately defined and is still subject to differing opinions among the scientific community and the public. We believe stabilization and long-term control of these tailings to be ,
1 necessary, particularly with respect to the need for preventing the unauthorized use of tailings and to control the blowing of tailings from the impoundment area. The need and extent of additional waste management l practices other than stabilization and control still remains to be defined.
Decommissioning of a uranium mill itself simply involves decontaminating the facility and associated systems of relatively low level contamination from natural uranium and its daughters and/or removal and dismantlement of the facility as appropriate.
1
.1 :' o- O other facilities have been decontaminated and released for unrestricted use, e.g. , Gulf United Nuclear's mixe& oxide facility at Pawling, N.Y.
and Union Carbide's fabrication plant at Lawrenceburg, Tennessee. ;
Because of the difference in size, type and age of LWR fuel fabrication facilities the cost estimate for decommissioning will. vary considerably.
Because of the low hazards associated with uranium oxide contamination of components and systems the standard procedure for decommissioning fuel fabrication plants is decontamination of the facility and disposal of unusable equipment-in accordance with the staff's guidelines for release for unrestricted use. (See Attachment D.)
- 4. Fuel Reprocessing Plants Fuel [reprocessingplantsareusedtorecover'uraniumandplutoniumfrom
-fuel _that has been used in the generation of electricity from nuclear power reactors. Three commercial fuel reprocessing plants have been built in the United States, but none of these plants is currently reproc-essing spent fuel.
The technology associated with the decontamination of reprocessing plants is available today based upon experience obtained from numerous pilot plant programs at Oak Ridge and Hanford where systems involving the reprocessing of irradiated fuel have been decontaminated and equipment disassembled. A substantial amount of this information is directly
[
i
- 2. UF6 Conversion Plants l There are two (2) plants licensed by NRC to convert natural uranium L oxides to uranium hexafluoride to be used as feed for the enachment plants.. To date, no UF e6 nversion plants have been decommissioned; r i
l however, the NRC staff anticipates no significant problems with decon-taminating this type of facility, based upon the relatively low radio-logical hazard associated with natural uranium. The decommissioning l task is normally one of removing surface contamination from facilities and equipment and disposal of excess components, before reler.se for unrestricted use. i'
- 3. Fuel Fabrication Plants l There are currently nine ura 'um fuel fabrication plants licensed by NRC l
that have the capability of performing all or part of the fuel fabrication ;
L operations for Light Water Reactors (LWR's). Three of the plants use
. enriched UF6 as feed material and produce completed LWR fuel elements.
j 'Two of the facilities use enriched UF6 as starting material to produce uranium powder and/or pellets which are then shipped to sister plants where the fuel assemblies are fabricated. Two other producers of uranium dioxide fuel are currently ~ shut down because of the lack of demand, and 2
i one of these is preparing decommissioning plans.
l- Although only one LWR fuel fabrication plant has been decommissioned
- (Gulf United Nuclear's facility at New Haven, Connecticut) a number of
1 .
o o 5- .
4 relatable to decontamination and dismantling of future fuel reprocessing
~
plants.
As mentioned in. testimony before the Environment, Energy, and Natural
- Resources Subcommittee on March 8, 1977, the Nuclear Fuel Services (NFS) plant in West Valley, New York is the only commercial reprocessing plant
-that has been operated in the United States. .The NFS situation has been cited as an example of the.high costs of' decommissioning nuclear facilities.
NRC does not believe that the NFS situation is directly translatable to the present or projected nuclear power industry for two reasons. First, a national _ policy (10 CFR 50, Appendix-F), on long-term management of high-level waste generated from spent ~ fuel reprocessing plants was. .
established in 1971 after the plant began operation.
Secondly, the task _ g of conve'rting the neutralized high-level liquid' wastes in storage at NFS c to a solid form suitable for final disposal is much more difficult and expensive than it would be for the acid type wastes of future reprocessing ,
1 plants. It would, therefore, be inappropriate to equate the NFS situation with the latest criteria and policies.
d 1
i 9 , . , , - .rw- g. - -- - m,. ., -
r - - , -. ,- _w- r
- 4
Reference:
"Deconmissioning and Decontamination of Licensed Reactor Facilities and' Demonstration Nuclear Power Plants," by P. B. Erickson and G. Lear, U.S. NRC, presented at Conference on Decontamination and Decommissioning in Idaho Falls, Idaho, August 19-21, 1975.
A byproduct license may be issued by Agreement State per 10 CFR 150.
icT use of a continuous security force was not required by the NRC because continuous manned security was provided other on-site activities that were unrelated to the decommissioned reactor. If such a security force was not
- present, the NRC may have stipulated manned security or other additional access control measures.
]dA possession-only license permits possession of a reactor facility but not its operation.
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e T
I. . . , ,
l TABLE 1. EXPERIMENTAL AND DEMONSTRATION REACTOR DECOP911SSIONING HISTORYa Reactor Reactor Facility Reactor Thennal Protective Type of Status of Monitoring Storage and Location Type Rating, MW Decommissioning License System Measures-(-
C6.}. Pressure tube 65 -Mothballing Periodic Parr, SC heavy water Byproducg Welded closure, to state surveillance locked doors, security fence-Pathfinder BWR 190 Mothballing with Byproduct-Sioux Falls, SD Continuous Welded closure, nuclear steam plant per.10 CFR superheat securfty. security fence conversion 30 force FERMI 1 Sodium cooled. 200 Mothballing Monroe Co., Mich. fast Possgssion Continuous Locked doors,.
only securfty security -fence force Peach Bottom 1 Gas cooled 115 Mothballing Possession--
York Co., Penn. graphite.
Continuous Not yet only securfty established moderated '
force .,
VL-. -- BWR 50 Mothballing with Alameda Co., CA Possession Continuous Locked doors,-
steam plant only security fence conversion secur[ty force
- NASA Plunbrook Light water - . 60 Mothballing' . Possession Continuous Sandusky, Ohio
- LLocked doors, only securfty, security . fence force GE EVESR- .BWR with il7 Mothballing Alameda Co., CA Possession- Continuous Locked doors,.
nuclear. only securfty . security fence
.; _ .. superheat force Saxton','PA ~ PWR' 23.5 Mothballing
' Possession- Lintrusion Welded closure, only~: alarms: ' locked doors, wanrdVhArea-
a TABLE 1. EXPERIMENTAL'AND DEMONSTRATION REACTOR DECOMMISSIONING llISTORY (Cont'd)
Reactor Reactor Protective Facility Reactor Thermal Type of Status of Monitoring Storage and Location Type Rating, MW Decommissioning License System Measures SEFOR Sodium 20 Mothballing Byproduct Intrusion Welded closure, Strickler, cooled,' fast to state alarms locked doors, A$sas security fence Westinghouse Tank 60 Mothballed -
Possession Continuous Locked doors, Test Reactor only secur[ty. security fence Waltz Mill, PA force B&W Pool -
6 Partial Byproduct Not required Not required Lynchburg, VA dismantling per 10 CFR 30 itallam Sodium cooled- 256 Entombing Operating Not required Welded closure, Hallam, Neb. - graphite .
authorization concrete' cover,J modera ted terminated weatherproofed Piqua Organic 45.5- Entombing Operating Not required Welded closure I Piqua, Ohio cooled and authorization concrete cover, moderated terminated waterproofed BWR with 50 Entombing , Operating Not required Welded closure, Ricon, Puerto nuclear. authoriza tion concrete cover, Rico superheat~ terminated locked doors, security fence.,
Elk . River BWR '58.2_ Dismantling & Operating Not required Not required Elk River, partial-. authorization -
Minn. conversion terminated m
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[. O O 2-The instructions in this guide in conjunction with Table I specify the radioactivity and radiation exposure rate limits which should be used in accomplishing the decontamination and survey of surfaces or premises and equipment prior to abandonment or release for unrestricted use. The limits in Table I do not apply to premises, equipment, or scrap containing induced radioactivity for which the radiological considerations pertinent to their use may be different. The release of such facilities or items from regulatory control will be considered on a case-by-case basis.
- 1. The licensee shall make a reasonable effort to eliminate residual contamination.
- 2. Radioactivity on equipment or surfaces shall not be covered by paint, plating, or other covering material unless contamination levels, as determined by a survey and documented, are below the limits specified in Table I prior to applying the covering. A reasonable effort must be made to minimize the contamination prior to use of any covering.
- 3. The radioactivity on the interior surfaces of pipes, drain lines, or ductwork shall be determined by making measurements at all traps, and other appropriate access points, provided that contamination at these locations is likely to be representative of contamination on the interior of the pipes, drain lines, or ductwork. Surfaces of premises, equipment, or scrap which are likely to be contaminated but are of l
s
O O such size, construction, or location as to make the surface inaccessi-ble for purposes of measurement shall be presumed to be contaminated in excess of the limits.
- 4. Upon request, the Commission may authorize a licensee to relinquish possession or control of premises, equipment, or scrap having sur-faces contaminated with materials in excess of the limits specified.
This may include, but would not be limited to, special circumstances such as razing of buildings, transfer of premises to another organiza-tion continuing work with radioactive materials, or conversion of facilities to a long-term storage or standby status. Such requests must:
- a. Provide detailed, specific information describing the premises, equipment or scrap, radioactive contaminants, and the nature, extent, and degree of residual surface contamination,
- b. Provide a detailed health and safety analysis which reflects that the residual amounts of materials on surface areas, to-gether with other considerations such as prospective use of the premises, equipment or scrap, are unlikely to result in an unreasonable risk to the health and safety of the public.
O O ATTACHMENT D GUIDELINES FOR DECONTAMINATION OF FACILITIES AND EQUIPMENT PRIOR TO R,ELEASE FOR UNRESTRICTED USE OR TERMINATION OF LICENSES FOR BYPRODUCT, SOURCE, OR SPECIAL NUCLEAR MATERIAL U.S. Nuclear Regulatory Commission Division of Fuel Cycle and Material Safety Washington, D.C. 20555 NOVEMBER 1976 tot 3Diotip- W.
O O
- 5. Prior to release of premises for unrestricted use, the licensee shall make a comprehensive radiation survey which establishes that contamina-tion is within the limits specified in Table I. A copy of the survey report shall be filed with the Division of Fuel Cycle and Material Safety, USNRC, Washington, D.C. 20555, and also the Director of the Regional Office of the Office of Inspection and Enforcement, USNRC, having jurisdiction. The report should be filed at least 30 days prior to the planned data of abandonment. The survey report shall:
- a. Identify the premises,
- b. Show that reasonable effort has been made to eliminate residual contamination.
- c. Describe the scope of the survey and general procedures followed.
- d. State the findings of the survey in units specified in the instruction.
Following review of the report, the NRC will consider visiting the facili-ties to confirm the survey.
.s TABLE I ACCEPTABLE SURFACE CONTAMINATION LEVELS NUCLIDES" AVERAGE b ,c.f b ,d,f b MAXIMUM REMOVABLE .e.f U-nat, U-236, U-238, and 5,000 dpm a/100 cm2 15,000 dmp a/100 cm 2 1,000 dpm a/100 cm2 associated decay products Transuranics, Ra-226. Ra-228, 100 dpm/100 cm 2 300 dpm/100 cm2 Th-230, Th-228, Pa-231, Ac-227, I-125, I-129 Th-nat, Th-232, Sr-90, 1,000 dpm/100 cm2 3,000 dpm/100 cm 2 200 dpm/100 cm2 Ra-223, Ra-224, U-232, I-126, a
I-131, I-133 m
Beta-gamma emitters (nuclides 5,000 dpm Sy/100 cm 2 15,000 dpm sy/100 cm 2 1,000 dpm sy/100 cm2' with decay modes other than alpha emission or spontaneous fission) except Sr-90 and others noted above.
a Where surface contamination by both alpha- and beta-gamma-emitting nuclides exists, the limits established for h alpha- and beta-gamma-emitting nuclides should apply independently.
b As used in this table, dpm (disintegrations per minute) means the rate of emission by radioctive material as determined by correcting the counts per minute observed by an appropriate detector for background, efficiency, and geometric factors associated with the instrumentation.
c Measurements of average contaminant should not be averaged over more than 1 square meter. For objects of less surface area, the average should be derived for each such object.
d The maximum contamination level applies to an area of not more than 100 cm2 ,
TABLE I (Cont'd) 2 "The amount of removable radioactive material per 100 cm of surface area should be detennined by wiping that area with dry filter or soft absorbent paper, applying moderate pressure, and assessing the amount of radio-active material on the wipe with an appropriate instrument of known efficiency. When removable contamination on objects entire of less surface should surface area is determined, the pertinent levels should be reduced proportionally and the be wiped.
The average and maximum radiation levels associated with surface contamination resulting from beta-gamma g
emitters should not exceed 0.2 mrad /hr at 1 cm and 1.0 mrad /hr at I cm, respectively, measured through not more than 7 milligrams per square centimeter of total absorber.
s On S
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ATTACHMENT E
_ ... _. _ .. _.NRC STAFF URANIUM .._
MILL TAILINGS MANAGEMENT BackgroMa A major expansion in the uranium industry is taking place. Many times more uranium will be extracted in the upcoming decades than has been extracted so fa r. This requires that the NRC examine very closely the past problem areas encountered in the uranium industry and take action to assure that they are not repeated.
The first major' portion of the industry within the licensing jurisdiction of the NRC is uranium milling. The major problem encountered in past milling operations is the management of tailings generated by the milling process.
Although the concentration of radioactivity in the tailings is relatively low, control measures are necessary because of the large quantities involved and because of the long half-life of the parent radionuclides that are present.
The management of mill tailings has received increasing attention and interest in recent years from involved federal and state agencies and from environmental conservation groups.
This interest has resulted from studies carried out during the last decade which have indicated that uranium mill tailings, if not properly managed and controlled, could present a potential'public health hazard. The most vivid example, of course, is the situation that occurred in
v .
O O Grand Junction. The remedial actions determined necessary to correct the misuse of tailings in the construction of homes, schools, and other public structures are continuing at substantial cost to the Federal Government and the State of Colorado.
In addition, final technical resolution and financial responsibility for the disposition of tailings at the 22 " inactive" sites being evaluated by ERDA will further increase public, state, and local as well as congressional concern with prevention of similar problems in the future.
It is incumbent on NRC and the uranium industry to assure that current and future licensed milling operations do not result in similar situations.
Towards this end, the NRC staff has developed performance objectives for an acceptable tailings management program based on the latest technology available.
Position The staff is of the opinion that an acceptable tailings management program will vary depending on site or region specific parameters, such as geology, hydrology,.and meteorology. Viable methods of tailings management for a specific mill location may include classic impoundment behind a dam, deep mine burial, open pit mine burial, specially excavated pit burial, or even elimination of radioactive waste by process variations.
o 0 Considering the many variables involved, the staff will use the following performance objectives to determine the adequacy of proposed site specific tailings management programs.
Siting and Design'
- 1. Locate the tailings isolation area remote from people such that population exposures would be reduced to the maximum extent reasonably achievable. '
- 2. Locate the tailings isolation area such that disruption and dispersion by natural forces is eliminated or reduced to the maximum extent reasonably achievable.
~
- 3. Design the isolation area such that seepage of toxic .naterials into the groundwater system would be eliminated or reduced to the maximum extent reasonably achievable.
During Operations
- 4. Eliminate the blowing of tailings to unrestricted areas during normal operating conditions.
Post Reclamation
- 5. Reduce direct gama radiation from the impoundment area to essentially background.
O O
- 6. Reduce the radon emanation rate from the impoundment area to about twice the emanation rate in the surrounding environs.
- 7. Eliminate the need for an ongoing monitoring and maintenance program following successful reclamation.
- 8. Provide surety arrangements to assure that sufficient funds are available to complete the full reclamation plan.
Implementation All objectives will be considered and satisfied during the review of proposed tailings management programs for new milling operations. .
Current licensee's tailings management programs will be reviewed to determine the best way to apply. objectives 4 through 8 to the extent practicable.
During the course of license renewal reviews, the locations of existing tailings areas will be reviewed considering objectives 1 through 3 to determine if sufficient cause exists to require an alternate disposal location for tailings generated by future milling operations and the relocation of existing tailings at the time of mill decommissioning.
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O O
ATTACHMENT F NRC ACTIVITIES RELATING TO ABANDONED SITES URANIUM MILLS, In response to a congressional mandate in 1974. ERDA, EPA, and the States involved embarked upon a joint evaluation of problems associated with inactive mill tailings sites. A total of 22 inactive mill sites were identified which contained an estimated 25 million tons of tailings.
The evaluation was divided into two phases. The first phase, which is completed, was a preliminary evaluation to determine site conditions s and served as the basis for a detailed engineering assessment where necessary. The second phase includes an evaluation of the problems, an examination of alternative solutions, and the preparation of plans for and cost estimates of remedial actions.
ERDA was designated by Congress as the lead agency with respect to the assessment of the health impact of mill tailings at inactive sites and for developing plans and recomendations for remedial actions for these sites, where appropriate. The Phase II studies are nearing completion, and reports for all of the sites should be available from ERDA within the next several months. When these studies are completed, ERDA will propose legislation to Congress for any necessary remedial actions.
The Nuclear Regulatory Commission staff is working closely with ERDA to define what NRC's involvement should be in these remedial action programs.
At the present time, NRC's participation involves: (a) working with ERDA and EPA in developing standards and criteria for mill tailings disposal sites and (b) review and coment on ERDA recommendations for remedial actions.
, y
O O
OTHER FUEL CYCLE FACILITIES There are current programs at ERDA and NRC to evaluate facilities, other than mills, that previously handled radioactive material and have since been released for unrestricted use.
In June 1974, the Atomic Energy Commission (AEC) instructed its field offices to identify sites possibly contaminated with radioactivity as a result of being used for research and development activities in the early days of the Nation's atomic energy program.
Many of the sites were used more than 30 years ago as part of the World War II Manhattan Project. Others were used by the AEC from the late 1940's through the 1960's. The sites were either owned by, or under contract to, the Government; and many are presently being used for other purposes.
Prior to their release from Government control, the sites,were to have been decontaminated according to health guidelines then in use. In many cases, however, the radiological records to document the extent to clean-up actions were incomplete or are presently missing.
Thus far, about 80 sites have been identified for review; of these, ERDA estimates approximately 40 may require radiation surveys by its contrac-tors and 10 to 15 sites may require some remedial action.
Based on its knowledge of these sites ERDA does not believe that any of
. them pose an immediate health and safety problem. However, some sites may contain licensable quantities of material and thus require an
O O interface with NRC or the State to determine what course of action should be taken where questions concerning possession of this material are involved.
Because of the potential problems identified by ERDA at the former Government-owned and AEC contractor sites, NRC is comitted to review the files of AEC licenses terminated prior to 1965 to assure itself that adequate documentation exists to show that the sites were properly decommissioned. Since these files number in the thousands and staff time is limited, NRC is actively seeking a contractor to perform this service. This program, hopefully, will get underway this fiscal year; and the file search will be complete by the end of next year.
. _ _ _ _ _