ML20196E703

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Provides Comments on 880420 Proposal Re Matl Licensee Sites Undergoing Decommissioning
ML20196E703
Person / Time
Issue date: 05/12/1988
From: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Cunningham R, Knapp M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20150E008 List:
References
FOIA-88-514 NUDOCS 8812120065
Download: ML20196E703 (2)


Text

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a, MEMORANDUM FOR: Richard E. Cunningham, Director Division of Industrial and Medical Nuclear Safety, NMSS Malcolm R. Knapp, Director, Division of Low Level Waste Management and Decomissioning, M4SS FROM: Charles E. Norelius, Director, Division of Radiation Safety and Safeguards, Region III

SUBJECT:

MATERIAL LICENSEE SITES UNDERGOING DEC0tti!SSIONING We have reviewed your April 50,1988, proposal on the above subject matter and offer the following coments. For ease of reference our comments follow the numbering system used in your enclosure 2 to the above described memorandum.

Initial proposal For Data For Decomissioning Database Item 3. This item is not clear, as to whether the point of interest is the activities to be accomplished to decommission the site, or the fonn, quantities, or activity involved in the decontamination process. The type of activities to accomplish decomissioning may include interaction with other federal agencies or local government coordination. You should consider including this in your database.

Regarding quantities of material, the guidance should be clarified to specify the quantity allowed by the license, the estimated quantity of material to be removed to accomplish the decomissioning, or the quantities that will remain after decomissioning. It appears that the estimated quantity of material to be removed would be the most useful infonnation.

Item 4 This item raises a question as to how broad this database will be.

l We suggest that you limit your data base to those licensees which will be terminated upon decomissioning and to other unlicensed sites with known contamination (e.g., Westlake landfill).

l l Item 7. Tracking licensee performance is accomplished by periodic inspection to ensure the licensee is in compliance with their decomissioning plan. Financial information is nonnally not available to the inspector; any financial information in a data base should be basec' on public documents produced by the licensee. Your database should identify the inspections perfonned to date and the next scheduled inspection. The inspection program should define the expected inspection frequency and the expected FTE to be utilized.

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Ri' chard E. Cunningham Malcolm R. Knapp MAY 121988 Finally, we recemend that you cevelop another database regarding actions the NRC must accomplish to close out the license including any criteria for release of the facility for unrestricted use. We suggest that each action be clearly described, milestones be established, and identification of the organization responsible for completing the action be included in the database.

Database Management Issues Item 3. We recommend using an IBM compatible system with storage on a diskette and/or IBM 5520 system. The system will need to be flexible for input from 255 and regional offices with responsibility for the site.

Item 5. We recomend only specified individuals be allowed to access the system. If NMSS will do all u > dates, we recomend that one individual be responsible, wit 1 monthly input from regions.

Item 8. Much of the information is available through record review in either headquarters or the region; however, some FTE will need to be utilized to complete a search. Region III presently tracks the total staff FTE utilized for sites under decomissioning, however, we have no record of contract FTE utilized at each site.

! Finally, we suggest that your database not be restricted to materials licenses.

We understand that NMSS will assume respensibility for decommissioning of both I

power and non-power reactors. As some of these facilities will remain in safe i

storage for long periods of time, it is important that the NRC maintain a complete record of licensee and NRC activities for historical purposes.

Should you wish to discuss this issue further, we would be happy to meet with you.

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WY h Charles E. Norelius'. Director Division of Radiation Safety and Safeguards cc: A. B. Davis, RIII C. J. Paperiello, RIII T. T. Martin, RI J. P. Stohr, RII R. L. Bangart, RIV R. A. Scarano, RV ef A. Nussbaumer, GPA B. S. Itallett, RIII L. Rouse, NMSS V. L. Miller, NMSS M. C. Schumacher, RIII i

G. M. France, III, PIII l

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