ML20198D161
| ML20198D161 | |
| Person / Time | |
|---|---|
| Issue date: | 12/30/1997 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Blough A, Mallett B, Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| REF-WM-3, RTR-REGGD-GENERA NUDOCS 9801080144 | |
| Download: ML20198D161 (17) | |
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l December 30, 1997 1
MEMORANDUM TO: A. Randolph Blough, Director Division of Nuclear Materials Safety, R l Bruce A. Mallett, Director Division of Nuclear Materials Safety, R Il Cynthia D. Pederson, Director Division of Nuclear Materials Safety, R Ill Ross A. Scarano, Director Division of Nuclear Materials Safety, R IV Jack W. Roe, Director Division of Reactor Program Management, NRR Joseph A. Murphy, Director Division of Regulatory Applications, RES FROM:
John T. Greeves, Director [ ORIGINAL SIGNED BY:]
Division of Waste Management, NMSS
SUBJECT:
REVIEW OF THE REVISFD DRAFT STANDARD FORMAT AND CONTENT GUIDE OF A LICENSE TERMINATION PLAN FOR POWER REACTORS (10 CFR PART 50.82(a)(9))
I have attached a revised copy of the " Standard Format and Content of a License Termination Plan for Power Reactors (10 CFR Part 50.82(a)(9))." As a result of the comments that were provided in response to our requested review, the draft guide required euensive changes to address your comments, and to reflect the revised site specific radiological criteria for license termination effective August 20,1997. Because of the changes made to the draft guide, I would like to provide you an opportunity to review the revised draft guide. If you have any additional comments, I am requesting your comments be provided by January 14,1998.
Atta.chment: As stated
Contact:
Larry Pittiglio, LLDP/DWM (301)415-6702 DISTRIBUTION. Central File LLDP r/f DWM r/f NMSS r/f PUBLIC RJohnson
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December 30, 1997 MEMORANDUM TO: A. Randolph Blough, Director Division of Nuclear Materials Safety, R l Bruce A. Mallett, Director Division of Nuclear Materials Safety, R il Cynthia D. Pederson, Director Division of Nuclear Materials Safety, R lli Ross A. Scarano, Director Divinion of Nuclesr Materials Safety, R-IV Jack W. Roe, Director Division of Reactor Progrcm Management, NRR Joseph A. Murphy, Director Division of Regulatory Applications, RES u
FROM:
John T. Greeves, Direg s
Division of Waste Ma ement, NMSS
SUBJECT:
REVIEW OF THE REVISED DRAFT STANDARD FORMAT AND CONTENT GUIDE OF A LICENSE TERMINATION PLAN FOR POWER REACTORS (10 CFR PART 50.82(a)(9))
I have attached a revised copy of the
- Standard Format and Content of a License Termination Plan for Power Reactors (10 CFR Part 50.82(a)(9))." As a result of the comments l
that were provided in response to our sequested review, the drafi guide required extensive changes to address your comments, and to reflect the revised site specific radiological criteria for license termination effective August 20,1997. Because of the changes made to the draft guide, I would like to provide you an opportunity to review the revised draft guide, if you have any additional comments, I am requesting your comments be provided by January 14,1998.
1 l
Attachment:
As stated L
Contact:
Larry Pitti lio, LLDP/DWM 0
(301) 415-6702 I
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t REGULATORY GUIDE (Task 97 XX)
STANDARD FORMAT AND CONTENT OF A LICENSE TERMINATION PLAN FOR NUCLEAR POWER REACTORS (10 CFk 50.82(a)(9))
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TABLE OF CONTENTS I
. A. INTRODUCTION............................................
1. Ge ne ra l.................................................
1 H. CONTENT Of LICENSE TEIUdlNATION PLAN....................... 2 I
- 1. General lnformation......................................... 2
- 2. Site Characterization..........
3
- 3. Identification of Remaining Site Dismantlement Activities................. 3
. 4. Re media tion Pla ns............................ -............. 3
- 5. Final Radiation Survey Plan............,....................... 4
- 6. Approach Used to Demonstrate Compliance with the Radiological Criteria for License Termination................................. 5 i
- 7. Description of Site End Use for Restricted Release. Documentation llow Public Consultation Requirements. Institutional Controls, and Financial Assurance Requirements for License Termination for Restricted Release or Alternate Criteria 6
Were Met
- 8. Updated Site-Specific Decommissioning Cost......................... 6
- 9. Supplement to the Environmental Report............................ 7 C. l M PLEM ENTATI ON........................................... 7 D. FO RM AT.................................................
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- 1. Graphical Presentations
- 2. Physical Specificaticas....
..................................8
- 3. Procedures for Updating or Revising Pages........................... 8 E. REFERENCES............................................... 9 iii o
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A. INTRODUCTION
- 1. General On July 29,1996, the Commission published amendments to its regulations in 10 CFR Parts 2,50, and $1 (61 FR 39278)(Ref 1), prescribing specific criteria for decommissioning nuclear power reactors, effective August 28,1996. The rule specifies applicable requirements for reactors that are permanently shut down and have no fuel in the reactor vessel by climinating, revising, or extending operating reactor requirements commensurate with the importance to safety. Reactors that are permanently shut down with no fuel in the vessel present a significantly reduced risk to the public.
Decommissioning activities for power reactors may be divided into three phases: 1) initial activities; 2) major decoinmissioning and storage activities; and 3) license tennination activities. Regulatory Guide DG-1067, " Decommissioning of Nuclear Power Reactors," dated May 1997 (Ref. 2) describes methods and procedures that are acceptaMe to the Nuclear Regulatory Commission staff for implementing the requirements of the final rule that relate to the ini ial activities and the major phases t
of decommissioning.
For Phase 3, the rule (10 CFR 50.82(a)(9)) specifies that an application for license termination must be accompanied or preceded by a License Tennination Plan (LTP),
which is subject to review and approval by NRC. 10 CFR 50.82(a)(9)(i) states that at least 2 years before termination of the license, the licensee must submit an LTP. The lil'P approval process is by license amendment and requires that a public meeting be held nes the site and any hearing held in relation to this plan (LTP) would fall either under Subpart G or Subpart L of Part 2. If the fuel has been permanently removed from the Part 50 facility to an authorized facility, a hearing for the LTP would be in-accordance with Subpart L. Conversely, if a LTP were submitted while the spent fuel was stored within the Part 50 facility, Subpan G of 10 CFR Part 2 would apply. NRC anticipates that normally any hearing at the license termination stage will be under Subpart L, but that it is conceivable the facts could be such that Subpart G would still apply. Similarly, although circumstances could arise where the LTP would be pan of the PSDAR, the NRC would not expect that to be the usual case. Once the LTP is approved,10 CFR 50.59 would apply to allow the licensee to make certain changes that do not result in an unreviewed safety question or changes to the technical specifications, l
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The LTP should include either of the following requests:
Release of facility and site for unrestricted use; or Release of the facility and site under restricted use conditions.
On July 2' 1997, the Commission published amendments to its tegulations in 10 CFR Parts 20, 30,40,50,51,70, and 71 (62 FR 39058) (Ref 3) prescribing specific radiological criteria for license termination, effective August 21,1997.
These radiological criteria apply to all sites except those sites that were
" grandfathered" per 10 CFR 20.1401(b).
For the most part the LTP will be a Anal site characterization, dose assessment, remediation, and survey plan. The LTP must be submitted as a supplement to 'he licensee's Final Safety Analysis Report (FSAR) or equivalent document.
H. CONTENT OF LICENSE TERMINATION PLAN
- 1. General Information The licensce's name and address, license number, and docket number should agree with the most recent license. 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 release of the site, with any supporting information required:
A site characterization; Identification of remaining site dismantlement activities; Platis for site remediation; Detailed plans for the final radiation / release survey; Approach used to demonstrate compliance with the radiological criteria for license termination; Description of site end use for restricted release, and documentation as to how public consultation, institutional controls, and financial assurance requirements for license termination for restricted release or alternate criteria were met; An updated site-specinc estimate of remaining decommissioning costs; and A supplement to the environmental report, pursuant to 10 CFR 51.53, describing any new infonnation or significant environmental changes associated with the licensee's proposed termination activities.
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- 2. Site Characterization The pumose of providing site characke information is to ensure that the final surveys are conducted to cover all arc.o,o,ae contamination previously existed, remains, or has the potential to remain.
The licensee can docket the entire site characterization package separately at any time prior to submittial of the LTP, and reference it in the LTP, or it can be submitted as an integral part of the LTP. The detail of the site characterization should allow NRC to detennine the extent and range of radiological contamination of stmetures, jstems, components, residucs, soils, and surface or groundwater. The site characterization should be suf0ciently detailed to provide data for planning further oecommissioning activities, which include decontamination techniques, projected schedules, costs, waste volumes, dose assessment, and health and safety consideratiora. The guidance in NRC's
- Draft Branch Technical Position on Site Characterization for Decommissioning," dated November 1994 (Ref. 4) provides an example of an acceptable site characterization.
The LTP should include an historical description (including dates, types of occurrences, krations in and outside of the facility) of events, such as radiological spills, burials, or other radiological accidents / incidents, that resulted, or could have resulted, in contamination of structures, equipment, laydown areas, or soils (subnoor and outside area).
- 3. Identification of Remaining Site Dismantleinent Activities The LTP should discuss the remaining tasks associated with the decontamination and dismantlement, estimation of the quantity of radioactive material to be released to unrestricted areas, and the proposed control mechanisms, person-rem estimates, and radioactive waste characterization. Those areas and equipment that need further rernediation shou!d be described in suf0cient detail to allow the reviewer to estimate the radiological conditions that will be encountered during remediation of equipment, components, and structures. The details of this section should be of sufficient detail for the NRC to identify any inspection or technical resources needed during the remaining dismantlement activities.
- 4. Remediation Plans The LTP should address any changes in the previously approved radiological control program to be used for the control of radiological contamination associated with remaining decommissionine and remediation activities.
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The LTP should discuss in detail how facility areas and site areas will be remediated to meet NRC criteria for license termination in 10 CFR Part 20, Subpart E (Ref 3) or the Site Decommissioning Management Plan (SDMP) Action Plan criteria if the site has been granfathered. The relevant "grandfathering" is under the 1997 mle on residual ciiteria for license termination (Ref. 3). Discussions should focus on any t.nique techniques or procedures used to conduct the remediation or evaluate its effectiveness, including any computer modeling programs.
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- 5. Final Radiation Survey Plan The LTP should describe the final survey plan for confirming that the plant and site will meet restricted or unrestricted release criteria in 10 CFR Part 20, Subpart E (Ref.
- 3) or SDMP Action Plan criteria for heense ternunation. The items identified below that should be included in the final radiation survey plan are:
a) The proposed appicach for surveying all equipment, systems, structures, and the soils (diagrams, plot plans, and facility layout drawings should be used to facilitate resentation) and a method for assuring that sufficient data are included for a numingful statistical survey; b) A description of the methods to be used to establi:.h background radiation levels (variances in background radiatien can be expected between stmetures constructed of different materials)(Ref. 5);
c) A description of the Quality Assurance (QA) Program to support both field survey work and laboratory analysis addressing: 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 and shipping of survey equipment and laboratory samples; nonconformance items; corrective action; QA records; and survey audits, including methods to be used for reviewing, analyzing and auditing data (Ref. 6);
d) Verification surveys used to support delineation of radiologically affected and unaffected areas; c) Identification of major radiological contaminants; O Methods used for addressing hard-to-detect radionuclides; and g) Access control procedures.
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- 6. Approach Used to Demonstrate Compliance with the Radiological Critrria for License Termination if a licensee requests unrestricted release of the site per 10 CFR Part 20 Subpart E, and the site that has not been grandfathered per 10 CFR 20.140t(b) (Ref. 3, Statement of Consideration), Section F.2 (62 FR 39080)), the LTP should demonstrate that the residual radioactivity, distinguishable from background radiation, does not exceed 25 mrem (0.25 mSy) per year to an average member of the critical group over a 1000 year period, including from drinking water, and that residual radioactivity has been reduced to levels that are as low as reasonably achievable (10 CFR 20.1402). The LTP should describe, in detail, the approach and assumptions used to demonstrate compliance with the 25 mrem criteria, if a licensee requests unrestricted release of the site under the "graadfathering" provisions per 10 CFR 20.1401(b), the LTP should describe, in detail, the approach and assumptions to demonstrate compliance with the SDMP Action Plan criteria.
If a licensee requests license termination under restricted release criteria per 10 CFR Part 20. Subpart E (Ref 3), the LTP should describe, in detail, the approach ar ]
assump' ions used to demonstrate that the licensee will provide reasonable assurance that the dose from residual radioactivity, distinguishable from background, will not exceed 25 mrem /y to a member of the critical group over a 1000 year period with the restrictions in place,10 CFR 20.1403(b), and when the restrictions fail, meet the seguirements of 10 CFR 20.1403(c)(1) or (2).
If a the licensee requests license termination using alternate radiological criteria in 10 CFR 20.1404, the LTP should describe, in detail, the approach and assumptions used to demonstrate that public heahh and safety would continue to be protected.
Specifically, the LTP should demonstrate that the dose from all man-made tources combined, other than medical, would be unlikely to exceed the 100 mrem annual vaine set forth in 10 CPR 20.1301(a)(1) (10 CFR 20.14N(a)(1)), that the licensee has employed, to the extent practicable, restriesions on site use to minimize exposures at the site, and reduced doses to ALARA levels taking into consideration any detriments, such as traffic accidents, expected to potentially result from decontamination or waste dispoul.
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- 7. Description of Site Eud Use for Restricted Release, Documentatior,llow Public Consultation Requ;temer,, Institutional Controls, and Financial Assurance Requirements for License Terminati., for Restricted Release on Alternate Criteria Were Met if a licensee requests license te~nination under restricted release criteria or alternate criteria per 10 CFR Part 20, Subpan II(Ref 3), the LTP should discuss site end use, the institutional contrc!s to be put in place, and the required maintenance of the controls (including financial assurance for any necessary control and maintenance of the site) until the residual radioactivity meets unrestricted release criteria or for the life of the facility.
If a licensee requees license tennination under the restricted release criteria of 10 CFR 20.1403 or the alternate criteria under 10 CFR 20.14(4, the LTP should document how the public consultation requirements of 10 CFR 20.1403(d) or 10 CFR 20.1404(a)(4) have been addressed.
- 8. Update Site Specific Decommissioning Cest The license termination plan must-a) Provide an estimate of the decommissioning cost, and b) Compare the cost with the present funds set rside for decommissioning. If there is a deficit in present funding, the LTP must indicate the means for ensuring adequate funds to complete ?.he decommissioning.
Regulatory Guide 1.159, " Assuring the Availability of Funds for Decommissioning Nuclear Pi. ors" (Ref. 7) provides detailed explanation of methods for estimating decommmw. ting costs, as well as accepted financial assurance mechanisms. If the LTP indicates that assurance of funding is to be provided by use of a surety method, insurance, or other guarantee, then the financial assurance instrument must remain in effect until the Commission has terminated the license. The decommissioning cost estimates should include an evaluation of the following elements, as related to cost:
Cost lilements Cost assumptions used, including contingency factor Major decommissioning activities / tasks Unit cost factors F.stimated equipment /stmetural decontamination and removal cost Estimated waste disposal cost, including applicable disposa; site surcharges 6
Estimated final survey cost Estimated total cost
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The cost estimate should focus on the remaining work, detailed retivity by activity, for each measurable activity associated witn the decommissioning--mcluding the cost of later, materials, equipment, energy, and services. No credit for the salvage value of egoipment should tm taken.
- 9. Supplement to the Enviromnental Report if the licensce's proposed termination activities result ;a significant environmental changes not bounded by the decommissioning activities described in previously issued environmental assessments, or environmental impact statements, the licensee should submit a Supplement to the Environmental Report describing the impacts associated with the site-specific termination activities.
The Supplement to the Environmental Report should:
a) Describe in detail the impact of the site-specine termination act vity; i
b) Compare the impact with previously analyzed tennination activities; and c) Analyze the environmental impact of the site-specific activity.
C. IMPLEMENTATION This Standard Fonnat and Content Guide (SF&C) will be used to provide information to licensees regarding the staff's plans for evaluating conformance of LTP submittals--
including submittals in acceptable alternative fonnats--with Commission regulations.
The provisions of this SF&C apply to submittals made after the SF&C's date of issuance.
D. FORMAT
- 1. Graphical Presentations Graphical presentations such as drawings, maps, diagrams, sketches, and tables should be employed if the infonnation may be presented more adequately or conveniently by such means. Due concern should be taken to ensure that all infonnation so presented is legible, that symbols are denned, and that scales are not t
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reducui to the extent that visual aids are necessary to interpret pertinent items of infonnation. These graphical presentations should be located in the section where they are primarily discussed, iteferences used may appear either as footnotes to the page where discussed or at the end of each chapter.
- 2. Physical Specifications
- a. Paper site (1) Text pages: 8 l/2 x 11 inches.
(2) Drawings and graphics: 81/2 x 11 inches; however, a larger size is acceptable provided the finished copy, when folded, does not exceed 8-1/2 x 11 inches.
- b. Paper stock and ink. Suitable quality in substance, paper color, and ink density for handling and reproduction by microfilming or image-copying equipment,
- c. Page margins. A margin of no less than I inch should be maintained on the top, bottom, and binding side of all pages submitted.
- d. Printing (1) Composition: text pages should be single spaced.
(2) Typeface and style: should be suitable for microfilming or image-copyhig equipment.
(3) Iteproduction: may be mechanically or photographically reproduced. All pages of text should be printed on both sides and the image printed head to
- head, Ilinding. Pages >hould be punched for standard three hole loose-leaf binders.
c.
- f. Page numbering. Pages should be numbered with the digits corresponding to the chapter followed by a hyphen and a sequential number e.g., the third page of Section 4 should be numbered 4-3. Do not number the entire repon sequentially.
- g. Table of contents. A table of contents and an index of key items should be included.
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- 3. Procedures for Updating or Revising Pages Data and text should be updated or revised by replacing pages. The changed or revised portion on each page should be highlighted by a " change indicator" mark consisting of a bold vertical line drawn in the margin opposite the binding margin. The line shauld be of the same length as the portion actually changed.
All pages submitted to up< late, revise, or add pages to the report should show the date of change and change or amendment number. A guide page listing the pages to be inserted and the pages to be removed should accompany the revised pages. When major changes or additions are made, a reviwd table of contents should be provided,
!!. REFERENCES
- 1. Final Rule: Decommissioning of Nuclear Power Reactors,61 FR 39278, (July 29,1996).
- 2. U.S. Nuclear Regulatory Commission Draft Regulatory Guide DG 1067,
" Decommissioning of Nuclear Power Reactors," May 1997.
- 3. Final Rule: Radiological t'riteria for I.icense Tennination,62 FR 39058, July 21,1997.
- 4. U.S. Nuclear Regulatory Commission, " Draft firanch Technical Position on Site Characterization for Decommissioning," (NMSS/DWM), November 1994.
- 5. U.S. Nuclear Regulatory Commission, NUREG 1501, "Hackground as a Residual Radioactivity Criterion for Decommissioning," Draf t, August 1994.
- 6. U.S. Nuclear Regulatory Commission, NUREG-1500 " Working Draft Regulatory Guide on Release Criteria for Decommissioning: NRC Sialf's Draft for Comment," August 1994.
- 7. U.S. Nuclear Regulatory Conunission, Regulatory Guide 1.159, " Assuring the Availability of Funds for Decommissioning Nuclear Reactors."
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l MEMORANDUM TO: A. Randolph Blough, Director Division of Nuclear Materials Safety, R l Bruce A. Mallett, Director Division of Nuclear Materials Safety, R ll Roy J. Canlano, Acting Director Division of Nuclear Materials Safety, R ill Ross A. Scarano, Director Division of Nuclear Materials Safety, R IV Jack W. Roe, Acting Director Division of Reactor Program Management, N.
Jo eph A. Murphy, Director Division of Regulatory Applicationp, ES FROM:
John T. Greeves, Director [pMiGINAL SIGN BY;l Division of Waste Manag ent, NMSS
SUBJECT:
REVIEW OF THE RE ISED DRAF TANDARD FORMAT AND CONTENT GUIDE,dF A!.lCENS TERMINATION PLAN FOR POWER REACTORS (10CFR PAR f 5 2(a)(9))
I have attached a revised co y of the "St ard Format and Content of a License Termination Plan for Power Reac rs (10 CFR rt 50.82(a)(9))," As a result of the comments that were provided in response our requ review, the draft guide required extensive changes to address your com ents, and reflect the revised site specific radiological criteria for license termination effec e August
,1997 Because of the changes made to the draft guide, I would like to provi you an ortunity to review the revised draft guide, if you have any additional comment I am req sting your comments be provided by January 14,1998.
Attachment:
As state
Contact:
Larry Pittiglio, LLD DWM (301)415-6702 DISIRlBUTION: Central la LLDP r/f DWM r/f NMSS r/f PUBLIC RJohnson
- See previous concur nce Path & File Name: S:\\DWM\\LLDP\\CLP\\LTR.SFC S:\\DWM\\CLP\\SFCR LLDP*[
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YES _ N 1
Category: Proprietary _ or CF Only _
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YES 4 0 1 LSS:
YES _ NO 1-Delete Ole aner distribution: Yes._, No x__
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e0 Bruce A, Mallett Director Division of Nuclear Materials Safety, R-Il t
Roy J. Caniano. Acting Director Division of Nuclear Materials Safety. R-Ill I
Ross A. Scarano. Director Division of Nuclear Materials Safety, R-IV f
Jack W,- Roe Acting Director Division of Reactor Program Management, NRR Joseph A. Murphy, Director Division of Regulatory Applications 4ES FROM:
John T. Greeves, Director [0RI HAL S1 NED BY:]
Division of Waste Managemen' NMSS/
SUBJECT:
FEVIEW0FTHEREVISEDD8ATSTAfAIRDFORMATAND CONTi.NT GUIDE OF A LICENSE TE INATION PLAN FOR POWER REACTORS '10 R PART 50.82(a)(9))
I have attached a revised copy of t "Stan rd Format and Content of a License Termination Plar, for Power Reactors CFR P t 50.82(a)(9))." As a result of the 1
comments that were provided in resp se to r requested review, the draft guide required extensive changes to address your omments and t) reflect the revised site specific radiological criteria for licen e termin ion effective August 20, 1997.
Because of the changes made to the draft gui
, I woul like to provide you an opportunity to review the revised draft guide.
If yo ave any dditional comments. I am requesting your comments be provided by January 14, 98.
Attachment:
As stated
Contact:
Larry Pittiglio, DP/DWM j
(301) 415-6702 DISTRIBUTION: CentralF)ie LLDP r/f,
DWM r/f NMSS r/f PUBLIC
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I have attached a r ised copy of the " Standard Format and Content of a License Termination Plan or Power Reactors (10 CFR Part 50.82(a)(9))." As a result of the comments at were provided in response to our requested review, the draft guide requir d extensive changes to address your comments.
Because of the changes made t the draft guide. I would like to provide you an opportunity to revie the revised draft guide.
If you have any additional comments, I am requ sting your comments be provided by October 8. 1997.
Attachment:
As s ated
Contact:
Larry Pittigi
. LLDP/DWM (301 415-6702 DISTRIBUTION: Central ile LLDP r/f DWM r/f NMSS r/f PUBLIC JSurmeier Path & File Name:
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DWM NAME LP[kdlib/cv EK TJ N on Mckey JGreeves DATE 9/6/97 9/$/97 9/897 9////97 9/ /97 0FFICTAL RECORD COPY ACNW: YES NO x
Category:
Proprietary or CF Only IG
- YES NO x
LSS YES NO x
Delete file after distribution:
Yes No x L