ML20210R370

Informs That NRC Staff Developing SRP for Use by Staff in Reviewing Decommissioning Plans & Other Info Used by Licensees & Other Responsible Parties to Support Decommissioning & License Termination

ML20210R370
Person / Time
Issue date:	06/10/1999
From:	Nelson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	External (Affiliation Not Assigned)
References
NUDOCS 9908170095
Download: ML20210R370 (138)

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Dear Workshop Participant:

1 The U.S. Nuclear Regulatory Commission (NRC) staff is deygyppgg@(ggpstReview Plan (SRP) for use by the staff in reviewing decommissioning plans and other information used by licensees and other responsible parties to support decommis, gningr4ticpe tgrmination. i The goal of the SRP will be to enable NRC staff to evaluate i crmeertfubmitteda by licensees

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in a timely, efficient, and consistent manner, to determine if the decommissioning can be (

conducted in such a way that the public health and safety is protected and the facility can be I released in accordance with NRC's requirements. Since late 1998, NRC staff has been working with interested parties to identify and address the issues that will need to be addressed I in the SRP. This workshop is our most recent effort to include the regulated community and other stakeholders in its development.

The NRC staff has developed drafts of several modules (or chapters) of the SRP which are enclosed for your review. NRC staff is interested in obtaining comments on the draft SRP modules from allinterested individuals and parties and we urge you to provide the staff with your comments. Also, please feel free to copy and distribute the draft SRP modules to any other interested individuals you may know. The SRP modules are also available on the Intemet at. 1 http//techconf.llnl. gov /cgi-bin / library? source =*& library =Lic_ Term _ lib & file =* I NRC staff will accept comments on the draft modules until December 15,1999. Comments may be sent to: I Dominick A. Orlando, Project Manager Special Projects Section Decommissioning Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T8F-37 Washington, DC 20555 l If you have any questions concerning the draft modules, you may contact Dominick at (301) 415-6749 or e-mail dao@nrc.cov. Comments may also be e-mailed to him at this address.

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Workshop Participants Thank you for participating in the workshop, and we look forward to your comments on the SRP.

Robert A. Nelson, Chief Special Projects Section Decommissioning Branch

~ Division of Waste Management Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated I

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+ June 10, 1999

Dear Workshop Participant:

The U.S. Nuclear Regulatory Commission (NRC) staff is developing a Standard Review Plan (SRP) for use by the staff in reviewingustop0VDgrglans and other information used by licensees and other responsible parties to support decommissioning and license termination.

The goal of the SRP will be to enable tjjlO ft.,tg e uatp information submitted by licensees in a timely, efficient, and consistent m5f'ine , 6dte i W the decommissioning can be conducted in such a way that the public health and safety is protected and the facility can be released in accordance with NRC's requirements. Since late 1998, NRC staff has been working with interested parties to identify and address the issues that will need to be addressed in the SRP. This workshop is our most recent effort to include the regulated community and other stakeholders in its development.

The NRC staff has developed drafts of several modules (or chapters) of the SRP which are enclosed for your review. NRC staff is interested in obtaining comments on the draft SRP modules from allinterested individuals and parties and we urge you to provide the staff with your comments. Also, please feel free to copy and distribute the draf t SRP modules to any other interested individuals you may know. The SRP modules are also available on the Internet at:

http://techconf.llnl. gov /cgi-bin / lib ra ry? sou rce =* & libra ry= Lic_.Te rm_ lib & file =

• NRC staff will accept comments on the draft modules until December 15,1999. Comments may be sent to:

f Dominick A. Orlando, Project Manager Special Projects Section Decommissioning Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Mail Stop T8F-37 Washington, DC 20555 )

If you have any questions concerning the draf t modules, you may contact Dominick at (301) 415-6749 or e-mail dao@nrc.aov. Comments may also be e-mailed to him at this address.

.)

June 10, 1999 Thank you for participating in the workshop, and we look forward to your comments on the SRP..

[ Original signed by:]

Robert A. Nelson, Chief Special Projects Section Decommissioning Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards

Enclosure:

As stated I

DISTRIBUTION: Central File - DCB r/f NMSS r/f RJohnson J . Bu k.q matw DOCUMENT NAME: S:\DWM\DCB\DAO\wkspcovr.wpd OFC DCB , DCB/J[//

NAME DOrland RN n DATE 6//o/99 6/ /D/99 OFFICIAL RECORD COPY LSS: YES __ NO _X_

ACNW: YES__ NO _X.__ '

IG: YES _.__ _ NO_X_ Delete file after distribution YES __. NO _

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tlclutouNj'tg This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the i

early stages of the development of the SRP. The SRP has not yet received i complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff i

will issue the SRP in final form.

Standard Review Plan for the Review of Decommissioning Plans and Other information Submitted to Support the Release of Nuclear Facilities l

l DRAFT FOR REVIEW AND COMMENT ONLY i

l Enclosure

5 NMSS DECOMMISSIONING PROGRAM ~

STANDARD REVIEW PLAN 1.0 EXECURVE

SUMMARY

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This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the

- development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has j

' reviewed, evaluated, and as appropriate incorporated all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

1 This Standard Review Plan (SRP) is being issued in draft ,

form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the l j

development of the SRP. The SRP has not yet received i complete NRC staff review and approval and does not I represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 1.0 EXECUTIVE

SUMMARY

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l RESPONSIBILITY FOR REVIEW

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Primary: NMSS: Division of Waste Management - La.eLevel Waste and l Decommissioning Projects Branch Division of Fuel Cycle Safety and Safeguards - Licensing Branch Region 1: Division of Nuclear Materials Safety - Decommissioning and i Laboratory Branch Region 11: Division of Nuclear Materials Safety - Materials Licensing / Inspection Branch 1 Region 111: Division of Nuclear Material Safety - Decommissioning Branch Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing Branch, Fuel Cycle and Decommissioning Branch Secondary: None Support: None AREAS OF REVIEW The staff will review the generalinformation supplied by the licensee or responsible party to determine if the decommissioning objective and general decori.missioning schedule comply DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

1 with NRC requirements. This information should include: the name and address of the licensee og owner of the site; the location and address of the site; a brief description of the site and immediate environs; a summary of the licensed activities that occurred at the site, including the number and type of license (s); when the facility began and ceased using licensed material and the types and activities of licensed material authorized under the license (s); the nature and extent of contamination at the site; the decommissioning objective proposed by the licensee (i.e., restricted or unrestricted use); the derived concentration guidelines (DCGLs) proposed by the licensee or responsible party, the corresponding doses to these DCGLs and the method by which the DCGL was determined; if appropriate, the restrictions the licensee intends to use to limit doses as required in 10 CFR Part 20.1403 or 20.1404 and a summary of the activities undertaken by the licensee to comply with 10 CFR Part 20.1403(d) or 20.1404(a)(4); the proposed initiation and completion dates of decommissioning; and any post-remediation, pre-license termination activities (such as groundwater monitoring); and a statement that the licensee is requesting that its license be amended to incorporate the decommissioning plan.

The purpose of the staff's review of the Executive Summary is to determine, in a general manner, whether the decommissioning plan submitted by the licensee or responsible party should provide an adequate demonstration that the licensee or responsible party understands, and has complied with, the requirements of 10 CFR 20.1400-1404,30.36,40.42,70.38,72.54 for decommissioning and license termination. The staff will not perform a technical review of any information in the Executive Summary.

REVIEW PROCEDURES Acceptance Review The staff will review the generalinformation supplied by the licensee or responsible party for completeness in accordance with this SRP.

Safety Evaluation The material to be reviewed is informational in nature, and no specific detailed technical analysis is required. The staff will verify that the specific information (licensee or responsible {

party's name and address etc.)is correct. The staff will make a qualitative assessment as to J the licensee's or responsible party's compliance with the requirements of 10 CFR 20.1402, regarding the estimated dose to the public from residual radioactive material at the completion of decommissioning and the method that the estimated dose from residual radioactivity was determined; the requirements of 10 CFR 20.1403 or 20.1404, if the decommissioning alternative proposed by the licensee is license termination under restricted conditions or using attemate criteria, and; if the decommissioning schedule summarized by the licensee or responsible party is reasonable.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 l 1

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ACCEPTANCE CRITERIA L Reaulatory Reauirements

- 10 CFR 20.1400-1404, 30.36, 40.42, 70.38; 72.54 -

Reaulatory Guidance

-None'-

Information Reauirements The information supplied by_the licensee or responsible party should provide contributory evidence as to the licensee's or responsible party's understanding of the technical and institutional requirements for the decommissioning of licensed nuclear facilities. The staff's review should verify that the following information is included in the Executive Summary:

e- the name and address of the licensee or owner of the site; e- the location and address of the site; e- a brief description of the site and immediate environs; e- a summary of the licensed activities that occurred at the site, including the number and type of license (s); when the facility began and ceased using licensed material and the types and activities of licensed material authorized and used under the license (s);

e the nature and extent of contamination at the site; e the decommissioning objective proposed by the licensee (i.e., restricted or unrestricted use);

e the DCGLs for the site, the corresponding doses from these DCGLs and the method that the DCGLs were determined; e a summary of the ALARA evaluations performed to support the decommissioning; e- if the licensee or responsible party requests license termination under restricted conditions, the restrictions the licensee intends to use to limit doses as required in 10 CFR Part 20.1403 or 20.1404 and a suminary of institutional controls, financial assurance.

e if the licensee requests license termination under restricted conditions or using altemate criteria a summary of the public participation activities undertaken by the licensee to comply with 10 CFR Part 20.1403(d) or 20.1404(a)(4);

e the proposed initiation and completion dates of decommissioning; e any post-remediation activities (such as groundwater monitoring) that the licensee proposes to undertake prior to requesting license termination; and e a statement that the licensee is requesting that its license be amended to incorporate the decommissioning plan ORAFT NMSS Decommissioning SRP - For Review and Comment Only 617/9 9

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EVALUATION FINDINGS Evaluation Criteria The staff should verify th-* the information summarized in "Information Requirements," above, is included in the Executiv mmary. The staff's review should verify that the decommissioning alternativ. .snd activities proposed by the licensee are or will be in compliance with the requirements of 10 CFR 20.1402 or 1403 as appropriate and that the decommissioning timeframe appears to be reasonable.

Samole Evaluation Findinas The NRC staff has reviewed the information in the Executive Summary of the Decommissioning Plan for the [ insert name and (license number) of facility] located at (insert location of facility]

according to the NMSS Decommissioning Standard Review Plan, Section 1(Executive Summary). Based on this review the NRC staff has determined that the licensee (insert name]

has provided sufficient information on the facility history, current radiological condition, proposed decommissioning alternative and activities undertaken by the licensee to comply with 10 CFR 20. [ insert as appropriate 1402 or 1403] to enable the NRC staff to conclude that the f 1 licensee appears to understand the NRC's requirements for decommissioning licensed nuclear .

facilities at 10 CFR 20.[ insert as appropriate 1402 or 1403] and 10 CFR [ insert, as appropriate 30,40,70,72]. j i

SUGGESTED FORMAT i

1. Length: not to exceed 3 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Ucensees Under 10 CFR 30,40, and 70" August 1989.

3. 1'2 paragraphs summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encourapad to submit the information in electronic format.

l This Standard Review Plan (SRP) is being issued in draft j form, for comment, to allow interested members of the public  !

to provide input to NRC staff in the early stages of the I development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

DRAFT NhfSS Decommissioning SRP - For Review and Comment Only 6/7/99

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NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 2.0 }

FACILITY OPERATING HISTORY l

i This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow

. interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any odicial NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

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1 This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 2.0 FACILITY OPERATING HISTORY RESPONSIBILITY FOR REVIEW Primary: NMSS: Division of Waste Management - Low-Level Waste and Decommissioning Projects Branch Division of Fuel Cycle Safety and Safeguards - Licensing Branch Region 1: Division of Nuclear Materials Safety - Decommissioning and Laboratory Branch Region 11: Division of Nuclear Materials Safety - Materials Licensing / inspection Branch 1 Region Ill: Division of Nuclear Material Safety - Decommissioning Branch Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing Branch, Fuel Cycle and Decommissioning Branch Secondary: None Support: None l

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 I

2 AREAS OF REVIEW The staff will review the information supplied by the licensee or responsible party to determine if the description of the operating history of the facility is adequate to allow the staff to fully understand the types of radioactive material (and for Part 70 licenses, the hazardous chemicals produced from radioactive material) used at the site, the nature of the authorized use of radioactive materials at the site and the activities at the site that could have contributed to residual radioactive material being present at the site. This information should include the license number (s) and status of the license (s) held by the licensee or responsible party; descriptions of: the activities authorized under the current license; past authorized activities utilizing licensed radioactive material at the site; all previous decommissioning or remedial activities at the site; and descriptions of and the locations of all spills and releases of radioactive material at the site and all previous burials of radioactive material, including those where the material was subsequently exhumed.

REVIEW PROCEDURES Acceptance Review The staff will ensure that the decommissioning plan contains the information summarized under

" Areas of Review," above. Staff will review the facility operating history portion of the decommissioning plan without assessing the technical accuracy or completeness of the information contained therein. The adequacy of this information will be assessed during the detailed technical review. Staff will review the decommissioning plan table of contents and the individual descriptions under " Areas of Review," above, to ensure that the licensee or responsible party has included this information in the decommissioning plan and to determine if the level of detail of the information appears to be adequate for the staff to perform a detailed technical review.

Safety Evaluation The material to be reviewed is informational in nature, and no specific detailed technical analysis is required. The staff will verify that the specific information (license numbers, status and current authorized activities) is correct. The staff will make a qualitative assessment as to whether the licensee's or responsible party's descriptions of authorized activities, past operating activities, spills, and previous burials is adequate to serve as the basis for evaluating the accuracy of the descriptions of the radiological status of the facility and the decommissioning activities proposed by the licensee to rernediate the facility can be conducted safely.

2.1 LICENSE NUMBER / STATUS / AUTHORIZED ACTIVITIES The purpose of the review of the description of the license number and authorized activities is to verify that the number and types of licenses and the status of each license is accurate and to familiarize the staff with the licensee's use of radioactive material at the site. This will enable the staff to evaluate the licensee's determination of the radiological status of the facility and the I

i DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

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licensee's planned decommissioning activities to ensure that the decommissioning can be conducted in accordance with NRC requirements.

l ACCEPTANCE CRITERIA l

Reaulatory Reauirements * (

10 CFR 30.36(g)(4)(i),40.42(g)(4)(i), 70.38(g)(4)(i) and 72.54(g)(1)

Reaulatorv Guidance None 1

Information Reauirements l

1 The information supplied by the licensee should be sufficient to enable the staff to fully understand what licensed activities are currently being performed by the licensee.

The staff's review should verify that the following information is included in the authorized activities section of the facility decommissioning plan:

e the radionuclides and maximum activities of radionuclides authorized and used under the current license; e

the chemical forms of the radionuclides authorized and used under the current license;

• 4 a detailed description of how the radionuclides are currently being used at the site; i e the location (s) of use and storage of the various radionuclides authorized under current licenses; and

• l a scale drawing or map of the building or site and environs showing current the locations of radionuclide use at the site;  !

EVALUATION FINDINGS Evaluation Criteria The staff's review should verify that the number and type of license (s) and the status of each license is accurate by comparing the information presented in the decommissioning plan to NRC license information. The staff should verify that the information summarized under "Information Requirements", above is included in the licensee's description of the authorized activities under the license. The staff should verify that this information is correct by comparing it to current NRC license information.

Sample Evaluation Findinos The NRC staff has reviewed the information in the Facility History section of the Decommissioning Plan for the (insert name and (license number) of facility) located at [ insert location of facility) according to the NMSS Decommissioning Standard Review Plan, Section 2(Facility History). Based on this review the NRC staff has determined that the licensee (insert name] has provided sufficient information to aid the NRC staff in evaluating the licensee's 1

i DRAFTNMSS Decommissioning SRP - For Review and Comment Only 6f7/99 I

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. determination of the radiological status of the facility and the licensee's planned decommissioning activities to ensure that the decommissioning can be conducted in accordance with NRC requirements. (Note that this finding incorporates the results of the' staff's assessment under Sections 2.3,2.4, and 2.5, below).

SUGGESTED FORMAT l

1. Length: not to exceed 10 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard ,

Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. Bullets 1 and 2 in Acceptance Criteria, above should be no more than a few sentences.

Up to 4 pages summarizing each of the remaining items outlined in Acceptance Criteria, above. Licensees are also encouraged to submit the information in electronic format.

2.2 LICENSE HISTORY The purpose of the review of the description of the license history is to familiarize the staff with the licensee's previous uses of radioactive material at the site so that the staff can evaluate whether the licensee's determination of the radiological status of the fccility is adequate and the licensee's planned decommissioning activities are appropriate to ercore that the decommissioning can be conducted in accordance with NRC regt urements.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.35(g),40.36(f),70.25(g),72.30(d) 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1)

Reculatory Guidance None Information Reauirements The information supplied by the licensee should be se.xient to enable the staff to fully understand what licensed activities were performed by the licensee in the past.

The staff's review should verify that the following information is included in the license histroy section of the facility decommissioning plan:

e the radionuclides and maximum activities of radionuclides authorized and used under all previous licenses; e the chemical forms of the radionuclides authorized and used under all previous licenses; e a detailed description of how the radionuclides were used at the site; DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

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• the location (s) of use and storage of the various radionuclides authorized under all previous licenses as described in 10 CFR 30.35(g),40.36(f),70.25(g),72.30(d); and e a scale drawing or map of the site, facilities and environs showing previous locations of radionuclide use at the site as described in 10 CFR 30.35(g),40.36(f),70.25(g),

72.30(d). -

EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements" abova is included in the licensee's description of the license history under the license. The staff ,

should verify that this information is correct by comparing it to historical NRC license '

information. I Samole Evaluation Findinas j I

None. The staff should combine the assessment of this section of the decommissioning plan l with Section 2.1 above. i SUGGESTED FORMAT (

1. Length: not to exceed 20 pages

2. - Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and ]

70' August 1989.

3. 3-5 pages summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

2.3 - PREVIOUS DECOMMISSIONING ACTIVITIES The purpose of the revNw of the license's previous decommissioning activities is to provide the staff with information that will aid the staff in evaluating the licensee's determination of the radiological status of i a facility and whether previous decommissioning activities are sufficient to comply with current NRC criteria for license termination ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.35(g),40.36(f),70.25(g),72.30(d) 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1)  ;

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

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' Reaulatory Guidance None Information Reouirements-The information _ supplied by the licensee should be sufficient to enable the staff to fully

understand what decommissioning activities were performed by the licensee in the psct.

The staff's review should verify that the following information is included in the previous decommissioning activities'section of the facility decommissioning plan:

t- e . a list or summary of areas at the site that were remediated in the past, e a summary of the types, forms,-' activities and concentrations of radionuclides that were

present in previously remediated areas; e the activities that caused the areas to become contaminated; e the procedures used to remediate the areas and the disposition of radioactive material generated during the remediation;

• - a summary of the results of the final radiological evaluation of the previously remediated area including the locations and average radionuclide concentrations in the previously remediated areas, and

• - a scale drawing or map of the site, facilities and environs showing the locations of

previous remedial activity ' -

- EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements".

above is included in the licensee's description of the previous decommissioning activities -

> carried out under the license. The staff should verify, to the extent practicable, that this

. information is correct by comparing it to any historical NRC license information.

'Samole Evaluation Findinos None.. The staff should combine their assessment of this section of the decommissioning plan with Section 2.1, above. j SUGGESTED FORMAT-

1. _ Length: not to exceed 5 p' ages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and  ;

70' August 1989. j 3.~ . Information requested for bullets 1,2 and 5 in Acceptance Criteria, above, may be presented in. tabular form. 3-5 paragraphs summarizing each of the remaining items outlined in' Acceptance Criteria, above. Licensees are also encouraged to submit the  ;

information in electronic format.- 1 DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99  !

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- 2.4 SPILLS The purpose of the review of the license's description of spills', that have occurred at the site is to provide the staff with information that will aid in the staff's evaluation of the licensee's determination of the radiological status of the facility ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 30.35(g)(1),40.36(f)(1),70.25(g)(1),72.30(d)(1) 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1)

Reoulatory Guidance fJone information Reauirements l 1

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l The information supplied by the iicensee should ba sufficient to enable the staff to determine whether spills that have occurred at the facility in the past could impact on the current l radiological status of ths fe!lity. The staff's review should verify that the following information is included in the spills section of the decommissioning plan (note that this information may be }

presented concurrently with the information discussed in Section 2.4, Previous l

Decommissioning Activities, above): i

)

e a summary of areas at the site where spills (or uncontrolled releases) of radioactive a

4 material occurred in the past; e the types, forms, activities and concentrations of radionuclides involved in the spill or uncontrolled release, and; e a scale drawing or map of the site, facilities and environs showing the locations of spills EVALUA710N FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of spills that have occurred at the facility. The staff should verify that this information is correct by comparing it to any historical NRC license information. J

' ' In this context a "spiir'is defined as any controlled or uncontrolled release of radioactive material at the site that results in radioactive material being present in the environment or any unusual occurrences involving the j spread of contamination in and around the facihty, equipment, or site DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

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Sample Evaluation Findinos None. The staff should combine their assessment of this section of the decommissioning plan with Section 2.2, above.

SUGGESTED FORMAT

1. Length: not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 3-5 paragraphs summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

2.5 PRIOR ON-SITE BURIALS The purpose of the review of the license's description of prior on-site burials is to provide the staff with information that will aid in the staff's evaluation of the licensee's determination of the radiological status of the facility ACCEPTANCE CRITERIA Reaulatory Reauire$1ents 10 CFR 20.2002,30.35(g)(3)(iii),40.36(f)(3)(iii),70.25(g)(3)(iii),

10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1)

Reculatorv Guidance NUREG 1101, Volume 1'On-site Disposal of Radioactive Waste

• March 1986 Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to determine whether previous burials at the facility could impact on the current radiological status of the facility. Note that all radioactive material at the site would be included in the staff's evaluation of the doses from residual radioactive material and as such would be included in any dose assessments that are performed for the facility. The staff's review should verify that the following informati'.,n is included in the previous burials section of the decommissioning plan:

e a summary of areas at the site where radioactive material has been buried in the past; e the types, forms, activities and concentrations of waste and radionuclides in the former burial, and; DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99

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- a scale drawing or map of the site, facilities and environs showing the locations of former burials.

EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of former burials at the site. The staff should verify that this information is correct by comparing it to historical NRC license information, as well, as information submitted pursuant to 10 CFR 20.302,20.304 20.2002,30.35(g)(3)(iii),

40.36(f)(3)(iii),70.25(g)(3)(iii) and NUREG 1101, Volume 1. Note that the information required pursuant to 30.35(g)(3)(iii),40.36(f)(3)(iii),70.25(g)(3)(iii) may not be submitted to NRC until license termination. However, the licensee should include or use a summary of this information in developing this section cf the decommissioning plan.

Sample Evaluation Findings 4 None. The staff should combine their assessment of this section of the decommissioning plan I with Section 2.1, above.

SUGGESTED FORMAT

1. Length: not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and j 70' August 1989.

3. J 3-5 paragraphs summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official N,RC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 3.0 FACILITY DESCRIPTION l

l This Standard Review Plan (SRP) ic being issued in draft form, for comment, to allow i interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and '

approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

1 1 l This Standard Review Plan (SRP)is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not {

represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the' draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM i

STANDARD REVIEW PLAN 3.0 FACILITY DESCRIPTION RESPONSIBILITY FOR REVIEW Primarv: NMSS: Division of Waste Management - Decommissioning Branch Division of Fuel Cycle Safety and Safeguards - Licensing Branch Region 1: Division of Nuclear Materials Safety - Decommissioning and Laboratory Branch Region ll: Division of Nuclear Materials Safety - Materials Licensing / Inspection Branch 1 Region Ill: Division of Nuclear Material Safety - Decommissioning Branch Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing Branch, Fuel Cycle and Decommissioning Branch f

Secondarv: None {

1 Support: Division of Waste Management - High Level Waste and Performance Assessment Branch l

I I

l DRAFTNMSS Decommissioning SRP - For Review and Comment Only 617/9 9

2 NOTE TO REVIEWERS OF THE DRAFT SRP:

THE GUIDANCE IN THIS SECTION OF THE SRP HAS BEEN DEVELOPED FOR SITES: (1) REQUIRING SITE-SPECIFIC DOSE MODELING; (2) RESIDUAL CONTAMINATION AT DEPTHS EXCEEDING 15 CM; AND/OR (3) HAVING ONSITE DISPOSAL CELLS FOR RADIOLOGICALLY CONTAMINATED DECOMMISSIONING WASTE. REFER TO SECTION X.X OF THE SRP FOR GUIDANCE ON THE INFORMATION NEEDED FOR LESS COMPLEX CASES AREAS OF REVIEW The staff will review the information supplied by the licensee or responsible party to determine if the description of the facility and environs is adequate to allow the staff to: (1) evaluate the licensee's estimation of doses to on and off-site populations during, and at the completion of decommissioning; and, (2) to evaluate the licensee's estimation of the impacts of the proposed {

decommissioning alternative on the site and surrounding areas. This information should include a description of the site and environs; a description of the current population distribution, including minority populations; a summary of current and potential future uses of land in and around the site; descriptions of the site meteorology, geology, seismology, climatology, surface and groundwater hydrology; descriptions of the natural and water resources at the site; a description of the ecology of the site; and, a summary of all endangered species at the site.

REVIEW PROCEDURES 1

Acceptance Review The staff will review the decommissioning plan to ensure that, at a minimum, the decommissioning plan contains the information summarized under " Areas of Review," above.

Staff will review the facility description portion of the decommissioning plan information without assessing the technical accuracy or completeness of the information. The adequacy of the )

information will be assessed during the detailed technical review. Staff will review the l

decommissioning plan table of contents and the individual descriptions under " Areas of  !

Review," above, to ensure that the licensee or responsible party has included this inforrnation in the decommissioning plan and to determine if the level of detail of the information appears to be adequate for the staff to perform a detailed technical review.

Safety Evaluation The material to be reviewed is generally informational in nature however, significant detailed l technical analysis may be required. The staff will verify that the specific information concerning site meteorology, geology, seismology, climatology, surface and groundwater hydrology, geotechnical characteristics, natural and water resources, ecology and endangered species at DRAFTNMSS Decommissioning SRP - For Review and Comment Only 617/9 9 1

l 3

the site is complete and accruate. .The staff will make a qualitative assessment as to whether the licensee's or responsible party's descriptions of the site and environs and summary of current and potential future land uses is adequate to serve as the basis for evaluating the licensee's or responsible party's dose and environmental impacts estimates.

0.1 SITE LOCATION AND DESCRIPTION The purpose of the review of the description of the site location and description is to verify that sufficient information is presented to allow the NRC staff to understand the physical characteristics of the site and relationship of the site to surrounding areas. This will aid the staff in evaluating the licensee's or responsible party's dose and environmental impacts estimates and planned decommissioning activities to ensure that the decommissioning can be conducted in accordance with NRC requirements.

ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 30.36(g)(4)(i), 40.42(g)(4)(i), 70.38(g)(4)(i) and 72.54(g)(1)

Reaulatory Guidance None Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the physical characteristics of the site. The staff's review should verify that the following information is included in the description of the site description and location section of the decommissioning plan: )

e the size of the site in acres or square meters; 1

• the State and county in which the site is located; e the names and distances to nearby communities, towns and cities;

)

-e a description of the contours and features of the site; {

e {

the elevation of the site; j

• a description of property surrounding the site;

• - the location of the site relative to prominent features such as rivers and lakes. To facilitate presentation of this information, U.S. Geological Survey (USGS) topographic  !

maps may be provided; '

a map that shows the detailed topography of the site using a contour interval (such as 2 feet or 1 meter) and including plot plans, the locations of characterization borings and monitoring wells, and the positions and types of geologic characterization activities.

e the location of the nearest residences and all significant facilities or activities near the site DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/9 9 l

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e 1 a description of the facilities (buildings, parking lots, fixed equipment, etc.) at the site EVALUATION FINDINGS '

Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above, is included in the licensees description of the site and environs. The staff's review I

should verify, to the maximum extent practicable, that the information supplied by the licensee or responsible party is accurate by comparing it to licensing and inspection information maintained in NRC files.

)

Samole Evaluation Findinas None. The staff does not need to comment on the accuracy of the information presented in the  !

site description / location section of the decommissioning plan I SUGGESTED FORMAT

1. Length: not to exceed 7 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Cor! tent of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

3.2 POPULATION DISTRIBUTION The purpose of the review of the description of the population distribution is to determine if the licensee or responsible party has supplied sufficient information on the makeup and distribution of the population in the vicinity of the site to enable the NRC staff to evaluate the licensee's or responsible party's estimate of doses to off-site individuals during and at the completion of decommissioning and to determine if population characteristics warrant an evaluation of ,

l environmentaljustice issues. 4 ACCEPTANCE CRITERIA 1

Reaulatory Recuirements 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1)

Reaulatory Guidance NMSS Policy and Procedures Letter 1-50 Revision X " Environmental Justice in NEPA Documents" DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 \

l l

5 Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to determine I the population makeup and distribution in the vicinity of the site. The staff's review should verify that a summary of current and projected populations in the vicinity of the site, by principal  !

compass sectors is included in the decommissioning plan. This summary should be sufficiently  !

detailed to allow the determination of doses to off-site individuals via atmospheric pathways. In {

addition, the staff will verify that the makeup and distribution of minority and low-incom

{

populations are sufficiently described in the decommissioning plan as to allow the environmentaljustice evaluation described in Policy and Procedures Letter 1-50. The {

l decommissioning plan should include the following:

e a summary of the current population in and around the site, by compass vectors e a summary of the projected population in and around the site by compass vectors e a list of minority populations by compass vectors e demographic data by census block group to identify minority or low-income populations E'/. ALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirernents",

above, is included in the licensee's or responsible party's description of the distribution of populations around the site. The staff will verify the licensee's or responsible party's population data against available independent population data (e.g., information from the Census Bureau including any special census that may have been conducted, local and State agencies, and regional Councils of Government). The staff will evaluate project population information by comparing it to projections made by local planning boards or offices.

Sample Evaluation Findinos None. The staff should combine the assessment of this section of the decommissioning plan with Section 3.1 above, and 3.3 below (see Sample evaluation Findings at Section 3.3 below).

SUGGESTED FORMAT

1. Length: not to exceed 2 pages.

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 3-5 paragraphs summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

DRAFTNMSS Decommissioning SRP - For Review and Comment Only 6/7/99

6 3.3 CURRENT / FUTURE LAND USE The purpose of the description of current and future land use is to provide the staff with information that will aid the staff in evaluating the licensee's estimates of doses to on and off-site individuals during and at the completion of decommissioning.

ACCEPTANCE CRITERIA Reculatory Reauirements 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1)

Reaulatorv Guidance None Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to understand what current land uses are and what local, regional or State planning boards or office anticipate the future land uses to be at the site. The staff's review should verify that the licensee or responsible party has used all available data on land use, plans and trends in land use, land use controls (such as zoning), potential for growth, or other factors likely to inhibit or stimulate growth in the area by comparing it to publically available information from local, regional or State land use planning boards or offices. The decommissioning plan should include a description of the current land uses in and around the site and a summary of anticipated land uses.

EVALUATION FINDINGS Evaluation Critena The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's d;scussion of current and future land use. The staff should verify, to the extent practicable, that this information is correct by comparing it to publically available information on current land use in the vicinity of the site, land use trends in and around the site and expected future uses of the land in and around the site.

Samole Evaluation Findinas None.

1 SUGGESTED FORMAT i

1. Length: not to exceed 3 pages DRAFTNAfSS Decommissioning SRP - For Review and Comment Only 6f7/99 {

l l

v  ;

7

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

3.4 METROLOGY AND CLIMATOLOGY The purpose of the review of the license's description of metrology and climatology is to determine if the licensee has provided sufficient information to allow the NRC staff to evaluate the licensee's or responsible party's estimations of doses to on and off-site individuals during and at the completion of decommissioning operations.

ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 30.3G(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 73.54(g)(1)

Reaulatorv Guidance RegGuide 1.23 "Onsite Meterological Programs" (Safety Guide 23)

Information Reauirements The information 4.jpplied by the licensee should be sufficient to enable the staff to determine how local weather pattems will effect the estimation of doses to on and off-site individuals durire and at the completion of decommissioning operations. The staff's review should verify

< that the Mllowing information is included in the climatology and metrology section of the decommis9oning plan:

e a description of the general climate of the region with respect to types of air masses, synoptic features (high- and low-pressure systems and frontal systems), general air-flow patterns (wind direction and speed), temperature and humidity, precipitation, and relationships between synoptic-scale atmospheric processes and local meteorological conditions; e seasonal and annual frequencies of severe weather phenomena including tornados; water spouts, thunderstorms, lightning, hail, and high air pollution potential;

• weather-related radionuclide transmission parameters including average and extreme wind vectors and average and extreme duration and intensity of precipitation events;

• routine weather-related site deterioration parameters including precipitation intensity and duration, wind vectors, and temperature and pressure gradients; e extreme weather-related site deterioration parameters including tornados, water spouts, thunderstorms, hail, and extreme air pollution (from offsite sources); and, e a description of the local (site) meteorology in temperature, atmospheric water vapor, precipitation, fog, atmospheric stability and air quality; DRAFT NMSS Decommissioning SRP - For Review and Comment only 617/9 9

p 8

e the National Ambient Air Quality Standards Category of the area in which the facility is located and, if the facility is not in a Category 1 zone, the closest and first downwind Category 1 Zone.

- EVALUATION FINDINGS Evaluation Criteria The staff will review the licensee's or responsible party's description of the site climatology and metrology for completeness and adequacy of basic data. The wind and atmospheric stability data should be based on onsite data. The other summaries should be based on nearby representative stations with long record retention periods. When offsite data are used, the staff will determine how well the data represent site conditions and whether more representative data are available. The staff will use National Oceanic and Atmospheric Administration (NOAA) (U.S.

Department of Commerce) State meteorological summaries (" State Climatological Summary"),

local climatological data (" Local Climatological Data Annual Summary with Comparative Data"),

and NOAA Environmental Data Service summaries pertinent to the site to evaluate the representativeness of stations and periods of record. The staff should be familiar with all primary meteorological data collection locations. The staff will ensure that all topographic maps and topographic cross-sections presented by the applicant are legible and well-labeled so that the information needed during the review can be readily extracted.- Points of interest such as facility structures, site boundary, and buffer zone should be marked on all maps and diagrams.

The staff will compare the applicant's assessment of the effect of topography with standard assessments such as those presented in " Meteorology and Atomic Energy - 1968" (Slade, 1968) and decide whether the standard regulatory atmospheric diffusion models are appropriate for this site. The staff will review for completeness and authenticity the general climatic description of the region in which the site is located. Climatic parameters such as air masses, general air flow, pressure patterns, frontal systems, and temperature and humidity conditions reported by the applicant will be checked against standard references (Thom,1968; U.S. Department of Commerce,1968) for appropriateness with respect to location and period of record. The staff will verify the applicant's description of the role of synoptic-scale atmospheric processes on local (site) meteorological conditions against the descriptions provided in " Climatic Atlas of the United States" and " Local Climatological Data -

l Annual Summary With Comparative Data" (both published by the U.S. Department of Commerce).

Because meteorological averages and extremes can only be obtained from stations in the region of the site that have long record retention periods and the stations are not usually very close to the site, the staff will first determine the representativeness of the data to site conditions and then ascertain the adequacy of the stations and their data. The staff will verify (1) recorded meteorological averages and extremes using standard publications such as " Storm Data", published by the U.S. Department of Commerce; (2) other averages and extremes using

" State Climatological Summaries" and " Storm Data", published by the U.S. Department of Commerce; (3) the potential for high air pollution; (4) extreme winds and their distribution using i

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99

i l

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RegGuide 1.234 and " Metrology and Atomic Energy - 1968" (Slade,1968); and, (5) gust factors using RegGuide 1.23 i

Samole Evaluation Findinas

'None.

SUGGESTED FORMAT

1. Length: not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and

)

l 70" August 1989.

3. 3-5 paragraphs summarizing each of the items outlined in Acceptance Criteria, above. 1 Licensees are also encouraged to submit the information in electronic format. l 3.5 GEOLOGY AND SEISMOLOGY The purpose of the review of the license's or responsible party's description of the site geology -

and seismology is to determine if the licensee has provided sufficient information to allow the NRC staff to evaluate the licensee's or responsible party's estimations of doses to on and off-site individuals during and at the completion of decommissioning operations.

1

- ACCEPTANCE CRITERIA I

Reaulatorv Reauirements j l

10 CFR 30.36(g)(4)(i), 40.42(g)(4)(i), 70.38(g)(4)(i) and 72.54(g)(1) '

Reaulatory Guidance None Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to determine how site geological and seismological characteristics will effect the estimation of doses to on and off-site individuals during and at the completion of decommissioning operations. The staff's review should verify that the geology and seismology section of the decommissioning plan contains the following information: i i

Geoloa_ v

• a detailed description of the geologic characteristics of the site and the region around the site DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 i

l j

o 10 e a discussion of the tectonic history of the region, regional geomorphology, physiography, stratigraphy, and geochronology. All tectonic structures should be ]

identified, in particular folds and faults in the region around the site, and their geologic and structural history should be discussed. The relationship between seismicity and tectonic structures and the earthquake-generating potential of any active structures should be determined.

e a regional tectonic map showing the site location and its proximity to tectonic structures should be provided. Appropriate references of supporting documents should be provided with regional physiographic and topographic maps, geologic and structure maps, fault maps, stratigraphic sections, boring logs, and aerial photographs.

e a description of the structural geology of the region and its relationship to the site geologic structure should be discussed. Any faults, folds, open jointing, fractures, and shear zones in the region must be identified, and their significance to the facility should be discussed.

e a description of any crustal tilting, subsidence, karst terrain, landsliding, and erosion.

e a description of the surface and subsurface geologic characteristics of the site and its vicinity. The description should include local stratigraphic units and their accepted names, ages, genetic relationships, and lithologies. To facilitate the presentation, these descriptions should be accompanied by appropriately scaled geologic maps.

Descriptions of mineralogy, particle size, organic materials, degree of cementation, zones of alteration, and depositional environment of unconsolidated strata should be included.

e a description of the geomorphology of the site, including USGS topographic maps that emphasize local geomorphic features pertinent to the site. The applicant should describe the geomorphic processes affecting the present-day topography of the disposal site and vicinity. Information should include descriptions of processes such as mass wasting, erosion, slumping, landsliding, and weathering where appropriate. The discussion of relevant geomorphic processes should include their rates, frequencies of occurrence, and controlling mechanisms or factors.

e a description of the location, attitude, and geometry of all known or inferred faults in the site and vicinity. Fault displacements should be identified and potential recurrence intervals addressed.

e a discussion of the nature and rates of deformation such as folding within the site and relate these to the local stress regime. Any joint sets within the site including their densities and orientations should be described, and their relative ages discussed.

Remineralization and mineralization history of the various joint sets should also be

. discussed. Solution cavities and crevices in the bedrock should be described and discussedif applicable.

Seismoloav e a description of the seismicity, tectonic characteristics of the site and region, correlation of earthquake activity with geologic structures and tectonic provinces, maximum earthquake potential, seismic wave transmission characteristics of the site, design earthquake, settlement and liquefaction, and geophysical methods for site characterization.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/9 9

11 e

a complete list of all historical earthquakes that have a magnitude of 3 or more or a modified Mercalliintensity of IV or more within 200 miles of the site. The listing should include all available information about the earthquakes such as epicenter coordinates, depth of focus, origin time, intensity, and magnitude, augmented by a map showing the locations of these earthquakes. The references from which the information was obtained should be indicated. In addition, any earthquake that induced geologic hazard (e.g.,

landsliding or liquefaction) should be identified, and the acceleration that caused the hazard should be provided.

EVALUATION FINDINGS Evaluation Criteria The staff will review for completeness the information on geologic site characterization in the decommissioning plan. If the information reflects the results of a thorough literature search and an adequate reconnaissance and physical examination of the regional and site conditions by the licensee or responsible party the decommissioning plan will be considered acceptable.

Consultations with commercial companies and Federal, State, and local government agencies that may have had occasion to characterize the site will help ensure the adequacy of the characterization in the decommissioning plan. The review can be completed quickly if the decommissioning plan contains sufficient information to allow the staff to make an independent essessment of the licensee's or responsible party's assumptions, analyses, and conclusions.

Tha staff will thoroughly review the information in the decommissioning plan to determine if all  ;

interpretations and conclusions are founded on sound geologic practice and do not exceed the i limits of validity of the data in the decommissioning plan or of other data published in the l literature.

Samolo Evaluation Findinas None.

SUGGESTED FORMAT

1. Length: not to exceed 15 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989,

3. 3-5 paragraphs summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

1 3.6 SURFACE WATER HYDROLOGY l i

l ACCEPTANCE CRITERIA DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 I

I

12 The purpose of the review of the license's description of the surface water hydrology at the site is to determine if the licensee has provided sufficient information to allow the NRC staff to evaluate the licensee's or responsible party's estimations of doses to on and off-site individuals during and at the completion of decommissioning operations.

Reaulatory Reauirements 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1) 1 1

Reaulatorv Guidancq '

None Evaluation Criteria The information supplieo by the licensee should be sufficient to enable the staff to determine whether surface water characteristics could impact on the doses to on or off-site individuals during or at the completion of decommissioning. The staff's review should verify that the following information is included in the surface water hydrology section of the decommissioning plan:

e a description of site drainage and surrounding watershed fluvial features, including important water users a water resource data including maps, hydrographs, and stream records from other agencies (e.g., U.S. Geological Survey and U.S. Army Corps of Engineers),

e topographic maps of the site that show natural drainages and man-made features e

a description of the surface water bodies at the site and surrounding areas, including the location, size, shape, and other hydrologic characteristics of all streams, lakes, or coastal areas.

e a description of existing and proposed water control structures and diversions (both upstream and downstream that may influence the site).

e flow-duration data that indicate minimum, maximum, and average historical observations for surface water bodies in the site areas e

aerial photography and maps of the site and adjacent drainage areas identifying features such as drainage areas, surface gradients, and areas of flooding.

e an inventory of all existing and planned surface water users, whose intakes could be adversely affected by migration of radionuclides from the site . The inventory should include the owner, location, type, and amount of use; source of supply; type of intake; and surface water quality data.

e topographic and/or aerial photographs that delineate the 100-year floodplain at the site e-a description of any man-made changes to the surface water hydrologic system that may influence the potential for flooding at the site. (Such changes may include construction of reservoirs, urban development, strip mining, lumbering, etc.). The description of these changes should include the proximity of the affected area to the site, the surface water bodies affected, the size of the area affected, and the potential effects at the site.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only G/7/99

L 13 EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of the surface water features at the site.

Acceptance of the information in the decommissioning plan will be based in part on a qualitative evaluation of the completeness and adequacy of the information and of maps. Descriptions and evaluations of structures, tacilities, etc. are adequate if they are sufficiently complete to allow independent evaluations of the effects of flooding and intense rainfall. Site topographic maps are acceptable if they are of good quality, are legible and adequate in coverage to substantiate applicable data and analyses. The descriptions of the hydrologic characteristics of surface '

water features and water use are acceptable if they are detailed and generally correspond to those of the U.S. Geologic Survey (USGS), National Oceanographic and Atmospheric Administration, Soil Conservation Service, Corps of Engineers, or appropriate State and river basin agencies. Descriptions of existing or proposed reservoirs and dams that could influence conditions at the site should be based on reports of the USGS, U.S. Bureau of Reclamation, Corps of Engineers, and others; these reports normally include tabulations of drainage areas, types of structures, appurtenances, ownership, seismic and spillway design criteria, elevation-storage relationships, and short- and long-term storage allocations.

Samole Evaluation Findinas None.

SUGGESTED FORMAT

1. Length: not to exceed 15 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 3-5 paragraphs summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

l I

i 3.7 GROUNDWATER HYDROLOGY '

The purpose of the review of the license's description of groundwater hydrology section of the decommissioning plan is to determine if the licensee has provided sufficient information to allow the NRC staff to evaluate the licensee's or responsible party's estimations of doses to on and off-site individuals during and at the completion of decommissioning operations.

ACCEPTANCE CRITERIA Reaulatory Reauirements DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99 1

14 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1)

Reculatory Guidance None Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to determine how the groundwater characteristics of the site effnct the doses to on or off-site individuals during or at the completion of decommissioning. The staff's review should verify that the following information is included in the groundwater hydrology section of the decommissioning plan:

o a description of the saturated zone including all potentially affected aquifers, the lateral extent, thickness, water-transmitting properties, recharge and discharge zones, groundwater flow directions and velocities, and other information that can be used to create an adequate conceptual model of the saturated zone.

' e descriptions for monitor wells, including location, elevation, screened intervals, depths, construction and completion details, and hydrogeologic units monitored. The description should include domestic, industrial and/or municipal wells or other monitoring devices, if applicable, and any construction and completion details for these devices, when available. Descriptions of all aquifer tests should also be provided, including test data and a discussion of the assumptions, analysis, and test procedures used.

e physical parameters such as storage coefficients, transmissivities, hydraulic conductivities, porosities, and intrinsic permeabilities should be included, e a description, to the extent practicable, of groundwater flow directions and velocities ,

(horizontal and vertical) for each potentially affected aquifer. When applicable, the i groundwater hydrology should be described by making use of hydrogeologic columns, cross-sections, and water table and/or potentiometric maps.

e a description of the unsaturated zone including descriptions of the lateral extent and thickness of permeable and impermeable zones, potential conduits of anomalously high flux, and direction and velocity of unsaturated flow.

e information on all monitor stations including location and depth e a description of physical parameters including the spatial and stratigraphic distribution of the total and effective porosity; water content variations with time; saturated hydraulic conductivity; characteristic relationships between water content, pressure head, and hydraulic conductivity; and hysteretic behavior during wetting and drying cycles, especially during extreme conditions.

e a description of the numerical analyses techniques used to characterize the unsaturated and saturated zones including the model type, justification, documentation, verification, calibration and other associated information. In addition, the description should include the input data, data generation or reduction techniques, and any modifications to these i data, f

i l

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 1

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" EVALUATION FINDINGS

~

Evaluation Criteria -

LThe staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's or responsible party's description of the groundwater

~ hydrology at the site. The staff will review the information on the saturated zone by evaluating ,

the testing and monitoring program and sample collection procedure. The staff will evaluate the i rationale for choosing particular sampling locations and verify that they are commensurate with the complexity of the saturated zone. The staff will confirm that acceptable procedures were used by the licensee or responsible party to collect, preserve, and analyze samples. Staff will-

. determine that adequate quality control was used for the collection, preservation, and laboratory analyses of samples. The staff will evaluate the adequacy of non-applicant-constructed =

monitoring devices used in the characterization (iricluding the characterization of seeps, springs, and private, municipal, or industrial wells in the vicinity of the proposed site). The staff will evaluate aquifer tests performed by the licensee or responsible party to ensure ,

that applicable test methods incorporate proper assumptions, analyses, and test procedures.

The staff will assess the accuracy of the transmissivity, storativity, and hydraulic conductivity ,

results derived from testing. The staff will determine if groundwater will discharge to the surface 1 within the site boundry and if fluctuations in the water table will result in interactions of groundwater with the residual radioactive material. Staff will confirm that the description of major hydrologic parameters, aerial extent of aquifers, recharge-discharge zones, flow rates and directions, and travel times, including seasonal fluctuations and long-term trends.

{

.The staff will review the licensee's or responsible party's information on the unsaturated zone i by evaluating the monitoring program and sample collection procedure. The staff will evaluate l the rationale for choosing particular sampling locations and verify that they are commensurate with the complexity of the unsaturated zone. The staff will confirm that the description of the unsaturated zone incorporates the necessary field and laboratory data, including seasonal fluctuations and long-term trends. The staff will review the applicant's analysis of the likelihood of the development of perched aquifers and perform independent analyses, using accepted methods, to determine the adequacy of the description.

The evaluations described in the following paragraphs may be included in groundwater

~ hydrology portion or dose modeling sections of the of the decommissioning plan.

The staff will evaluate the applicant's conceptual model that describes, to the extent practicable, all hydrogeologic processes and features, including the potential for deep percolation, recharge / discharge zones, areas of anomalous physical parameters affecting legional ,

processes, extent of aquifers and confining layers, interactions between aquifers, and 1 movement of groundwater in the saturated and unsaturated zone. The staff will review this model to determine its defensibility, conservatism, and adequate incorporation of data into a unified conceptual model.

ORAFT NAfSS Decommissioning SRP - For Review and Comment Only 6/7/99 i i

i a

l 16 The staff will evaluate the numerical analyses of groundwater data collected by the licensee or responsible party for the site and vicinity. This will normally involve analytical or numerical modeling. The staff will verify that the model type chosen for analysis is properly documented, verified, and calibrated and adequately simulates the physical system of the site and vicinity. The staff's will review the the modeling strategy used by the licensee or responsible pany to assure that it is logical and defensible. The staff will review the adequacy of the model input data generation and reduction techniques. Modifications of input data, required for calibration, ,will be reviewed to ensure that the new values are realistic and defensible.

Following its review of this information, the staff will determine whether the licensee's or j responsible party's conclusions are adequate. Alternatively, the staff may decide to conduct an -

independent analysis. If the staff conducts an independent analysis, it will compare the results with those derived by the licensee or responsible party to determine if the applicant's results are adequate.  ;

Sample Evaluation Findinas j

)

None.

SUGGESTED FORMAT

1. Length: not to exceed 20 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and ,

70" August 1989. Licensees are also encouraged to submit the information in electronic format. i f 1 3.8 NATURAL RESOURCES The purpose of the review of the license's description of natural resources at the site is to aid the staff in evaluating the impacts that the decommissioning alternative chosen by the licensee may have on these resources and to evaluate whether the exploitation of these resources could impact on the licensee's or responsible party's dose estimates for the site.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1)

Reaulatorv Guidance None DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

l 17 l i

information Reauirements The information supplied by the licensee should be sufficient to enable the staff to determine what natural resources are present at and in the vicinity of the site. The staff's review should verify that the following information is included in the natural resources section of the decommissioning plan:

e a description of the natural resources occurring at or near the site including metallic and nonmetallic minerals and ores; fuels, such as peat, lignite, and coal; hydrocarbons, including gas, oil, tar sands, and asphalt; geothermal resources; industrial mineral deposits, such as sand and gravel, clays, aggregate sources, shales, and building stone; timber; agriculturallands; and waters in the form of brines.

e a description of potable, agricultural, or industrial ground or surface waters including l information on resource type, occurrence, location, extent, net worth, recoverability, and current and projected use.

e a description of economic, marginally economic, or subeconomic known or identified natural resources as defined in U.S. Geological Survey Circular 831.

e mineral, fuel, and hydrocarbon resources near and surrounding the site which, if s exploited, would effect the licensee' or responsible party's dose estimates 1 EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's or responsible party's description of the natural resources at ,

the site. l The staff will determine if the licensee or responsible party has identified known resources as described in U.S. Geological Survey Circular 831. The staff will verify that the decommissioning plan describes economic, marginally economic, and subeconomic known resources as defined in U.S. Geological Survey Circular 831. On the basis of these data, the staff will evaluate the licensees' or responsible party's estimation of potential future exploitation considering market values and current and projected demand for the resource in question. On the basis of the resources identified, the staff will examine the potential for site disruption resulting from exploration and exploitation techniques including, but not limited to, augering, drilling, shaft mining, strip mining, bulldozing and other excavation, quarrying, bore-hole injection and pumping, uprooting of vegetation, blasting, stream diversion, and dam construction. These ,

techniques are considered for the possibility of direct site intrusion as well as indirect effects  !

such as alternation of groundwater tables or increase in erosion. l Samole Evaluation Findinas None.

l DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99 i

j

p- 1 18 SUGGESTED FORMAT'

1. Length: not to exceed 5 pages

. 2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and )

70" August 1989. Licensees are also encouraged to submit the information in electronic format.

(

l 3.9 ECOLOGY / ENDANGERED SPECIES :

The purpose of the review of the license's description of th'e ecology and endangered species ]

at the site is to determine if the decommissioning alternative chosen by the licensee will have -

an adverse impact on the ecology or endangered species ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(i),40.42(g)(4)(i),70.38(g)(4)(i) and 72.54(g)(1) d Reaulatory Guidance None jnformation Reauirements i

The information supplied by the licensee should be sufficient to enable the staff to determine whether the decommissioning attemative chosen by the licensee will have an adverse impact on site ecology or endangered species at the site. The staff's review should verify that the I following information is included in the previous burials section of the decommissioning plan: I e a list of commercially or recreationally important invertebrate species known to occur within 5 km of the site e a list of all commercially important floral species known to occur within 5 km of the site e a list of commercially or recreationally important vertebrate animals known to occur within 5 km of the site.

estimates of the relative abundance of both commercially and recreationally important game and nongame vertebrates e a list of all endangered species at or within 5 km of the site j

i DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99 1

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19 EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under"Information Requirements",

above is included in the licensee's description of former burials at the site. The staff will review site information provided by the licensee or responsible party in both the decommissioning plan and Environmental Report (ER), if an ER was submitted. The staff will review for completeness of information on biotic features in the decommissioning plan based on information provided by the licensee or responsible party, information acquired during site visits, and consultation with appropriate local, State, and Federal agencies, including the U.S. Fish and Wildlife Service and the director of the State fish and wildlife agency. The staff will assess the probable effect of the decommissioning alternative chosen by the licensee or responsible party on these species.

Samole Evaluation Findinas None.

SUGGESTED FORMAT

1. Length: not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 3-5 paragraphs summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

l DRAFTNMSS Decommissioning SRP - For Review and Comment Only 6f7/99

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 4.0 RADIOLOGICAL STATUS OF FACILITY This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all camments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

I l

1 This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 4.0 RADIOLOGICAL STATUS OF FACILITY RESPONSIBILITY FOR REVIEW Primary: NMSS: Division of Waste Management - Decommissioning Branch Division of Fuel Cyc!e Safety and Safeguards - Licensing Branch Region I: Division of Nuclear Materials Safety - Decommissioning and Laboratory Branch Region 11: Division of Nuclear Materials Safety - Materials Licensing / Inspection Branch 1 Region Ill: Division of Nuclear Material Safety - Decommissioning Branch Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing Branch, Fuel Cycle and Decommissioning Branch Secondary: None Suocort: None DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

)

i l

1

2 AREAS OF REVIEW The staff will review the information supplied by the licensee or responsible party to determine if the description of the current radiological status of the facility is adequate to allow the staff to fully understand the types and levels of radioactive material contamination and the extent of radioactive material contamination at the facility. This information will be used by the staff during their review of the licensee's or responsible party's decommissioning activities, to evaluate the cost estimates for decommissioning, and decommissioning health and safety plans. This information should include summaries of the types and extent of radionuclide contamination in all media at the facility including buildings, systems and equipment, surface and subsurface soil, as well as surface and groundwater. Information presented in this section of the SRP should be developed based on the methodologies and procedures described in Section 14 of this SRP (Facility Radiation Surveys). Information describing how the licensee or responsible party developed the information presented in this section should be presented in the Radiation Surveys section of the decommissioning plan. If the licensee or responsible party combines the description of how the radiological status of the facility was determined with the results of the evaluation, NRC staff shall evaluate the licensee's methodology using the appropriate sections of Section 14 of this SRP.

REVIEW PROCEDURES Acceptance Review The staff will review the decommissioning plan to ensure that, at a minimum, the decommissioning plan contains the information summarized under " Areas of Review," above.

Staff will review the radiological status portion of the decommissioning plan without assessing the technical accuracy or completeness of the information. The adequacy of the information will be assessed during the detailed technical review. Staff will review the decommissioning plan table of contents and the individual descriptions under " Areas of Review," above, to ensure that the licensee or responsible party has included this information in the decommissioning plan and to determine if the level of detail of the information appears to be adequate for the staff to perform a detailed technical review.

Safety Evaluation The material to be reviewed is informationalin nature, and no specific detailed technical analysis is required. The staff will verify that the licensee or responsible party has summarized the radiological status of all buildings and equipment, surface and subsurface soil, and ground and surface water at the site.

4.1 CONTAMINATED STRUCTURES The purpose of the review of the description of the contaminated structures is to evaluate whether the licensee has fully described the types and activity of radioactive material contamination in the structures, as well as the extent of this contamination. This information DRAFTNMSS Decommissioning SRP - For Review and Comment Only 617/99 l

1

- -------- J

i 3

should be sufficient to allow the NRC staff to evaluate the potential safety issues associated with remediating the structures, whether the remediation activities and radiation control i measures proposed by the licensee or responsible party (described in Sections 8 and 10 of this SRP) are appropriate for the type of radioactive material present in the structure, whether the licensee's or responsible party's waste management practices are appropriate and whether the I licensee's or responsible party's cost estimates are plausible, given the amount of contaminated material that will need to be removed or remediated.

4 ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(i),10 CFR 40.42(g)(4)(i),10 CFR 70.38(g)(4)(i)(i),10 CFR 72.54(g)1 Reaulatory Guidance 4 Draft Branch Technical Position on Site Characterization for Decommissioning NUREG-1575 - Multi-Agency Radiological Survey and Site investigation Manual .

NUREG 1754 - Technology, Safety and Costs of Decommissioning Reference Non-Fuel Cycle ,

Nuclear Facilities, Addendum 1 '

information Reauirements

' The information_ supplied by the licensee should be sufficient to enable the staff to fully understand the types and activity of radioactive material contamination in the structure, as well as the extent of this contamination. The staff's review should verify that the following information is included in the contaminated structures section of the facility decommissioning plan:

e a list or description of all structures at the facility where licensed activities occurred that contain resdiual radioactive material in excess of site background levels; e a summary of the structures and locations at the facility that the licensee or responsible party has concluded have not been impacted by licensed operations and the rarionale for the conclusion; e a list or description of each room or work area within each of these structures; e a summary of the background levels used during scoping or characterization surveys;  ;

e a summary of the locations of contamination (i.e., walls, floors, wall / floor joints, I structural steel surfaces, ceilings, etc.) in each room or work area i e a summary of the radionuclides p. resent at each location, the maximum and average radionulide activities in dpm/100cm , and, if multiple radionuclides are present, the radionuclide ratios; e the mode of contamination for each surface (i.e., whether the radioactive materialis present only on the surface of the material or if it has penetrated the material);

e the maximum and average radiation levels in mrem /hr in each room or work area; and e a scale drawing or map of the rooms or work areas showing the locations of ,

radionuclide material contamination. I i

l DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99 l

i

.! k 4

EVALUATION FINDINGS I

Evaluation Criteria 1

,The staff should verify that the information summarizec under "Information Requirements," 1 above,'is included in the licensee's description of the contaminated structures. The staff's j

~ review should verify that the licensee has fully described the types and activity of radioactive J material contamination in facility structures, as well as the extent of this contamination. These {'

descriptions should be sufficient to allow the NRC staff to evaluate the potential safety issues

~ associated with remediating the structures, whether the remediation activities and radiation

. control measures proposed by the licensee or responsible party are appropriate for the type of i radioactive material present in the structures, whether the licensee's or responsible party's I waste management practices are appropriate, and whether the licensee's or responsible party's

. cost estimates are plausible, given the amount of contaminated material that will need to be removed or remediated.-

Samole Evaluation Findinos The staff may combine the evaluation finding for the licensee's or responsible party's description of contaminated structures with the findings for the remaining areas in this section of ihe SRP as follows:

The NRC staff has reviewed the information in the Radiological Status section of the Decommissioning Plan for the [ insert name and (license number) of facility) located at [ insert location of facility] according to the NMSS Decommissioning Standard Review Plan, Section 4 (Radiological Status of Facility). Based on this review, the NRC staff has determined that the licensee [ insert name] has described the types and activity of radioactive material contamination at its facility sufficiently to allow the NRC staff to evaluate the potential safety issues associated with remediating the facility, whether the remediation activities and radiation control measures proposed by the licensee or responsible party are appropriate for the type of radioactive material present at the facility, whether the licensee's or responsible party's waste management practices are appropriate, and whether the licensee's or responsible party's cost estimates are i plausible, given the amount of contaminated material that will need to be removed or

. remediated. .

I SUGGESTED FORMAT

1. Length: not to exceed 3 pages

2. . Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard

. Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and

- 70" August 1989.

3. The information may be summarized in narrative format. However, licensees should be encouraged to present the material in tabular format to the maximum extent possible.

Licensees are also encouraged to submit the information in electronic format.

DRAFT NntSS Decommissioning SRP - For Review and Comment Only 6/7/99

5 4.2 . CONTAMINATED SYSTEMS AND EQUIPMENT-The purpose of the review'of the description of the contaminated systems and equipment at the facility is to evaluate whether the licensee has fully described the types and activity of l radioactive material contamination in facility systems or on equipment, as well as the extent of this contamination. This information should be sufficient to allow the NRC staff to evaluate the potential safety issues associated with remediating the systems or equipment, whether the remediation activities and radiation control measures proposed by the licensee or responsible party (described in Sections 8 and 10 of this SRP) are appropriate for the type of radioactive material present in the. systems or equipment, whether the licensee's or responsible party's waste management practices are appropriate and whether the licensee's or responsible party's

. cost estimates are plausible, given the amount of contaminated material that will need to be removed or remediated.

ACCEPTANCE CRITERIA -

Reaulatorv Reouirements 10 CFR 30.36(g)(4)(i),10 CFR 40.42(g)(4)(i),.10 CFR 70.38(g)(4)(i),10 CFR 72.54(g)1 Reaulatory Guidance',

Draft Branch Technical Position on Site Characterization for Decommissioning NUREG-1575 - Multi-Agency Radiological Survey and Site investigation Manual NUREG 1754 - Technology, Safety and Costs of Decommissioning Reference Non-Fuel Cycle Nuclear Facilities, Addendum 1' information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the types and activity of radioactive material contamination present in systems or on equipment, as well as the extent of this contamination. The staff's review should verify that the following information is included in the contaminated systems and equipment section of the facility decommissioning plan:

• a list or description and the location of all systems or equipment at the facility that contain resdiual radioactive material in excess of site background levels; e- a summary of the radionuclides present in each systems or on the equipment at each Llocation, the maximum'and average radionulide activities in dpm/100cm2 , and, if multiple radionuclides are present, the radionuclide ratios; e the maximum and average radiation levels in mrem /hr at the surface of each piece of equipment; .. .

e a summary of the background levels used during scoping or characterization surveys; and,-

a a scale drawing or map of the rooms or work areas showing the locations of the contaminated systems or equipment; DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

g 6

EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements,"

above is included in the licensee's description of the contaminated systerns or equipment. The staff's review should verify that the licensee has fully described the types and activity of radioactive material contamination in the facility systems or on equipment, as well as the extent of this contam.ination. These descriptions should be sufficient to allow the NRC staff to evaluate the potential safety issues associated with remediating the systems or equipment, whether the remediation activities and radiation control measures proposed by the licensee or responsible j party are appropriate for the type of radioactive material present in the systems or equipment,  !

whether the licensee's or responsible party's waste management practices are appropriate and whether the licensee's or responsible party's cost estimates are plausible, given the amount of contaminated material that will need to be removed or remediatcJ.

Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licenss9's or responsible party's description of contaminated systems or equipment with the findings for the remaining areas in this section of the SRP (see Section 4.1, above)

SUGGESTED FORMAT

1. Length: not to exceed 3 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. The information may be summarized in narrative format. However, licensees should be encouraged to present the material in tabular format to the maximum extent possible.

Licensees are also encouraged to submit the information in electronic format.

4.3 - SURFACE SOIL CONTAMINATION The purpose of the review of the description of surface soil (i.e., soil within the top 15 cm of the soil column) contamination is to determine if the licensee has fully describeo the types and activity oi radioactive material contamination in the surface soil, as well as the extent of this contamination. This information should be sufficient to allow the NRC staff to evaluate the potential safety issues associated with remediating the surface soil, whether the remediation activities and radiation control measures proposed by the licensee or responsible party (described in Sections 8 and 10 of this SRP) are appropriate for the type of radioactive material present in the surface soil, whether the licensee's or responsible party's waste management practices are appropriate and whether the licensee's or responsible party's cost estimates are l plausible, given the amount of contaminated soil that will need to be removed or remediated.

i DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 i

7

' ACCEPTANCE CRITERIA -

' Reaulatorv'Reauirements, 10 CFR 30.36(g)(4)(i),10 CFR 40.42(g)(4)(i),10 CFR 70.38(g)(4)(i),10 CFR 72.54(g)1 Reaulatory Guidance

. Draft Branch Technical Position on Site Characterization for Decommissioning NUREG-1575 - Multi-Agency Radiological Survey and Site investigation Manual NUREG 1754 - Technology, Safety and Costs of Decommissioning Reference Non-Fuel Cycle Nuclear Facilities, Addendum 1 Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the types and activity of radioactive material in surface soil, as well as the extent of this contamination. The staff's review should verify that the following information is included in the description of contaminated surface soil in the facility decommissioning plan:

• a list or description of all locations at the facility where surface soil contains residual radioactive material in excess of site background levels;

'a summary of the background levels used during scoping'or characterization surveys e

a summary of the radionuclides present at each location, the maximum and average radionuclide activities in pCi/gm, and, if multiple radionuclides are present, the radionuclide ratios; e the maximum and average radiation levels in mrem /hr at each location; and

• a acale drawing or map of the site showing the locations of radionuclide material contamination in surface soil; -

EVALUATION FINDINGS '

Evaluation Criteria The staff should verify that the information summarized under *1nformation Requirements,"

above is included in the licensee's description of the surface soil contamination at the facility The staff's review should verify that the licensee has fully described the types and activity of radioactive material contamination in the surface soil at the facility, as well as the extent of this contamination. These descriptions should be sufficient to allow the NRC staff to evaluate the potential safety issues associated with remediating the soil, whether the remediation activities and radiation control measures proposed by the licensee or responsible party are appropriate for the type of radioactive material present in the soil, whether the licensee's or responsible party's waste management practices are appropriate and whether the licensee's or responsible party's cost estimates are plausible, given the amount of contaminated material that will need to be removed or remediated.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99 l

8 Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of surface soil contamination with the findings for the remaining areas in this section of the SRP (see Section 4.1, above).

SUGGESTED FORMAT

1. Length: not to exceed 3 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. The information may be summarized in narrative format. However, licensees should be encouraged to present the material in tabular format to the maximum extent possible.

Licensees are also encouraged to submit the information in electronic format.

4.4 SUBSURFACE SOIL CONTAMINATION The purpose of the review of the description of subsurface soil (i.e., soil below the top 15 cm of soil in the soil column) contamination is to determine if the licensee has fully described the types and activity of radioactive material contamination in the subsurface soil, as well as the extent of this contamination. This information should be sufficient to allow the NRC staff to evaluate the potential safety issues associated with remediating the subsurface soil, whether the remediation activities and radiation control measures proposed by the licensee or responsible party (described in Sections 8 and 10 of this SRP) are appropriate for the type of radioactive material present in the subsurface soil, whether the licensee's or responsible party's waste management practices are appropriate and whether the licensee's or responsible party's cost estimates are plausible, given the amount of contaminated soil that will need to be removed or remediated.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(i),10 CFR 40.42(g)(4)(i),10 CFR 70.38(g)(4)(i),10 CFR 72.54(g)1 Reaulatory Guidance Draft Branch Technical Position on Site Characterization for Decommissioning NUREG-1575 - Multi-Agency Radiological Survey and Site investigation Manual NUREG 1754 - Technology, Safety and Costs of Decommissioning Reference Non-Fuel Cycle Nuclear Facilities, Addendum 1 DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

9 information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the types and activity of radioactive materialin subsurface soil, as well as the extent of this contarnination. The staff's review should verify that the following information is included in the description of contaminated subsurface soilin the facility decommissioning plan:

e a list or description of all locations at the facility where subsurface soil contains residual radioactive materialin excess of site background levels;

• . a summary of the background levels used during scoping or characterization surveys I e a summary of the radionuclides present at each location, the maximum and average radionulide activities in pCi/gm, and, if multiple radionuclides are present, the j radionuclide ratios; I e

e the depth of the subsurface soil contamination at each location; and j a scale drawing or map of the site showing the locations of subsurface soil  !

contamination.

EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements,"

above is included in the licensee's description of the subsurface soil contamination at the facility. The staff's review should verify that the licensee has fully described the types and activity of radioactive material contamination in the subsurface soil at the facility, as well as the extent of this contamination. These descriptions should be sufficient to allow the NRC staff to evaluate the potential safety issues associated with remediating the subsurface soil, whether the remediation activities and radiation control measures proposed by the licensee or ,

responsible party are appropriate for the type of radioactive material present in the subsurface soil, whether the licensee's or responsible party's waste management practices are appropriate .

and whether the licensee's or responsible party's cost estimates are plausible, given the j amount of contaminated material that will need to be removed or remediated.

Samole Evaluation Findinas l

None. The staff should combine the evaluation finding for the licensee's or responsible party's description of subsurface soil contamination with the findings for the remaining areas in this section of the SRP (see Section 4.1, above).

SUGGESTED FORMAT

1. Length: not to exceed 3 pages .

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

10

3. The information may be summarized in narrative format. However, licensees should be encouraged to present the materialin tabular format to the maximum extent possible.

Licensees are also encouraged to submit the information in electronic format.

4.5 SUHFACE WATER  ;

The purpose of the review of the description of contaminated surface water is to evaluate whether the licensee has fully described the types and activity of radioactive material present in surface water bodies at the facility, as well as the extent of this contamination. This information should be sufficient to allow the NRC staff to evaluate potential safety issues associated with remediating the surface water, whether the remediation activities and radiation control measures proposed by the licensee or responsible party (described in Sections 8 and 10 of this SRP) are appropriate for the type of radioactive material present in the surface water, whether the licensee's or responsible party's waste management practices are appropriate and whether the licensee's or responsible party's cost estimates are plausible, given the amount of contaminated water that will need to be removed or remediated.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(i),10 CFR 40.42(g)(4)(i),10 CFR 70.38(g)(4)(i),10 CFR 72.54(g)1 Reaulatory Guidance Draft Branch Technical Position on Site Characterization for Decommissioning NUREG-1575 - Multi-Agency Radiological Survey and Site investigation Manual Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the types and activity of radioactive material contamination in surface water at the facility, as well as the extent of this contamination. The staff's review should verify that the following information is included in the description of surface water contamination in the decommissioning plan:

e a list or description of all surface water bodies at the facility that contain residual radioactive materialin excess of site background levels; e

a summary of the background levels used during scoping or characterization surveys e a summary of the radionuclides present in each surface water body and the maximum and average radionuclide activities in pCi/l.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 .

l

)

I1

- EVALUATION FINDINGS

' Evaluation Criteria The staff should verify that the information summarized under"Information Requirements,"

above, is included in the licensee's description of the sudace water contamination at the site.

The staff's review should verify that the licensee has fully described the types and activity of radioactive material contamination in the sudace water at the site, as well as the extent of this contamination. These descriptions should be sufficient to allow the NRC staff to evaluate potential safety issues associated with remediating the surface water, whether the remediation activities and radiation control measures proposed by the licensee or responsible party are appropriate for the type of radioactive material present in the water, whether the licensee's or responsible party's waste management practices are appropriate and whether the licensee's or responsible party's cost estimates are plausible, given the amount of contaminated material that will need to be removed or remediated.

Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of contaminated surface water with the findings for the remaining areas in this section of the SRP. (See section 4.1, above).  ;

SUGGESTED FORMAT i

1. Length: not to exceed 2 pages ,

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and l

70" August 1989.

3. The information may be summarized in narrative format. However, licensees should be encouraged to present the material in tabular format to the maximum extent possible.

Licensees are also encouraged to submit the information in electronic format.

4.6 GROUNDWATER The purpose of the review of the description of contaminated groundwater is to evaluate whether the licensee has fully described the types and activity of radioactive material present in groundwater at the facility, as well as the extent of this contamination. This information should be sufficient to allow the NRC staff to evaluate potential safety issues associated with remediating the groundwater, whether the remediation activities and radiation control measures proposed by the licensee or responsible party (described in Sections 8 and 10 of this SRP) are appropriate for the type of radioactive material present in the groundwater, whether the ,

licensee's or responsible party's waste management practices are appropriate and whether the l licensee's or responsible party's cost estimates are plausible, given the amount of contaminated water that will need to be removed or remediated.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 \

m

[

12 ACCEPTANCE CRITERIA' Reaulatory Reauirements 10 CFR 30.36(g)(4)(i),10 CFR 40.42(g)(4)(i),' 10 CFR 70.38(g)(4)(i),10 CFR 72.54(g)1 Reaulatorv Guidance -

)

Draft Branch Technical Position on Site Characterization for Decommissioning NUREG 1575 - Multi-Agency Radiological Survey and Site investigation Manual NUREG 1754 - Technology, Safety and Costs of Decommissioning Reference Non-Fuel Cycle Nuclear Facilities, Addendum 1 Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the types 'and activity of radioactive material contamination in groundwater at the facility, as well as the extent of this contamination. The staff's review should verify that the following information is included in the description of groundwater contamination in the L decommissioning plan:

e a summary of the aquifer (s) at the faci!ity that contain residual radioactive material in excess of site background levels; e a summary of the background levels used during scoping or characterization surveys a summary of the radionuclides present in each aquifer and the maximum and average radionulide activities in pCi/l EVALUATION FINDINGS

- Evaluation Criteria The staff should verifv that the information summarized under "Information Requirements?

above, is included in the licensee's description of the groundwater contamination at the site.

The staff's review should verify that the licensee has fully described the types and activity of radioactive material contamination in the groundwater at the site, as well as the extent of this contamination. These descriptions should be sufficient to allow the NRC staff to evaluate the potential safety issues associated with remediating the groundwater, whether the remediation actMties and radiation control measures proposed by the licensee or respotisible party are  ;

appropriate for the type of radioactive material present in the groundwater, whether the i hcensee's or responsible party's waste management practices are appropriate and whether the i licensee's or responsible party's cost estimates are plausible, given the amount of contaminated material that will need to be removed or remediated.

Sample Evaluation Findine l

ORAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99

13 None. The staff should combine the evaluation finding for the licensee's or responsible party's description of contaminated groundwater with the findings for the remaining areas in this section of the SRP. (See section 4.1)

. SUGGESTED FORMAT

1. Length: not to exceed 3 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. The information may be summarized in narrative format. However, licensees should be encouraged to present the material in tabular format to the maximum extent possible.

Licensees are also encouraged to submit the information in electronic format.

j This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has  !

reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

Cn. AFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

NMSS DECOMMISSIONING PROGRAM

, STANDARD REVIEW PLAN 5.0 DOSE MODELING FOR DECOMMISSIONING 1

NRC STAFF IS CURRENTLY COMPLETING DEVELOPMENT OF THIS MODULE.

WHEN COMPLETED, IT WILL BE POSTED ON THE WORLD WIDE WEB AT:

http://techconf,llnl. gov /cgi-bin / library? source =*& library =Lic_ Term _ lib & file =*

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the i public'on the draft SRP, the staff will issue the SRP in final form.

L_._ . _ .

I l

}

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 6.0 ALTERNATIVES CONSIDERED AND RATIONALE FOR CHOSEN ALTERNATIVE l

1 l

i This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has '

reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

c i

1 This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all '

comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 6.0 ALTERNATIVES CONSIDERED AND RATIONALE FOR CHOSEN ALTERNATIVE RESPONSIBILITY FOR REVIEW Primary: NMSS: Division of Waste Management - Decommissioning Branch Division of Fuel Cycle Safety and Safeguards - Licensing Branch Region 1: Division of Nuclear Materials Safety - Decommissioning and Laboratory Branch Region ll: Division of Nuclear Materials Safety - Materials Licensing / Inspection Branch 1 Region lil: Division of Nuclear Material Safety - Decommissioning Branch i

Region IV: Division of Nuclear Material Safety - Nuclear Materials Ucensing Branch, Fuel Cycle and Decommissioning Branch i Secondarv: None Support: Office of General Counsel DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99

2 NOTE TO DECOMMISSIONING PLAN REVIEWERS:

THE GUIDANCE IN THIS SECTION OF THE SRP APPLIES ONLY TO LICENSEES APPLYING FOR LICENSE TERMINATION UNDER 10 CFR 20.1403 (RESTRICTED USE) OR 10 CFR 20.1404 (ALTERNATE CRITERIA). THE INFORMATION WILL BE USED BY NRC STAFF TO SUPPORT THE DEVELOPMENT OF AN ENVIRONMENTAL A"S!SSMENT OR ENVIRONMENTAL IMPACT STATEMENT.

LICENSEES APPLYING FOR LICENSE TERMINATION PURSUANTTO 10 CFR 20.1402 (UNRESTRICTED USE) DO NOT NEED TO SUPPLY THIS INFORMATION AREAS OF REVIEW The staff will review the information supplied by the licensee or responsible party to determine if the licensee has identified and adequately evaluated all reasonable alternatives that could accomplish the decommissioning objective (s) identified in the decommissioning plan.

Information submitted should include descriptions of all reasonable decommissioning alternatives evaluated by the licensee; the impacts of each altemative; the environmental, economic, and or societal advantages and disadvantages of each alternative; and, the licensee's rationale for selecting the preferred attemative described in the decommissioning plan.

REVIEW PROCEDURES Acceptance Review q

The staff will review the decommissioning plan to ensure that, at a minimum, the decommissioning plan contains the information summarized under " Areas of Review," above.

f

. Staff wdl review the evaluation of decommissioning alternatives in the decommissioning plan

{

without assessing the technical accuracy or completeness of the information. The adequacy of the information will be assessed during the detailed technical review. Staff will review the {

j decommissioning plan table of contents and the individual descriptions under " Areas of j Review,* above, to ensure that the licensee or responsible party has included this information in '

the decommissioning plan and to determine if the level of detail of the information appears to be adequate for the staff to pedorm a detailed technical review.

Safetv Evaluation The material to be reviewed is informational in nature, and no specific detailed technical analysis is required. The staff will verify that the licensee has identified all reasonable alternatives that could accomplish the decommissioning objective (s). The staff will make a qualitative assessment as to whether the licensee's or responsible party's descriptions of the attematives are complete and adequate. Typically, NRC staff practice and guidance in the past DRAFT NhtSS Decommissioning SRP - For Review and Comment Only 6/7/99 I

i

3 1

~ has been to rely on the environmentally superior' alternative in selecting the preferred altemative for decommissioning actions. As such, the staff should ensure that the etivironmentally s superior alternative is evaluated by the licensee in the decommissioning plan.

6,1 ALTERNATIVES CONSIDERED The purpose of the review of the description of decommissioning attematives other than that proposed by the licensee in the decommissioning plan is to ensure that the attemative proposed by the licensee is the environmentally superior altemative.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 51.45 Reaulatorv Guidance Counsel on Environmental Quality (CEO) 40 Most Asked Questions About the National Environmental Policy Act (NEPA)

Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand what impacts result from each attemativa identified by the licensee. The staff should verify that the following information is included in the discussion of each alternative, including the licensee's proposed attemative:

e ' a description of the facility if the attemative is employed; e a summary of the health effects to adjacent communities if the alternative is employed;

e a summary of the impacts on community resources such as land use and property {

values; 1

• . a summary of the impacts on the geology, hydrology, air quality and ecology in and around the site; e a description of impacts to minority or low-income populations within a 0.6 mile radius of the center of the facility (urban location) or within a 4 mile radius of the center of the facility (rurallocation);

e if appropriate, an assessment of the potential for criticality; e a summary of the irreversible and irretrievable commitment of resources.

e an analysis of the proposed attemative and other attematives as required by 10 CFR 51.49c);

I 1

'It this context " environmentally superior" is defined as the attemative that, it selected, results in the lowest v >ses to the public at the completion of decommissioning and the retums the site to as close to a pre-licensin j condition as possible 1

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/9 9 l l

)

4

-e - a list of the permits, licenses, approvals, and other entitlements and the discussion of the status of compliance with these requirements required in 10 CFR 51.45(d)

EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's evaluation of altematives to the proposed decommissioning ,

altemative, NRC regulations at 10 CFR Part 51 require that all reasonable altematives will be '

identified. An otherwise reasonable attemative will not be excluded from discussion solely on the ground that it is not within the jurisdiction of the NRC (Appendix A to Subpart A, item 5). <

l 1

Reasonable altematives include those that are practical or feasible from a common sense, l technical, or economic standpoint, rather than simply being desirable from the standpoint of the applicant (CEO's 40 Most Asked Questions,2a). In fact, an altemative that is outside the legal jurisdiction of the NRC must stdl be analyzed if it is reasonable (CEO's 40 Most Asked Questions,2b). A potential conflict with local, State, tribal, or Federal law does not necessarily render an attemative unreasonable, although such conflicts must be considered and discussed.

For instance, a local law that prohibits on-site disposal of radioactive waste might conflict with the licensee's proposal, but that conflict would not be a sufficient basis to conclude that on-site disposal is not reasonable and that the alternative should not be considered in detail.

Alternatively, the fact that NRC regulations prohibit an attemative is not a sufficient reason to consider it an unreasonable attemative if it would have environmental advantages and would be technically feasible.

Many conceivable attematives are not considered to be reasonable. Alternatives that offer no potential environmental or other advantage (e.g., cost savings) need not be considered. Other attematives may have potential advantages, but the attemative may not be reasonable if the advantages are not sufficient to compensate for the altemative's adverse aspects. For instance, an alternative of excavating buried wastes, sorting it to place the most radioactive wastes on the bottom, and reburying the remaining waste could reduce the potential dose to an intruder, but at considerable' expense and relatively high doses to workers, in addition, many minor variations of attematives can be invented. Unless these variations exhibit appreciably different impacts, they should not be analyzed as separate attematives. While the full spectrum of reasonable attematives must be identified and evaluated, attematives that are only minor variations of other altematives are more likely to confuse the decision maker than to help clarify the decision.

Samole Evaluation Findinos The NRC staff has reviewed the information in the evaluation of the Decommissioning Attematives in the Decommissioning Plan for the [ insert name and (license number) of facility]

located at [ insert location of facility) according to the NMSS Decommissioning Standard Review Plan, Section 6 (Alternatives Considered and Rationale for Chosen Alternative). Based on this

' DRAFT NHSS Decommissioning SRP - For Review and Comment Only 6/7/99

r NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 7.0 SUBPART E ALARA REQUIREMENTS NRC STAFF IS CURRENTLY COMPLETING DEVELOPMENT OF THIS MODULE.

WHEN COMPLETED, IT WILL BE POSTED ON THE WORLD WIDE WEB AT:

http://techconf.llnl. gov /cgi-bin / library? source =*& library =Lic_ Term _ lib & file =*

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has myiewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

1 1

I i

l NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 8.0 PLANNED DECOMMISSIONING ACTIVITIES This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the  ;

public on the draft SRP, the staff will issue the SRP in final form. I i

L

1 This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed- evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 8.0 PLANNED DECOMMISSIONING ACTIVITIES RESPONSIBILITY FOR REVIEW Primary: NMSS: Division of Waste Management - Decommissioning Branch Division of Fuel Cycle Safety and Safeguards - Licensing Branch Region 1: Division of Nuclear Materials Safety - Decommissioning and Laboratory Branch Region 11: Division of Nuclear Materials Safety- Materials Licensing / inspection Branch 1 Region lil: Division of Nuclear Material Safety - Decomm; <tioning Branch Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing Branch, Fuel Cycle and Decommissioning Branch Secondarv: None Suooort: None AREAS OF REVIEW The staff will review the information supplied by the licensee or responsible party to determine if ,

the description of the planned decommissioning activities is adequate to allow the staff to fully {

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99 U

2 understand the methods and procedures the licensee or responsible party intends to use to remove residual radioactive material at the site to levels that allow for release of the site in

accordance with NRC requirements. This information should include descriptions of how the licensee or responsible party intends to remediate structures, systems and equipment, surface and subsurface soil, and surface and groundwater at the site. In addition, the licensee or responsible party should provide a schedule that demonstrates how the licensee will complete the interrelated decommissioning activities and the timeframes for completing the decommissioning.; The licensee or responsible party should also summarize which activities are being performed by licensee or responsible party staff and those being performed by decommissioning contractors, including which activities are being performed under the licensee's license and which are being performed under the contractor's license.

REVIEW PROCEDURES  !

. Acceptance Review

.The staff will ensure that the decommissioning plan contains the information summarized under

" Areas of Review," above. Staff will review the planned decommissioning activities portion of the decommissioning plan without assessing the technical accuracy or completeness of the information contained therein. The adequacy of this information will be assessed during the detailed technical review. Staff will review the decommissioning plan table of contents and the individual descriptions under " Areas of Review," above, to ensure that the licensee or responsible party has included this information in the decommissioning plan and to determine if the level of detail of the information appears to be adequate for the staff to perform a detailed technical review. '

Safety Evaluation

- The material to be reviewed is informational in nature, and no specific detailed technical analysis is required. The staff will make a qualitative assessment as to whether the licensee's or responsible party's descriptions of planned decommissioning activities are adequate to serve as the basis for evaluating the licensee's or responsible party's methods and procedures I for remediating the site and whether the decommissioning activities proposed by the licensee to remediate the facility can be conducted safely. . In addition, the staff will ensure that the >

licensee's or responsible paity's proposed schedule for completing the decommissioning f complies with the NRC's requirements under 10 CFR 30.36(h),10 CFR 40.42(h),70.38(h) or 72.54(j). Finally, the staff will ensure that the licensee and contractor are already authorized to perform the decommissioning procedures described in the decommissioning plan or that the licensee has described the decommissioning procedures sufficiently to allow the staff to  ;

incorporate them into the license.

8.1 CONTAMINATED STRUCTURES The purpose of the review of the description of the planned decommissioning activities for contaminated structures is to allow the staff to fully understand what methods and procedures DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

F )

3 the licensee or responsible party will undertake to remediate the contaminated structure. This will enable the staff to evaluate the licensee's methods and procedures to qualitatively assess if they can be performed safely and in compliance with NRC's requirements. This information may also aid the staff in evaluating the estimates of radioactive waste that will be generated )

during decomrnissioning, the cost estimates for the decommissioning, and the ALARA '

evaluations developed by the licensee or responsible party to support the decommissioning. .

I ACCEPTANCE CRITERIA Reaulatory Reauirements n

10 CFR 30.36(g),10 CFR 40.42(g),70.38(g),72.54(g)

Reaulatory Guidance None Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand what methods, procedures, and techniques the licensee or responsible party intends to use to remediate the contaminated structure, in addition, the information should be sufficient to allow the staff to determine if the licensee's or responsible party's radiation safety procedures are appropriate, given the level of contamination and proposed method (s) for remediation. The staff's review should verify that the following information is included in the authorized activities section of the facility decommissioning plan:

e a summary of the remediation tasks planned for each room or area in the contaminated structure in the order in which they will occur including which activities will be conducted by licensee staff and which will be performed by a contractor; e a brief summary of the radionuclides, maximum activities of radionuclides and radiation -

levels in each area or room of the contaminated structure; e

a description of the remediation techniques' (such as scabbling, hydrolazing or grit {

blasting) that will be employed in each room or area of the contaminated structure;  !

e a summary of the radiation protection methods (such as PPE, step-off pads and exit monitoring) and control procedures (such as scabbler shrouds, HEPA vented enclosures  ;

or superfine water misting) that will be employed in each room or area2;

' Licensees or responsible party's may generically describe these techniques once at the beginning of the contaminated structures section and refer to them in the descriptions of the remediation of the individual rooms or areas The staff's technical review of the adequacy of the licensee's or responsible party's radiation safety I procedures should be performed pursuant to the criteria in Section 10 of this SRP. In this section of the SRP the staff should make a qualitative assessment of the adequacy of the radiation protection and control methods proposed by the licensee or responsible party to determine if the procedures described in the Health and Safety section of the decommissioning plan have been followed.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

w i

4

'e a summary of the procedures already authorized under the existing license and those for which approval is being requested in the decommissioning plan; e- . a commitment to' conduct decommissioning activities in accordance with written, approved procedures; and, .

e a summary of any unique safety or remediation issues associated with remediating the room or area.-

If the licensee or responsible party intends to dismantle structures with contamination present in

- excess of the unrestricted use limits, the decommissioning plan should provide a separate summary of the information listed above for the areas containing contamination in excess of the unrestricted use limits._ in addition, the licensee or_ responsible party should provide a

~ description of the techniques and procedures that.will be used to dismantle the building or

. structure and the licensee's or responsible party's procedures for evaluating the areas prior to dismantlement.

EVALUATION FINDINGS Evaluation Criteria

The staff's reCew should verify that the licensee or responsible party has described the remediation activities and associated safety precautions in sufficient detail to allow the staff to make a qualitative assessment of the adequacy of the proposed activities with respect to safety )

in compliance with NRC requirements. The staff should verify that the information summarized -

under "Information Requirements", above, is included in the licensee's description of the decommissioning activities portion of the decommissioning plan. The staff should make a qualitative assesmeni vi the adequacy of the licensee's or responsible party's proposed remediation muhods and procedures to accomplish the remedation objectives in a manner that is protective of workers and the public and in compliance with NRC requirements. Detailed technical review of the safety precautions and procedures should be conducted pursuant to the criteria in Section 10 " Health and Safety Program" of this SRP.

Samole Evaluation Findinas The staff may combine the evaluation finding for the licensee's or responsible party's description of the planned decommissioning activities with the findings for the remaining areas in this section of the SRP as follows:

3 The NRC staff has reviewed the decommissioning activities described in _ the Decommissioning Plan for the (insert name and (license number) of facility) located at [ insert location of facility) -

according to the NMSS Decommissioning Standard Review Plan, Section 8 (Planned Decommissioning Activities). Based on this review the NRC staff has determined that the licensee (insert name) has provided sufficient information to allow the NRC staff to evaluate the

~ licensee's planned decommissioning activities to ensure that the decommissioning can be conducted in accordance with NRC requirements.

SUGGESTED FORMAT DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

5

1. Length: to be commensurate with the number of rooms or areas requiring remediation

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70' August 1989.

3. Bullet 1 under Acceptance Criteria, above should be no more than 1or 2 pages outlining the tasks in tabular form. Bullet 2 should be 1 or 2 sentences for each room or area.

Up to 3 paragraphs summarizing the information requested under bullets 3 and 4.

Bullets 5 and 6 should be 1or 2 sentences. Bullet 7 should be no more than 1 paragraph in length. Licensees are also encouraged to submit the information in electronic format.

8.2 CONTAMINATED SYSTEMS AND EQUIPMENT The purpose of the review of the description of the planned decommissioning activities for contaminated systems and equipment is to allow the staff to fully understand what methods and procedures the licensee or responsible party will undertake to remediate the contaminated systems or equipment at its facility. This will enable the staff to evaluate the licensee's methods and procedures to qualitatively assess if they can be performed safely and in compliance with NRC's requirements. Thi: information may also aid the staff in evaluating the estimates of radioactive waste that will i o generated during decommissioning, the cost estimates for the decommissioning, and the ALARA evaluations developed by the licensee or responsible party to support the decommissioning.

ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 30.36(g),10 CFR 40.42(g),70.38(g),

Reaulatory Guidance None information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand what methods, procedures, and techniques the licensee or responsible party intends to use to remediate the contaminated systems and equipment. In addition, the information should be sufficient to allow the staff to determine if the licensee's or responsible party's radiation safety procedures are appropriate, given the level of contamination and proposed method (s) for remediation. The staff's review should verify that the following information is included in the authorized activities section of the facility decommissioning plan:

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

6 e a summary of the remediation tasks planned for each system in the order in which they will occur including which activities will be conducted by licensee staff and which will be performed by a contractor; e a brief summary of the radionuclides, maximum activities of radionuclides and radiation levels present in or on each system; e a description of the techniques8(such as scabbling, hydrolazing or grit blasting) that will be employed to remediate each system in the facility or site; e a description of the radiation protection methods (such as PPE, step-off pads and exit monitoring) and control procedures (such as scabbler shrouds, HEPA vented enclosures or superfine water misting) that will be employed while remediating each system';

e a summary of the equipment will be removed or decontaminated and how the decontamination will be accomplished; e a summary of the procedures already authorized under the existing license and those for which approval is being requested in the decommissioning plan; e a commitment to conduct decommissioning activities in accordance with written, approved procedures; and, e a summary of any unique safety or remediation issues associated with remediating any system or piece of equipment.

EVALUATION FINDINGS Evaluation Criteria The staff's review should verify that the licensee or responsible party has described the remediation activities and associated safety precautions in sufficient detail to allow the staff to g determine if the proposed activities can be conducted safely and in compliance with NRC

/ requirements. The staff should verify that the information summarized under "Information Requirements", above is included in the licensee's description of the decommissioning activities portion of the decommissioning plan. The staff should make a qualitative assessment of the adequacy of the licensee's or responsible party's proposed remediation methods and procedures to accomplish the remedation objectives in a manner that is protective of workers and the public and in compliance with NRC requirements. Detailed technical review of the safety precautions and procedures should be conducted pursuant to the criteria in Section 10

" Health and Safety Program" of this SRP.

Sample Evaluation Findinos None. The staff should combine the evaluation finding for the licensee's or responsible party's description of decommissioning activities for contaminated systems and equipment with the findings for the remaining areas in this section of the SRP (see Section 8,1, above) 8 Licensees or responsible party's may generically describe these techniques once at the beginning of the contaminated systems section and refer to them in the descriptions of the remediation of the individual systems "See footnote 2 DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99

7 SUGGESTED FORMAT

1. Length: to be commensurate with the number of rooms or areas requiring remediation

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and

-70" August 1989.

3. Bullet 1 under Acceptance Criteria, above should be no more than 1or 2 pages outlining the tasks in tabular form. Bullet 2 should be 1 or 2 sentences for each system. Up to 3 paragraphs summarizing bullets the information requested under 3 and 4. Bullet 5 should be a few pages and in tabular form. Bullets 6 and 7 should be 1or 2 sentences.

Bullet 8 should be no more than 1 paragraph in length. Licensees are also encouraged to submit the information in electronic format.

8.3 SOIL The purpose of the review of the description of the planned decommissioning activities for soil is to allow the staff to fully understand what methods and procedures the licensee or responsible party will undertake to remove or remediate the surface and subsurface soil at the site. This will enable the staff to evaluate the licensee's methods and procedures to qualitatively assess if they can be performed safely and in compliance with NRC's requirements. This information may also aid the staff in evaluating the estimates of radioactive waste that will be generated during decommissioning, the cost estimates for the decommissioning, and the ALARA evaluations developed by the licensee or responsible party to support the decommissioning.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g),10 CFR 40.42(g),70.38(g),

Re_gulatory Guidance None information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand what methods, procedures, and techniques the licensee or responsible party intends to use to remove or remediate contaminated soil at the site. la addition, the information should be sufficient to allow the staff to determine if the licensee's or responsible party's radiation safety procedures are appropriate, given the level of contamination in the soil and proposed method (s) for removal or remediation. The staff's review should verify that the following information is included in the description of soil decommissioning activities in the facility decommissioning plan:

I DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99

8 e a summary of the removal /remediation tasks planned for surface and subsurface soil at the site in the order in which they will occur including which activities will be conducted by licensee staff and which will be pedormed by a contractor; e a brief summary of the radionuclides, maximum activities of radionuclides and radiation I levels present in the surface and subsurface soil; )

e a description the techniques that will be employed to remove or remediaie surface and subsurface soil at the site; ,

e a description of the radiation protection methods (such as PPE, or area exit monitoring) and control procedures (such as the use of HEPA vented enclosures during excavation or covering soil piles to prevent wind dispursion) that will be employed during soil removal /remediation5 ;

e a summary of the procedures already authorized under the existing license and those for which approval is being requested in the decommissioning plan; e a commitment to conduct decommissioning activities in accordance with written, approved procedures; and, e a summary of any unique safety or removal /remediation issues associated with j remediating the soil, l I

EVALUATION FINDINGS 1 Evaluation Criteria The staff's review should verify that the licensee or responsible party has described the remediation activities and associated safety precautions in sufficient detail to allow the staff to determine if the proposed activities can be conducted safely and in compliance with NRC requirements. Tha staff should verify that the information summarized under "Information Requirements", above is included in the licensee's description of the decommissioning activities portion of the decommissioning plan. The staff should make a qualitative assessment of the adequacy of the licensee's or responsible party's proposed remediation methods and procedures to accomplish the remedation objectives in a manner that is protective of workers and the public and in compliance with NRC requirements. Detailed technical review of the safety precautions and procedures should be conducted pursuant to the criteria in Section 10

" Health and Safety Program" of this SRP.

Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of decommissioning activities for soil with the findings for the remaining areas in this section of the SRP (see Section 8.1, above)

SUGGESTED FORMAT

1. Length: 5-10 pages I

5 See footnote 2 l l

)

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99 l l

I 1

4

t 9

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard

- Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70"_ August 1989,

3. Bullet 1 under Acceptance Criteria, above should be no more than 1or 2 pages outlining the tasks in tabular form. Bullet 2 should be 1 or 2 sentences for each area. Up to 3 paragraphs summarizing the information requested under Bullets 3 and 4. Bullets 5 and 6 should be 1 or 2 sentences. Bullet 7 should be no more than 1 paragraph in length.

Licensees are also encouraged to submit the information in electronic format.

8.4  : SURFACE AND GROUNDWATER The purpose of the review of the description of the planned decommissioning activities for surface and groundwater is to allow the staff to fully understand what methods and procedures the licensee or responsible party will undertake to remediate the contaminated water. This will enable the staff to evaluate the licensee's methods and procedures to qualitatively assess if they can be performed safely and in compliance with NRC's requirements. This information may also aid the staff in evaluating the estimates of radioactive waste that will be generated during decommissioning, the cost estimates for the decommissioning, and the ALARA evaluations developed by the licensee or responsible party to support the decommissioning.

ACCEPTANCE CRITERIA Reautatory Reauirements 10 CFR 30.36(g),10 CFR 40.42(g),70.38(g)

Reaulatorv Guidance None information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully i understand what methods, procedures, and techniques the licensee or responsible party intends to use to remediate the contaminated ground or surface water. In addition, the information should be sufficient to allow the staff to determine if the licensee's or responsible

_ party's radiation safety procedures are appropriate, given the level of contamination and proposed method (s) for remediation. The staff's review should verify that the following information is included in the authorized activities section of the facility decommissioning plan:

a summary of the remediation tasks planned for ground and surface water in the order in which they will occur, including which activities will be conducted by licensee staff and which will be pedormed by a contractor; e

a brief summary of the radionuclides and maximum activities of radionuclides present in the ground and sudace water; DRAFT NhfSS Decommissioning SRP - For Review and Comment Only 6f7/99 I

r I

10 e l a description the remediation techniques that will be employed to remediate the ground '

or surface water; e a description of the radiation protection methods and control procedures that will be employed during ground or surface water remediation 8 e a summary of the procedures already authorized under the existing license and those for which approval is being requested in the decommissioning plan e a commitment to conduct decommissioning activities in accordance with written, approved procedures; and, e a summary of any unique safety or remediation issues associated with remediating the ground or surface water.

EVALUATION FINDINGS

{

l Evaluation Criteria  !

The staff's review snou!d verify that the licensee or responsible party hat described the remediation activihs arid associated safety precautions in sufficient detail to allow the staff to determine if the proposed activities can be conducted safely and in compliance with NRC ,

requirements. The staff should verify that the information summarized under "Information Requirements", above is included in the licensee's description of the decommissioning activities  ;

portion of the decommissioning plan. The staff should make a qualitative assessment of the l adequacy of the licensee's or responsible party's proposed remediation methods and I procedures to accomplish the remedation objectives in a manner that is protective of workers and the public and in compliance with NRC requirements. Detailed technical review of the safety precautions and procedures should be conducted pursuant to the criteria in Section 10

" Health and Safety Program" of this SRP.

Eample Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of decommissioning activities for surface and ground water with the findings for the remaining areas in this section of the SRP (see Section 8.1, above) l SUGGESTED FORMAT

1. Length: 4-5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989;

1. Bullet 1 under Acceptance Criteria, above should be no more than 1or 2 pages outlining the tasks in tabular form. Bullet 2 should be 1 or 2 sentences for each area.1-2 paragraphs summarizing the information requested under Bullets 3 and 4. Bullets 5 and 6 should be 1 or 2 sentences. Bullet 7 should be no more than 1 paragraph in length.

Licensees are also encouraged to submit the information in electronic format.

'See footnote 2 DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

11 8.5 SCHEDULES The purpose of the review of the licensee's or responsible party's schedule is to determine whether it complies with NRC's requirements for the completion of decommissioning activities.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(h),10 CFR 40.42(h),70.38(h),72.54(j)

Reaulatorv Guidance Currently under development information Reauirements The schedule supplied by the licenses should be sufficient to enable the staff to fully understand what activities will be performed to complete the decommissioning, the amount of time required to perform the activity and the timeframe for performing the activities. The staff's review should verify that the licensee or responsible party has included e a Gantt or PERT chart detailing the proposed remediation tasks in the order in which they will occur and including the amount of time required to perform each decommissioning activity and the initiation and completion dates for the activities; e

a statement acknowledging that the dates in the schedule are contingent on NRC approval of the decommissioning plan; e

a statement acknowledging that circumstances can change during decommissioning, and, if the licensee determines that the decommissioning cannot be completed as outlined in the schedule, the licensee or responsible party will provide an updated schedule to NRC; and, e if the decommissioning is not expected to be completed within the timeframes outlined in NRC regulations at 10 CFR 30.36(h)(1),10 CFR 40.42(h)(1),70.38(h)(1), or 72.54(j)(1), the staff should verify that the licensee has requested an alternative schedule for completing the decommissioning and has addressed the criteria in NRC regulations at 10 CFR 30.36(h)(2)(i)(1-5),10 CFR 40.42(h)(2)(i) (1-5), 70.38(h)(2)(i)(1-5), or 72.54(k)(1-5)

EVALUATION FINDINGS Evaluation Criteria The staff's review should verify that the licensee's or responsible party's schedule for decommissioning its facility is in compliance with NRC requirements. The staff should verify that the information summarized under "Information Requirements", above is included in the licensee's description of the decommissioning activities portion of the decommissioning plan.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

12 Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of decommissioning activities for soil with the findings for the remaining areas in this section of the SRP (see Section 8.1, above)

SUGGESTED FORMAT

1. Schedule: PERT or Gantt chart

2. Discussion: 1-2 sentences addressing Bullets 2 and 3 above,2-3 paragraphs addressing the criteria in Bullet 4 above.

3. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not

~

represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 9.0 PROJECT MANAGEMENT AND ORGANIZATION i

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow Interested members _of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

I This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 9.0 PROJECT MANAGEMENT AND ORGANIZATION RESPONSIBILITY FOR REVIEW Priman: NMSS: Division of Waste Management - Decommissioning Branch Division of Fuel Cycle Safety and Safeguards - Licensing Branch Region 1: Division of Nuclear Materials Safety - Decommissioning and Laboratory Branch Region 11: Division of Nuclear Materials Safety - Materials Licensinglinspection Branch 1 Region lit: Division of Nuclear Material Safety - Decommissioning Branch Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing Branch, Fuel Cycle and Decommissioning Branch Secondarv: None Support: None AREAS OF REVIEW The staff will review the information supplied by the licensee or responsible party to determine if the description of the licensee's or responsible party's decomrnissioning project organization DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14/99

.2 and management structure is adequate to allow the staff to fully understand how the licensee or responsible party will ensure that it will exercise adequate control over the decommissioning project. This information should include a description of the management structure for the

project, including individual organizational unit reporting responsibilities and lines of authority; a description of how radioactive material work procedures (such as Radiation Work Permits) are developed reviewed, implemented and managed; a description of the qualifications necessary

~ forindividuals performing the various project management and safety functions; a description of the relationship between the various organizational units within the decommissioning organization (such as remedial activities and health and safety units) including the

! responsibilities and authority to revise or stop work; a description of the licensee's or responsible party's training program; and, a description of how contractors performing work at the facility will be managed during the decommissioning project.

REVIEW PROCEDURES -

4 Acceotance Review The staff will ensure that the decommissioning plan contains the information summarized under

" Areas of Review," above. Staff will review the decomrnissioning project management portion of the decommissioning plan without assessing the technical accuracy or completeness of the )

information contained therein. The adequacy of this information will be assessed during the ,

detailed review. Staff will review the decommissioning plan table of contents and the individual 1 descriptions under " Areas of Review," above, to ensure that the licensee or responsible party )

has included this information in the decommissioning plan and to determine if the level of detail of the information appears to be adequate for the staff to perform a detailed technical review.

Safety Evaluation The material to be reviewed is informational in nature, and no specific detailed technical analysis is required. The staff will make a qualitative assessment as to whether the licensee's or responsible party's descriptions of the proposed decommissioning project management and organization is adequate to serve as the basis for concluding that the licensee's or responsible party's management program will ensure that the appropriate control will be exercised during decommissioning operations.

9.1 DECOMMISSIONING MANAGEMENT ORGANIZATION The purpose of the review of the description of the decommissioning project management organization is to verify that the licensee or responsible party has a management organization, management philosophy and ti a personnel resources to ensure that the decommissioning of the facility can be completed stifely and in accordance with NRC requirements.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14/99

3

- ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(ii),'40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2)

Reaulatory Guidance None information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the structure and functions of the decommissioning project management organization. The staff's review should verify that the following information is included in the description of the decommissioning project management organization:

• a description of the decommissioning organization including descriptions of the individual decommissioning project units within the decommissioning project organization, such as project management, health and safety, remedial activities, etc.;

• a description of the responsibilities of each of these decommissioning project units; e description of the reporting hierarchy within the decommissioning project management organization including a chart or diagram showing the relationship of each

)

decommissioning project unit to other project units and decommissioning project management; and

• - a description of the responsibility and authority of each unit to ensure that decommissioning activities are conducted in a safe manner and in accordance with approved written procedures, inc!uding stop work authority of each unit and the manner in which concems about safety issues are managed within the overall decommissioning project.'

EVALUATION FINDINGS Evaluation Criteria The. staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of the decommissioning project management organization, NRC staff should verify that the. descriptions of the decommissioning project management organization and individual project unit responsibilities is sufficiently detailed to allow the staff to understand the manner in which the organization will ensure that decommissioning will be conducted safely. The staff should verify that the individual project unit reporting hierarchy and lines of authority within the decommissioning project do not create conflicts that could compromise safety during decommissioning and that, as appropriate, individual units report directly to the unit responsible for overall decommissioning project s +

management. The staff should verify that the individual project units, and individuals within each unit, have the responsibility and authority to bring safety concerns to decommissioning project  ;

I ORAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14/99

4 management and that stop work authority is provided to the unit responsible for safety and health. The staff should make a qualitative assessment of the adequacy of the licensee's or responsible party's proposed decommissioning management organization to accomplish the remedation objectives in a manner that is protective of workers and the public and in compliance with NRC requirements.

Samole Evaluation Findinos The NRC staff has reviewed the description of the decommissioning project management organization, position descriptions, management and safety position qualifications requirements and the manner in which the licensee [ insert nama of licensee) will utilize contractors during the decommissioning of its facility located at [ insert location of facility] according to the NMSS Decommissioning Standard Review Plan, Section 9 (Decommissioning Project Management).

Based on this review, the NRC staff has determined that the licensee [ insert name] has provided sufficient information to allow the NRC staff to evaluate the licensee's decommissioning project management organization and structure to determine if the decommissioning can be conducted safely and in accordance with NRC requirements. (Note that this finding incorporates the results of the staff's assessment under Sections 9.2 - 9.5, below).

SUGGESTED FORMAT I

1. Length: not to exceed 6 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 1-2 pages describing the information under each bullet above and a diagram showing the decommissioning project management organization and reporting authority.

l Licensees are also encouraged to submit the information in electronic format. '

1 9.2 DECOMMISSIONING TASK MANAGEMENT The purpose of the review of the description management of decommissioning tasks is to verify that all decommissioning actmties will be conducted in accordance with written, approved procedures and that the licensee or responsible party has a methodology in place to manage the development, review, and maintain the procedures. '

ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2) l l

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14/99 l

i

5 Reaulatorv Guidance None information Reauirements The information supplied'by the licensee should be sufficient to enable the staff to fully understand the manner in which the licensee or responsible party will evaluate

. decommissioning tasks and develop and manage the procedures necessary for conducting the

tasks. The staff's review should verify that the following information is included in the description of decommissioning task management:

e a description of the manner in which the decommissioning tasks are managed, such as through the use of a Radiation Work Permits (RWPs)';

e a description of how individual decommissioning tasks are evaluated and how ine RWPs are developed for each task; ..

• a description of how the RWPs are reviewed and approved by the decommissioning j

~ project management organization; l

• a description of how RWPs are managed throughout the decommissioning project (i.e.,

how they are issued, maintained, revised, and terminated);

e a description of how individuals performing the decommissioning tasks are informed of the procedures in the RWP, including how they are initially informed and how they are informed of when an RWP is revised or terminated; j l

EVALUATION FINDINGS Evaluation Criteria r

The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of the manner in which decommissioning tasks will be managed. The steff should verify that the licensee or responsible party will control decommissioning tasks through the use of written procedures. These procedures should be developed by individuals / units familiar with the physical and safety requirements necessary to complete the tasks safely. The procedures should be reviewed and approved by units responsible for physical, radiological, chemical, and occupational safety, as well as decommissioning project management. Note that NRC staff is not responsible for ensuring that physical, chemical or occupational safety procedures are adequate. Rather, the intent is to ensure that the licensee has an integrated approach for reviewing and approving procedures

- that could impact on radiological safety. Procedures should also undergo separate review by a group charged with ensuring that activities are conducted safely and in a manner that ensures that exposures to radiation are ALARA. Staff should verify that the licensee has a methodology to issue,' modify (after appropriate review and approval) and terminate RWPs, as well as a program for ensuring that individuals performing the tasks are informed or trained in the

'The term "RWP' will be used throughout this section to refer to the written procedure used to manage individual decommissioning tasks.

1 DRAFT NhtSS Decommissioning SRP - For Review and Comment Only 6/14/99

i )

1 l

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. procedures. The staff should make a qualitative assessment of the adequacy of the licensee's or responsible party's proposed decommissioning task management procedures to accomplish the decommissioning in a manner that is protective of workers and the public and in compliance with NRC requirements.

)

Samole Evaluation Findinas

)

None. The staff should combine the assessment of this section of the decommissioning plan with Section 9.1 above.

3 SUGGESTED FORMAT

1. Length: not to exceed 5 pages '

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard .

Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 1 page summar! zing each of the items outlined in Acceptance Criteria, above. Licensees are also encouraged to submit the information in electronic format.

9.3 DECOMMISSIONING MANAGEMENT POSITIONS AND QUALIFICATIONS The purpose of the review of the licensee's decommissioning management positions and qualifications is to ensure that the licensee or responsible party has the personnel resources to safely conduct and manage the decommissioning of its facility.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.33(3),10 CFR 40.32(b),10 CFR 70.22(a)(6), arid 10 CFR 72.28(a-d) 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2)

Reaulatorv Guidance None Information Reauirements  !

The information supplied by the licensee should be sufficient to enable the staff to fully understand the responsibilities and minimum qualifications required for each of the management and safety related positions within the licensee's or responsible party's

{

decommissioning project organization. The staff's review should verify that the following i information is included in the description of decommissioning positions and qualifications:

{

i DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14199 >

l i

r 7

I 1 l

e a description of the duties and responsibilities of each management position in the decommissioning organization and the reporting responsibility of the position; j e a description of the duties and responsibilities of each chemical, radiological, physical l and occupational safety-related position in the decommissioning organization c.ad the reporting responsibility of the position; e a description of the duties and responsibilities of each engineering, quality assurance, and waste management position in the decommissioning organization and the reporting responsibility of the position j e the minimum qualifications for %ch of the positions describe above, and the qualifications of the individuals currently occupying the positions (the licensee should also commit to providing the staff with the qualifications of any newly hired or replacements for these positions); and, -

e a description of all decommissioning and safety committees including the membership of the committees, the duties and responsibilities of each committee and the authority of each committee.

EVALUATION FINDINGS l l

Evaluation Criteria The staff should verify that the information summarized under "Information Requirements", I above is included in the licensee's description of the previous decommissioning activities carried out under the license. The staff should make a qualitative assessment of the adequacy of the licensee's or responsible party's decommissioning positions and qualifications requirements to ensure that the decommissioning can be conducted in a manner that is protective of workers and the public and in compliance with NRC requirements.

Samole Evaluation Findinas None. The staff should combine their assessment of tais section of the decommissioning plan with Section 9.1 above.

SUGGESTED FORMAT

1. Length: not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard  ;

Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 1-2 paragraphs outlining the duties and responsibilities of each of the positions / committees above. Minimum qualifications should be summarized in tabular form and the licensee should submit the cirriculum vitae of the individuals currently occupying the positions. Licensees are also encouraged to submit the information in electronic format. i l

i DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14/99 l

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8

-9.3.1 Radiation Safety Officer The purpose of the review of the Radiation Safety Officer position is to ensure that a qualified individual is designated and empowered to over-see the licensee's or responsible party's radiation protection program. The RSO must be qualified by training and experience for the types and quantities of radionuclides that will be encountered during decommissioning operations as well as the operations that will be undertaken to decommission the facility. In addition, the RSO must be empowered by the licensee or responsible party and be responsible for the implementation of the radiation protection program.

~ ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 33.13,(c) (2) 10 CFR 33.14 (b)(1),10 CFR 34.42,10 CFR 35.900,10 CFR 36.13(d)

Reaulatory Guidance None

, formation Reauirements The information supplied by the licensee or responsible party should be sufficient to allow the staff to fully evaluate the qualifications, authority and responsibilities of the RSO. The staff's review should verify that the following information is included in the description of the RSO's ,

qualifications, duties and responsibilities: J

• a description of the health physics and radiation safety education and experience required for individuals acting as the licensee's or responsible party's RSO e a description of the responsibilities and duties of the RSO; and e a description of the specific authority of the RSO to implement and manage the licensee's or responsible party' radiation protection program, including the RSO's ,

access and "stop work" authority for all activities involving radioactive material at the )

site; EVALUATION FINDINGS .

Evaluation Criteria The staff shou!d verify that the information summarized under "Information Requirements" above,is inauded in thre licensee's or responsible party's description of the duties and responsibilities of the RSO. The staff should verify that the description of the RSO's duties and responsibilities are sufficien'.ly detailed to allow the staff to determine whether the RSO can abd will be able to oversee the site radiation protection program effectively. The staff should verify that the RSO has clearly defined authority and responsibility to oversee the radiation protection program, such that if conflicts arise regarding the appropriate manner in which to conduct the decommissioning the RSO can ensure that the decommissioning will be conducted safely.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14/99

9 The RSO should have at least a Bachelors degree in physical, chemical or radiological health sciences and 5 years experience in the types, and quantities of radioactive material at the site '

and similar experience involving the types of decommissioning operations proposed by the i licensee or responsible party. The description of the RSO's duties and responsibilities should t include the responsibility aqd authority to: review and approve all procedures involving the use ,

of radioactive material at tha facility; review and approve individuals as radiation workers at the i site; conduct audits and ir 13ctions to ensure that activities involving the use of radioactive material are being conducted safely; monitoring of materials use and storage areas at the site; oversee the inventory, ordering, receipt and shipment of all radioactive material, and radioactive waste, at the site; ensure that all personnel at the site are trained in site radiation safety '

procedures and practices; ensure that sealed sources are leak-tested per NRC requiremenrr respond to and investigate incidents and accidents involving radioactive material at th; aie; monitor and evaluate radiation worker exposures at the site; and, maintain all required records.

The RSO should have the authority and access to all areas involved in decommissioning or radioactive material usage at the site and the specific authority and responsibility to stop any operations that in the RSO's opinion are not being conducted safely.

Samole Evaluation Findinas None. The staff should combine their assessment of this section of the decommissioning plan with Section 9.1, above.

SUGGESTED FOliMAT

1. Length: 4-5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. See Section 9.3, above 9.4 TRAINING The purpose of the review of the licensee's training program is to provide the staff with sufficient information to determine if the licensee can provide its employees with the training necessary to complete the decommissioning safely and in accordance with NRC requirements.

Note that training related to the Health and Safety Program will be evaluated under Section 10.1.2 of this SRP.

ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 19,10 CFR 30.33(3),10 CFR 40.32(b),10 CFR 70.22(a)(6),10 CFR 72.28(a), (b) and (d) 10 CFR 30.36(g)(4)(ii), 40.42(g)(4)(ii), 70.38(g)(4)(ii) and 72.54(g)(2)

{

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14/99

m

]

i

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10 Eggylatorv Guidance None.

1 Information Reauirements The infor' mation supplied by the licensee or responsible party sh remediation and safety procedures employees that in the will b reviewforshould

. program the facility:verify that the following information is included in the acility. The staff's escription of the training a description of the radiation safety training that the licensee e employee comply with 10 CFR including Part 19; . pre-employment, annual o each

/ periodic tra e ra ning to

.the a description beginning of each of any dailyorworker workday job task to "jobsidei familiarizeorwork Mailgate e _ procedures or safety requirements; and ers with job-specific commitments are being met.a description of the documen raining EVALUATION RNDINGS Evaluation Criteria .

The staff should verify that the information summarized under " I a on Requirements",

' qualitative amaaaament of the .

s a sadequacy ould make a of programs to ensure that workers are adequately informed of the ar y s training

, reventative measures and procedures associated with performing ask.

each de Samole Evaluation nndisios with Section 9.1, above.None. The staff should combine their asse e ecommissioning plan SUGGESTED FORMAT -

-1.

Length: 5-7 pages 2.

~70" Format August 1989 and Content of Decommissioning e. " Standard n er 10 CFR 30,40, and Pla

3. 3-4 pages summ.

information under bullet 3. Licensees are also enco electronic format.

m t t e information in

~ D' RAFTNMSS Decommissioning SRPny- 6/14/99 For Review an

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11 9.5 CONTRACTOR SUPPORT The purpose of the review of the ficansee's description of interaction between the licensee or responsible party and contractors is to determine if the interactions will occur such that both licensee and contractor personnel are adequately protected and that the decommissioning can be conducted in accordance with NRC requirements.

ACCEPTANCE CRITERIA Reaulatorv Reavirements 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2)

Reculatorv Guidance None Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to determine whether the licensee's or responsible party's radiation protection procedures are adequate to ensure the safety of contractor and licensee or responsible party personnel. The staff's review should verify that the following information is included in the discussion of contractor support at the facility:

a summary of decommissioning tasks that will be performed by contractors including the areas at the site where they will perform these tasks; e

a description of the management interfaces that will be in place between the licensee or responsible party's managernent and on-site supervisors and contractor management and on-site supervisors; e

a description of the oversight responsibilities and authority that the licensee or responsible party will exercise over contractor personnel; e

a description of the training that will be provided to contractor personnel by the licensee or responsible party and the training that will be provided by the contractor; and, e

a commitment that the contractor will comply with all radiation safety and license reauirements at the facility.

EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of contractor support at the site. The staff should make a qualitative assessment of the adequacy of the licensee's or responsible party's planned management interface procedures with contractor management to ensure that both licensee and contractor personnel are adequately informed of the hazards, preventative measures and procedures associated with performing each decommissioning task. The staff will vcrify that DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/14/99 i

l

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12

. the licensee has the authority and responsibility to ensure that contractor personnel perform decommissioning activities in accordance with all license commitments and NRC requirements, The statt will verify that all contractor personnel will receive adequate training (per the training program in section 9.4 above) either as part of the licensee's or responsible party's training program or as part of the contractor's training program j Samole Evaluation Findinas None. The staff should combine their assessment of this section of the decommissioning plan with Section 9.1, above, 3 j

SUGGESTED FORMAT

1. Length: not to exceed 4 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 3-5 paragraphs summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public

)

to provide input to NRC staff in the early stages of the I development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

i DRAFT NAtSS Dec ommissioning SRP - For Review and Comment Only 6/14/99

r i

i NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 10.0 HEALTH AND SAFETY PROGRAMS NRC STAFF IS CURRENTLY COMPLETING DEVELOPMENT OF THIS MODULE.  !

WHEN COMPLETED, IT WILL BE POSTED ON THE WORLD WIDE WEB AT: i http://techconf.llnl. gov /cgi-bin / library? source =*& library =Lic_ Term _ lib & file =*

i i

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and

. approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

s NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 11.0 ENVIRONMENTAL MONITORING PROGRAM NRC STAFF IS CURRENTLY COMPLETING DEVELOPMENT OF THIS MODULE.

WHEN COMPLETED, IT WILL BE POSTED ON THE WORLD WIDE WEB AT:

http://techconf. lint. gov /cgi-bin / library? source =*& library =Lic_ Term _ lib & file =*

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

R l 1

l NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 12.0 RADIOACTIVE WASTE MANAGEMENT PROGRAM  ;

1 This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow  :

interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and ]

approval and does not represent any official NRC positic; s. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

l This Standard Review Plan (SRP) is being issued in draft l form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the f development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 12.0 RADIOACTIVE WASTE MANAGEMENT PROGRAM

{

l RESPONSIBILITY FOR REVIEW Primarv: NMSS: Division of Waste Management - Decommissioning Branch i

Division of Fuel Cycle Safety and Safeguards - Licensing Branch l Region I: Division of Nuclear Materials Safety - Decommissioning and Laboratory Branch Region 11: Division of Nuclear Materials Safety - Materials Licensing / Inspection Branch 1 Region Ill: Division of Nuclear Material Safety - Decommissioning Branch Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing Branch, Fuel Cycle and Decommissioning Branch Secondarv: None Supoort: None AREAS OF REVIEW The staff will review the information supplied by the licensee or responsible party to determine if the description of the program for the management of radioactive waste generated as part of the decommissioning of the facility is adequate to allow the staff to fully understand the types of radioactive waste that will be generated by decommissioning operations and the manner in DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99

i i

2 which the licensee will manage these wastes. This information will be used by the staff to ensure that the waste will be managed in accordance with NRC requirements, to support the staff's evaluation of the licensee's or responsible party's health and safety program, the evaluation of potential accidents and the licensee's or responsible party's cost estimates for decommissioning. This information should include descriptions of the types, volumes and activities of radioactive waste generated by the decommissioning operations, a description of how the wastes will be stored, treated (if on-site treatment is anticipated) and packaged for transport and disposal, and the name and location of the facility where the licensee or responsible party intends to treat and or dispose of the waste.

REVIEW PROCEDURES Acceptance Review The staff will review the decommissioning plan to ensure that, at a minimum, the decommissioning plan contains the information summarized under " Areas of Review," above.

Staff will review the radioactive waste management portion of the decommissioning plan without assessing the technical accuracy or completeness of the information contained therein.

The adequacy of the information will be assessed during the detailed technical review. Staff will review the decommissioning plan table of contents and the individual descriptions under " Areas of Review," above, to ensure that the licensee or responsible party has included this information in the decemissioning plan and to determine if the level of detail of the information appears to be adequde for the staff to perform a detailed technical review.

SMW Evaluation The material to be reviewed is informational in nature, and no specific detailed technical analysis is required. The staff will verify that the manner in which the licensee or responsible party intends to package the waste for transport and disposal is acceptable by comparing the descriptions of the waste and the packaging procedures to the relevant NRC regulations. The staff will verify that the waste disposallocations are appropriate for the wastes generated during decommissioning by comparing the waste generated by the decommissioning operations to publically available information on the types of wastes that are accepted by the disposal facility.

The staff will make a qualitative assessment as to whether the licensee's or responsible party's descriptione n! the types, volumes and activities of radioactive waste generated by the decommissioning operations appear accurate (given the information presented in facility radiological status section of the decommissioning plan) and if the descriptions of how the  !

wastes will be stored and treated are appropriate for the types and volumes of wastes as well as being protective of worker and public health and safety. f I

12.1 SOLID RADWASTE l

l The purpose of the review of the description of the management of solid radwaste generated l during decommissioning operations is to ensure that the manner in which the licensee or responsible party proposes to manage the waste will be protective of the public health and DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99 1

l l

a

3 safety and that the waste will be treated and disposed of in accordance with NRC requirements.

The information will also be used to support the staff's evaluation of potential accidents and the licensee's or responsible party's cost estimates for decommissioning.

ACCEPTANCE CRITERIA

- Reaulatory Reauirements 10 CFR Part 20, Subpart K,10 CFR 61.55,10 CFR 61.56,10 CFR 61.57,10 CFR 71.5 l

10 CFR 30,36(g)(4)(ii),40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2) l Reaulatorv Guidance None information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the types, volumes, and activities of sciid radwaste generated during decommissioning operations and the manner in which the licensee intends to manage and dispose of the wastes. The staff's review should verify that the following information is included in the solid radwaste section of the facility decommissioning plan:

e a summary of the types of solid radwaste that are expected to be generated during decommissioning operations, including (but not limited to) soil, structural and component ,

metal, concrete, activated components, contaminated piping, wood, and plastic; I e

a summary of the estimated volume, in cubic feet, of each solid radwaste type summarized under bullet 1 above; e

a summary of the radionuclides (including the estimated activity of each radionuclide) in each estimated solid radwaste type summarized under bullet 1 above; e a summary of the volumes of Class A, B, C and Greater-than-Class-C solid radwaste (

that will be generated by decommissioning operations;

. a description of how and where each of the solid radwates summarized under bullet 1 f

above, will be stored on-site prior to shipment for disposal; ,

e a description of how the each of the solid radwastes summarized under bullet 1 above, l will be treated and packaged to meet disposal site acceptance criteria prior to shipment for disposal; e if appropriate, how the licensee or responsible party intends to manage volumetrically contaminated material; e a description of how the licensee or responsible party will prevent contaminated soil, or' j other loose solid radwaste, from being re-disbursed after exhumation and collection; and I e the name and locat:1n of the disposal facility that the licensee intends to use for each solid radwaste type summt.rized under bullet 1 above )

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

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4

I l

l 4

EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of the solid radwaste management program. The staff should verify that the licensee's or responsible party's program for the management of solid radwaste complies with NRC requirements at 10 CFR Part 20, Subpart K,10 CFR 61.55, 10 CFR 61.56,10 CFR 61.57 and 10 CFR 71.5. The staff should make a qualitative assessment of the accuracy of the licensee's or responsible party's descriptions of the types, volumes, and activities of the solid radwaste by comparing it to the information presented in the facility description, planned decommissioning activities, and radiological status portions of the decommissioning plan. The staff should make a qualitative assessment of the licensee's or responsible party's proposed methods to store solid radwaste prior to disposal and the manner in which volumetrically contaminated waste will be managed. The staff will verify that the waste disposal locations are appropriate for the solid wastes generated during decommissioning by comparing the solid waste generated by the decommissioning operations to publically available information on the types of solid wastes that are accepted by the disposal facility.

Samole Evaluation Findinas The staff may combine the evaluation finding for the licensee's or responsible party's description of solid radwaste management programs with the findings for the remaining areas in this section of the SRP as follows:

The NRC staff has reviewed the licensees descriptions of the radioactive waste management q program for the [ insert name and (license number) of facility] located at [ insert location of  !

facility) according to the NMSS Decommissioning Standard Review Plan, Section 12(Radioactive Waste Management Programs). Based on this review, the NRC staff has determined that the licensee's [ insert name] programs for the management of radioactive waste generated during decommissioning operations ensure that the waste will be managed in i accordance with NRC requirements and in a manner that is protective of the public health and  !

safety.

SUGGESTED FORMAT i

1. Length: not to exceed 2 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard f Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. Bullets 1- 4 under Acceptance Criteria, above should be in tabular format.1-2

)

paragraphs describing the program under each of the remaining bullets. Licensees are  !

also encouraged to submit the information in electronic format. l I

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 i

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12.2 LIQUID RADWASTE

. The purpose of the review of the description of the management of liquid radwaste generated

. during decommissioning operations is to ensure that the manner in which the licensee or responsible party proposes to manage the waste will be protective of the public health and safety and that the waste will be treated and disposed of in accordance with NRC requirements.

The information will also be used to support the staff's evaluation of potential accidents and the

= licensee's or responsible party's cost estimates for decommissioning.

ACCEPTANCE CRITERIA Reaulatory Reauirements .

10 CFR Part 20, Subpart K,10 CFR 61.55,10 CFR 61.56,10 CFR 61.57,10 CFR 71.5 Reaulatorv Guidance

-None Information Reouirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the types, volumes, and activities of liquid radwaste generated during decommissioning operations and the manner in which the licensee intends to manage and dispose of the wastes. The staff's review should verify that the following information is included 1 in the liquid radwaste 'section of the facility decommissioning plan:

-e

. a summary of the types of liquid radwaste that are expected to be generated during decommissioning operations e a summary of the estimated volume, in liters, of each liquid radwaste type summarized under bullet 1 above; e

a summary of the radionuclides (including the estimated activity of each radionuclide)in each liquid radwaste type summarized under bullet 1 above;

• a summary of the estimated volumes of Class A, B, C and Greater-than-Class-C liquid radwaste that will be generated by decommissioning operations; e a description of how and where each of the liquid radwastes summarized under bullet 1 above, will be stored on-site prior to shipment for disposal; e a description of how the each of the liquid radwastes summarized under bullet 1 above, -

will be treated and packaged to meet disposal site acceptance criteria prior to shipment for disposal; e the name and location of the disposal facility that the licensee intends to use for each liquid radwaste type summarized under bullet 1 above "

l DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

6 EVALUATION FINDINGS Evaluation Critela The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of the liquid radwaste management program.

The staff should verify that the licensee's or responsible party's program for the management of liquid radwaste complies with NRC requirements at 10 CFR Part 20, Subpart K,10 CFR 61.55, 10 CFR 61.56,10 CFR 61.57 and 10 CFR 71.5. The staff should make a qualitative assessment of the accuracy of the licensee's or responsible party's descriptions of the types, volumes, and activities of liquid radwaste by comparing it to the information preserited in the facility description, planned decommissioning activities, and radiological status portions of the ,

decommissioning plan. The staff should make a qualitative assessment of the licensee's or I responsible party's proposed methods to store liquid radwaste prior to disposal. The staff will I verify that the waste disposal locations are appropriate for the liquid wastes generated during decommissioning by comparing the liquid waste generated by the decommissioning operations  ;

to publically available information on the types of liquid wastes that are accepted by the ]

disposal facility.

{

l Samole Evaluation Findinos 1 I

None. The staff should combine the evaluation finding for the licensee's or responsible party's J description of liquid radwaste management programs with the findings for the remaining areas )

in this section of the SRP (see Section 12.1, above) l SUGGESTED FORMAT

1. Length; not to exceed 2 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989,

3. Bullets 1- 4 under Acceptance Criteria, above should be in tabular format.1-2 paragraphs describing the program under each of the remaining bullets. Licensees are also encouraged to submit the information in electronic format.

l 12.3 MIXED WASTE ,

1 The purpose of the review of the description of the management of mixed waste generated l during decommissioning operations is to ensure that the manner in which the licensee or l responsible party proposes to manage the mixed waste will be protective of the public health j and safety and that the waste will be managed, treated and disposed of in accordance with  ;

NRC and Environmental Protection Agency (or EPA authorized State) requirements. The information will also be used to support the staff's evaluation of potential accidents and the licensee's or responsible party's cost estimates for decommissioning.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

7

' ACCEPTANCE CRITERIA

~ Reaulatorv Reauirements 10 CFR Part 20, Subpart'K,10 CFR 61.55,10 CFR 61.56,10 CFR 61.57,10 CFR 71.5,40 CFR 260-270 .

Regulatorv Guidance Low-level Mixed Waste, A RCRA Perspective for NRC Ucensees information Reauirements The information supplied by the licensee should be sufficient to enable the staff to fully understand the types, volumes, and activities of mixed waste generated during decommissioning operations and the manner in which the licensee intends to manage and dispose of the wastes. The staff's review should verify that the following information is included

' in the mixed waste section of the facility decommissioning plan:

'e' a summary of the types of solid and liquid mixed waste that are expec'ted to be j generated during decommissioning operations; e a summary of the estimated volumes, in cubic feet of each solid mixed waste type summarized undar bullet 1 above and in liters for each liquid mixed waste; e 'a summary of the radionuclides (including the estimated activity of each radionuclide) in each type of mixed waste type summarized under bullet 1 above; e a summary of the estimated volumes of Class A, B, C and Greater-than-Class-C mixed waste that will be generated by decommissioning operations; .

e a descnption of how and where each of the mixed wastes summarized under bullet 1 above, will be stored on-site prior to shipment for disposal;- __  !

e .a description of how the each of the mixed wastes summarized under bullet 1 above, )

will be treated and packaged to meet disposal site acceptance criteria prior to shipment

. for disposal; e the name and location of the disposal facility that the licensee intends to use for each mixed waste type summarized under bullet 1 above;  ;

e ' a discussion of the requirements of all other regulatory agencies having jurisdiction over the mixed waste; and, e a demonstration the that the ' licensee possess the appropriate EPA or State permits to generate, store and/or treat the mixed wastes; EVALUATION FINDINGS l

- Evaluation Crite'ria The staff should verify that the information summarized under"Information Requirements",

above is included in the licensee's description of the liquid radwaste management program.

. The' staff should verify that the licensee's or responsible party's program for the management of DRAFTNMSS Decommissioning SRP - For Review and Comment Only 617/99

8 mixed waste complies with NRC requirements at 10 CFR Part 20, Subpart K,10 CFR 61.55,10 CFR 61.56,10 CFR 61.57 and 10 CFR 71.5. The staff should make a qualitative assessment of the accuracy of the licensee's or responsible party's descriptions of the types, volumes, and activities of mixed waste by comparing it to the information presented in the facility description, planned decommissioning activities, and radiological status portions of the decommissioning plan. The staff should make a qualitative assessment of the licensee's or responsible party's proposed methods to store mixed waste prior to disposal. The staff will verify that the waste disposallocations are appropriate for the mixed wastes generated during decommissioning by comparing the mixed waste generated by the decommissioning operations to publically available information on the types of mixed wastes that are accepted by the disposal facility.

Note that the NRC staff is NOT responsible for ensuring that the licensee or responsible party's program complies with the requirements of 40 CFR 260-270 or the Department of Transoortation regulations pertaining to the transportation of the hazardous component of the mixed waste. The staff should make a qualitative assessment of the acceptability of the licensee's or responsible party's descriptions of the methods they will employ to comply with the requirements of other agencies with regulatory responsibility for the mixed waste.

Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of mixed waste management programs with the findings for the remaining areas in this section of the SRP (see Section 12.1, above)

SUGGESTED FORMAT

1. Length: not to exceed 2 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. Bullets 1- 4 under Acceptance Criteria, above should be in tabular format.1-2 paragraphs describing the program under each of the remaining bullets. Licensees are also encouraged to submit the information in electronic format.

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 I

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3 NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 13.0 QUALITY ASSURANCE PROGRAM I

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

l l

l 1

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISF:ONING PROGRAM STANDARD REVIEW PLAN 13.0 QUALITY ASSURANCE PROGRAM RESPONSIBILITY FOR REVIEW Primarv: NMSS: Division of Waste Management - Decommissioning Branch Division of Fuel Cycle Safety and Safeguards - Licensing Branch i

Region 1: Division of Nuclear Materials Safety - Decommissioning and {

Laboratory Branch l Region ll: Division of Nuclear Materials Safety - Materials Licensing / Inspection Branch 1 Region lil: Division of Nuclear Material Safety - Decommissioning Branch )

1 Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing  !

Branch, Fuel Cycle and Decommissioning Branch Secondary: None Support: None  !

J l

AREAS OF REVIEW 4 The staff will review tne information supplied by the licensee to determine if the description of the quality assurance (OA) program is adequate to allow the staff to conclude that the licensee l or responsible party has adequate controls in place to support the decommissioning. Further, if DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 l

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2 the licensee effectively implements the OA program described, the data collected should be  !

accurate and of sufficient quality to justify the conclusions drawn from the information. This information should include a description of the organization responsible for implementing the OA program; a description of the OA program, including descriptions of the manner in which QA activities are controlled; a description of the manner in which OA program documents are controlled; a description of how measuring and test equipment is controlled; a description of how conditions adverse to quality are corrected; a description of the OA records that will be maintained; and, a description of the audits and surveillances that are performed as part of the OA program.

REVIEW PROCEDURES Acceptance Review The staff will ensure that the decommissioning plan contains the information summarized under

" Areas of Review," above. Staff will review the quality assurance program without assessing the adequacy or completeness of the information contained therein. The adequacy of this information will be assessed during the staff's detailed review. Staff will review the decommissioning plan table of contents and the individual descriptions under " Areas of Review," above, to ensure that the licensee or responsible party has included this information in the decommissioning plan and to determine if the level of detail of the information appears to be adequate for the staff to perform a detailed review.

Safety Evaluation The material to be reviewed is informational in nature, and no specific detailed technical analysis is required. The staff will make a qualitative assessment as to whether the licensee's OA program is adequate to ensure that accurate, high-quality information is developed to support the decommissioning of the facility.

13.1 ORGANIZATION The purpose of the review of the OA organization is to verify that the licensee or responsible party has an adequate organization, management philosophy, and the resources necessary to ensure that the information submitted to support the decommissioning is accurate and of sufficient quality to justify the conclusions drawn from the information.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(ii), 40.42(g)(4)(ii), 40.28(b)(3), 70.22(f), 70.38(g)(4)(ii), 72.54(g)(6) )

I DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99 i

1 3

Reaulatory Guidance

-i None.

Information Reauirements

The staff will review the licensee's description of its organizational structure to ensure that persons and organizations performing quality affecting activities have sufficient authority and freedom to_ identify quality problems, provide solutions, and verify that solutions have been implemented. The staff's review should verify that the following information is included in the description of the'QA program organization:~

e' a description of the QA program management organization, I e a description of the duties responsibilities of each unit within the organization and how

- delegation of responsibilities is managed within the decommissioning program e a description of how work performance is evaluated; e a description of the authority of each unit within the QA program e -an organization chart of the QA program organization 1

EVALUATION FINDINGS Evaluation Critena The staff should verify that the information summarized under "Information Requirements" above is included in the licensee's or responsible party's description of the QA program. The

. staff should verify that the organization or individual responsible for submitting the license.

application exercises and retains the responsibility for the establishment and execution of the overall program. The staff should verify that major delegations of work are fully described and in each case organizational responsibilities and methods for control of the work by the applicant are described, including how responsibility for delegated work is to be retained and exercised.

. The staff should verify that licensee or responsible party and its prime contractors describe how

responsibility is exercised for the overall QA program and that the extent of management

responsibility and authonty from the applicant are addressed. The staff should verify that policies regarding the implementation of the QA program are documented and made mandatory.

The staff should verify that the licensee or responsible party and its contractors will evaluate l the performance of work delegated to other organizations, including audits and surveillances of

.the contractor's QA programs and audits and surveillances of subcontractors, consultants, and vendors fumishing~ equipment or services to the applicant or its contractors. The frequency and I method of this evaluation should be specified. - I

[The staff should verify that the licensee or responsible party and prime contractors identify a management position that retains overall authority and responsibility for the OA program (normally, this position is filled by the QA Manager).The staff should verify that the QA Manager position is at the same, or at a higher organization level than the position of the highest line

- DRAFT NntSS Decommissioning SRP - For Review and Comment Only 617/9 9 l

l i- 4 j

4 manager directly responsible for performing activities affecting quality (such as engineering, procurement, construction, and operation) and is sufficiently independent from cost and schedule restraints (this does not mean that the OA position must report outside of the project or program). The staff should verify that the authority and duties of persons and organizations performing functions related to meeting the performance objectives are clearly established and delineated in writing, including both the performing functions of attaining the requisite quality of work (quality achieving) and the assurance functions of verifying the attainment of quality (quality assuring). The staff should verify that designated QA personnel, sufficiently free from direct pressures resulting from cost and schedule, have the responsibility, delineated in writing, to stop unsatisfactory work and control further processing, delivery, or installation of nonconforming material.

The staff should verify that persons and organizations performing quality assuring functions have sufficient authority and organizational freedom to (1) identify quality problems, (2) initiate, recommend, or provide solutions through designated channels, and (3) verify implementation of solutions. The staff should verify that persons and organizations with the above authority are identified and a description of how those actions are carried cut is provided.

The staff should verify that provisions are established for the resolution of disputes involving quality arising from a difference of opinion between OA personnel and other department personnel. The staff should verify that the position description ensures that the individual directly responsible for the definition, direction, and effectiveness of the overall OA program has sufficient authority to effectively implement responsibilities. This position is to be sufficiently free from cost and schedule responsibilities.

The staff should verify that the person responsible for the onsite OA program is identified by position and has the appropriate organizational position, responsibilities, and authority to exercise proper control over the QA program.

The staff should verify that organization charts clearly identify all the on site and off site organizational elements that function under the cognizance of the OA program.

Sample Evaluation Findinas The NRC staff has reviewed the Quality Assurance Program for the (insert name and (license number) of facility) located at [ insert location of facility) according to the NMSS Decommissioning Standard Review Plan, Section 13 (OA Program). Based on this review the NRC staff has determined that the licensee's (insert name) OA program is sufficient to ensure that information submitted to support the decommissioning of its facility should be of sufficient quality to allow the staff to evaluate and determine whether the licensee's planned decommissioning activities to ensure that the decommissioning can be conducted in accordance with NRC requirements. (Note that this finding incorporates the results of the staff's assessment of the entire OA program as described in the following subsections of Section 13).

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

5 SUGGESTED FORMAT 1 1; Length; not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and

. 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

13.2 QUALITY ASSURANCE PROGRAM ACCEPTANCE CRITERIA I

The purpose of the review of the QA program is to verify that the licensee's or responsible party's OA program and activities affecting quality will be controlled by written policies, procedures and instruction, which if effectively implemented, should ensure that the information i submitted to support the decommissioning is accurate and of sufficient quality to justify the conclusions drawn from the information.

l Reaulatorv Reauirements 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),40.28(b)(3),70.22(f),70.38(g)(4)(ii),72.54(g)(6)

Reaulatorv Guidance '

None Information Reauirements The staff will review the licensee's or responsible party's OA program to determine if activities affecting quality will be conducted in accordance with written policies, procedureu and instructions and that activities affecting quality are accomplished by suitably trained and qualified individuals. The staff shall review the licensee's OA program to ensure that quality affecting activities are prescribed by documented procedures, drawings or instructions.

The staff will verify that the following information is included in the description of the OA program:

e a commitment that activities affecting the quality of site decommissioning will be subject i to the applicable controls of the OA program and activities covered by the OA program i are identified on program defining documents; l e a brief summary of the company's corporate OA policies; l

• a description of provisions to ensure that technical and quality assurance procedures required to implement the OA program are consistent with regulatory, licensing, and QA program requirements and are properly documented and controlled; e a description of the management reviews, including the documentation of concurrence

. in these quality-affecting procedures; 4

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99 l

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1 6

e a description of the quality-affecting procedural controls of the principal contractors, including documentation of the acceptance of the controls before the initiation of activities affected by the program; e a description of how NRC will be notified of changes (a) for review and acceptance in the accepted description of the QA program as presented or referenced in the DP before implementation and (b) in organizational elements within 30 days after the announcement of the changes (Note: Editorial changes or personnel reassignments of a nonsuostantive nature do not require NRC notification);

e a description is provided of how management (above or outside the QA organization)

- regularly assesses the scope, status, adequacy, and compliance of the QA program; e a description of the instruction provided to personnel responsible for performing activities affecting quality pertaining to the purpose, scope, and implementation of the quality-related manuals, instructions, and procedures; e a description of the training and qualifications of personnel verifying activities affecting quality in the principles, techniques, and requirements of the activity being performed; e for formal training and qualification programs, documentation includes the objectives and content of the program, attendees, and date of attendance; e a description of the self-assessment program to confirm that activities affecting quality comply with the QA program; e a commitment that persons performing self-assessment activities are not to have direct responsibilities in the area they are assessing; e a description of the organizational responsibilities for ensuring that activities affecting quality are (a) prescribed by documented instructions, procedures, and drawings; and, (b) accomplished through implementation of these documents; and, e a description of the procedures to ensure that instructions, procedures, and drawings include quantitative acceptance criteria (such as those pertaining to dimensions, tolerances, and operating limits) and qualitative acceptance criteria (such as workmanship samples) for determining that important activities have been satisfactorily performed.

EVALUATION FINDINGS Evaluation Criteria l

l The staff should verify that the information summarized under "Information Requirements" above, is included in the description of the QA program. ]

Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of the OA program with the finding for the remaining areas in this section of the SRP (see Section 13.1, above).

SUGGESTED FORMAT

1. Length: not to exceed 10 pages DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99 l

l i

7 l

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

1 13.3 DOCUMENT CONTROL' The purpose of the review of the licensee's or responsible party's description of how OA program documents are issued and amended is to ensure that adequate control is exercised l

over the development, issuance and revision of the documents.

ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),40.28(b)(3),70.22(f),70.38(g)(4)(ii),72.54(g)(6)

Reaula_lorv Guidance None l

Information Reauirements The information supplied by the licensee or responsible party should be sufficient to enable the j staff to understand how the licensee or responsible party will develop, issue and revise documents associated with the QA program. The staff's review should verify that the following information is included in the description of the OA document control program:

e a summary of the types of QA documents that are included in the program e a description of how the licensee or responsible party develops, issues, revises and retires OA documents EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements,"

above, is included in the licensee's or responsible party's description of the OA document control program. The staff should verify that the scope of the document control program is described, and the types of controlled documents are identified. As a minimum, controlled j

documents include (1) quality assurance and quality control manuals and quality-affecting 1 procedures, (2) technical reports. The staff should verify that procedures for the review, j approval, and issuance of documents and changes will be established and described to ensure l technical adequacy and inclusion of appropriate quality requirements before implementation.

The staff should verify that procedures will be established to ensure that changes to documents j 1

(

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 i

8 are reviewed and approved by the same organizations as those that performed the initial review and approval or by other qualified responsible organizations delegated by the applicant. The staff should verify that procedures will be established to ensure that documents are available at the location where the activity will be performed prior to commencing work. The staff should verify that procedures will be established to ensure that obsolete or superseded documents are removed and replaced by applicable revisions in work areas in a timely manner.

Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible par:y's description of the QA program with the finding for the remaining areas in this section of the SRP (see Section 13.1, above).

SUGGESTED FORMAT

1. Length: not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and .

70* August 1989. Licensees are also encouraged to submit the information in electronic  !

format.

13.4 CONTROL OF MEASURING AND TEST EQUlPMENT j l

The purpose of the review of the description of the test and measurement equipment calibration program is to verify that the licensee or responsible has a program to ensure that equipment used to support decommissioning activities are properly controlled, calibrated and maintained.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),40.28(b)(3),70.22(f),70.38(g)(4)(ii),72.54(g)(6)

Reaulatory Guidance None Information Reouirements The information supplied by the licensee or responsible party should be sufficient to enable the staff to fully understand the methods and procedures that the licensee or responsible party will use to ensure that only accurate, calibrated, test and measurement equipment will be used during the decommissioning project. The staff's review snould verify that the following information is included in the description of the test and measurernent equipment QA program.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

9 e

a summary of the test and measurement equipment used in the program e

description of how and at what frequency the equipment will be calibrated; e

a description of the daily calibration checks that will be performed on each piece of test or measurement equipment; e

a description of the documentation that will be maintained to demonstrate that only properly calibrated and maintained equipment was used during the decommissioning i

EVALUATION FINDINGS '

Evaluation Criteria l The staff should verify that the information summarized under "Information Requirements," I above, is included in the licensee's or responsible party's description of the test and measurement equipment program. The staff should verify that the scope of the program for the l control of measuring and test equipment is described and the types of equipment to be controlled are established. The staff should verify that QA and other organizations' )

responsibilities are described for establishing, implementing, and ensuring effectiveness of the calibration and adjustment program. The staff should verify that procedures will be established forcalibration (technique and frequency), maintenance, and control of the measuring and test equipment. The review of and documented concurrence in these procedures is described, and the organization responsible for these functions is identified. The staff should verify that measuring and test equipment is identified and traceable to the calibration test data. The staff should verify that measuring and test equipment will be labeled or tagged or "otherwise controlled" to indicate due date of the next calibration. The method to "otherwise control" equipment should be described. The staff should verify that measuring and test equipment will be calibrated at specified intervals on the basis of the required accuracy, purpose, degree of usage, stability characteristics, and other conditions affecting the measurement.

Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of the QA program with the finding for the remaining areas in this section of the SRP (see Section 13.1, above).

SUGGESTED FORMAT

1. Length: not to exceed 3 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

13.5 CORRECTIVE ACTION

' ORAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99

10 The staff will review the licensee's OA program to ensure that measures have been established to assure that conditions adverse to quality are promptly identified and corrected.

ACCEPTANCE CRITERIA Reaulatorv Reauirements 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),40.28(b)(3),70.22(f),70.38(g)(4)(ii),72.54(g)(6)

Reaulatorv Guidance None information Reauirements The information supplied by the licensee or responsible party should be sufficient to enable the staff to determine whether adequate procedures and controls are in place to identify and correct conditions that will aversely affect quality. The staff's review should verify that the following information is included in the description of the corrective action program portion of the OA

, program:

• a description of the corrective action procedures for the facility, including a description of how the corrective action is determined to be adequate; e a description of the documentation maintained for each corrective action and any followup activities by the QA organization after the corrective action is implemented; EVALUATION FINDINGS v

Evaluation Criteria The staff should verify that the information summarized under "Information Requirements,"

above, is included in the licensee's or responsible party's description of the corrective action.

The staff should verify that procedures will be established for a corrective action program and that the QA organization reviews and documents concurrence in the procedures. The staff should verify that corrective action will be documented and initiated following the determination of a condition adverse to quality (such as nonconformance, failure, malfunction, deficiency, deviation, and defective material and equipment) to preclude recurrence. The staff should verify that the QA organization will be included in the concurrence chain regarding the adequacy of the corrective action. The staff should verify that followup action will be taken by the QA organization to verify the proper implementation of corrective action and to close out the corrective action in a timely manner. The staff should verify that significant conditions adverse to quality, the cause of the conditions, and the corrective action taken to preclude repetition will be documented and reported to immediate management and upper levels of management for ruview and assessment.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/9 9

i l

11-

~ Samole Eva;umion Rndinc

' None. The staff should combine the evaluation finding for the licensee's or responsible party's description of the OA program with the finding for the remaining areas in this section of the SRP (see Section 13.1, above).

SUGGESTED FORMAT

. 1. Length: not to exceed 5 pages .

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

13.6 QUALITY ASSURANCE RECORDS The purpose of the review of the QA records program is to verify that the licensee or responsible party lw procedures and facilities in place to adequately maintain and store the OA program records.

ACCEPTANCE CRITERIA Reaulatorv Reauirements

.10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),40.28(b)(3),70.22(f),70.38(g)(4)(ii),72.54(g)(6)

Reaulatory Guidance None Information Reouirements The information supplied by the licensee or responsible party should be su+ficie.~ tc enable the staff to fully understand the types of procedures that will be in place to manage i A OA program records. The staff should verify that the following information is included in the desuiption of  !

the OA records program: i

• a description of the manner in which the OA records will be managed

• a description of the responsibilities of the OA organization as well as all other units involved in the decommissioning to implement and maintain OA records; and, e a description of the OA records storage facility.  !

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

u 12 EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements," .

above, is included in the licensee's or responsible party's description of the quality assurance  !

records program. The staff should verify that the OA records program is described, and -

includes results of reviews, inspections, tests, audits, and material analyses; monitoring records of work performance; records on tho qualification of personnel, procedures, and equipment.

The staff should verify that OA and other organizations are identified and their responsibilities are described for the definition and implementation of activities related to QA records. The staff should verify that suitable facilities for the storage of records are described arid satisfy the i requirements of ANSI /ASME NOA-1. Alternatives to the fire protection rating provisions are i acceptable if records storage facilities conform to National Fire Protection Association Standard NFPA 232, Class 1, for permanent records and if the 2-hour fire-rating requirement contained in proposed ANSI N45.2.9 is met by the applicant in any one of the following three ways: (1) a 2-hour-rated vault meeting NFPA 232, (2) 2-hour-rated file containers meeting NFPA 232 (Class B), or (3) a 2-hour-rated fire resistant file room meeting NFPA 232.

Sample Evaluation Findinas None. The staff should combine the evaluation finding for the iicensee's or responsible party's description of the OA program with the finding for the remaining areas in this section of the SRP (see Section 13.1, above).

SUGGESTED FORMAT

1. Length: not to exceed 5 pages j

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard i Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

13.7 AUDITS AND SURVElLLANCES The purpose of the staff's review of the licensee's or responsible party's description of audits and surveillances is to ensure that the licensee has a comprehensive system of audits planteed to verify compliance with all aspects of the OA program, and to determine the effectiveness of the OA program.

ACCEPTANCE CRITERIA Reaulatorv Reauirements DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

13 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),40.28(b)(3),70.22(f),70.38(g)(4)(ii),72.54(g)(6)

Reculatory Guidance None-Information Criterig The information supplied by the licensee's or responsible party's should be sufficient to allow the staff to determine if the of audit and surveillance program is adequate to ensure that a - )

comprehensive system of audits planned to verify compliance with all aspects of the QA program is in place to determine the effectiveness of the QA program. The following information should be included in the description of the audit program:

e a description of the audit program,-including the procedures for conducting the audits or surveillances

-e a description of the records and documentation generated during the audits and the

- manner in which the documents are managed e a description of all followup activities associated with audits or surveillances e a description of the trending / tracking that will be performed on the results of audits and surveillances EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements,"

above,'is inciuded in the licensee's or responsible party's description of the audits program for the facility. The staff should verify that audits and surveillances will be performed in accordance f

with pre-established written procedures or checklists and conducted by trained personnel not i having direct responsibilities for the achievement of quality in the areas being audited. The staff should verify that audit and surveillance results will be documented and then reviewed with management having responsibility in the area audited. The staff should verify that provisions exist such that appropriate follow-up corrective action to audit and surveillance reports will be undertaken by responsible management. Auditing organizations schedule and conduct appropriate follow-up to assure that the corrective action is effectively accomplished. The staff should verify that both technical and QA programmatic audits and surveillances will be performed to provide a comprehensive independent verification and evaluation of procedures and activities affecting quality. The staff should verify that audits and surveillances objectively maaama the effectiveness and proper implementation of the OA program and address the technical adequacy of the activities being conducted. The staff should verify that provisions will be provided such that audits and surveillances are required to be performed in all areas where the requirements of the QA program are applicable. The staff should verify that audit and surveillance deficiency data are analyzed and trended. The staff should verify that reports which indicate quality trends and the effectiveness of the OA programs will be given to management for review, assessment, corrective action and follow up.

ORAFT NMSS Decommissioning SRP - For Review and Comment Only 617/9 9 i

14 Samole Evaluation Findinas None. The staff should combine the evaluation finding for the licensee's or responsible party's description of the QA program with the finding for the remaining areas in this section of the SRP (see Section 13.1, above).

SUGGESTED FORMAT

1. Length: not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also encouraged to submit the information in electronic format.

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 14.0 FACILITY RADIATION STATUS SURVEYS NRC STAFF IS CURRENTLY COMPLETING DEVELOPMENT OF THIS MODULE.

WHEN COMPLETED, IT WILL BE POSTED ON THE WORLD WlDE WEB AT:

http:#techconf.llnl. gov /cgi-bin / library? source =*& library =Lic_ Term _ lib & file =*

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

l

. _ _1

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 15.0 FINANCIAL ASSURANCE NRC STAFF iS CURRENTLY COMPLETING DEVELOPMENT OF THIS MODULE.

WHEN COMPLETED, IT WILL BE POSTED ON THE WORLD WIDE WEB AT:

http://techconf.lini. gov /cgi-bin / library? source =*& library =Lic_ Term _ lib & file =*

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow

' interested members of the public to provide input to NRC staff in the early stages of the

' development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM STANDARD REVIEW PLAN 16.0 RESTRICTED USE/ ALTERNATE CRITERIA I

l l

l 4

This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

1 This Standard Review Plan (SRP) is,being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

NMSS DECOMMISSIONING PROGRAM i

STANDARD REVIEW PLAN 16.0 RESTRICTED USE/ ALTERNATE CRITERIA RESPONSIBILITY FOR REVIEW Primary: NMSS: Division oi Waste Management - Decommissioning Branch Division of Fuel Cycle Safety and Safeguards - Licensing Branch Region 1: Division of Nuclear Materials Safety - Decommissioning and Laboratory Branch Region 11: Division of Nuclear Materials Safety - Materials Licereing/ inspection Branch 1 Region lil: Division of Nuclear Material Safety - Decommissioning Branch Region IV: Division of Nuclear Material Safety - Nuclear Materials Licensing Branch, Fuel Cycle and Decommissioning Branch Secondary: None Support: Office of General Counsel AREAS OF REVIEW The staff will review the information supplied by the licensee or responsible party to determine if the description of the activities undertaken by the licensee or responsible party is adequate to allow the staff to conclude that the licensee or responsible party has complied with the DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/9 9

1 2

- applicable requirements of 10 CFR 20.1403 or 20.1404 for those licensees that intend to request termination of its radioactive materials license using either the restricted use or attemate criteria provisions of Subpart E.

If the licensee or responsible party is requesting license termination under restricted use this information should include: a demonstration that the licensee or responsible party qualifies for

) 1 license. termination under.10 CFR 20.1403(a); a description of the institutional controls the licensee or responsible party has instituted at the site; the financial assurance the licensee or i responsible party has provided for the site; a description of the activities undertaken by the licensee or responsible party to obtain advice from the public on the proposed institutional controls and the results of these activities; and, a demonstration that the potential doses from residual radioactive material at the site will not exceed the limits in 10 CFR 20.1403 or 20.1404 and are ALARA.

If the licensee or responsible party is requesting license termination using the attemate criteria provisions of 10 CFR 1404, the information should include a demonstration that doses from

- residual radioactive material at the site will not exceed the limits in 10 CFR 20.1404(a)(1); a description of the restrictions on site use the licensee or responsible party has provided to comply with 10 CFR 20.1404(a)(2); a demonstration that the potential doses are ALARA; and a description of the activities undertaken by licensee or responsible party to obtain advice from the public and the results of these activities'.

REVIEW PROCEDURES Acceptance Review The staff will ensure that the decommissioning plan contains the information summarized under

" Areas of Review," abov.e. Staff will review the licensee's or responsible puty's descriptions of  ;

the 10 CFR 20.1403 or 20.1404 compliance activities without assessing the technical accuracy )

or completeness of the information contained therein. The adequacy of this information will be  !

assessed during the detailed review. Staff will review the decommissioning plan table of contents and the indmdual descriptions under " Areas of Review," above, to ensure that the licensee or responsible party has included this information in the decommissioning plan and to determine if the level of detail of the information appears to be adequate for the staff to perform a detailed technical review.-

Safety Evaluation The material to be reviewed is both informational and technical in nature. The staff will make a quahtative assessment as to whether the licensee's or responsible party's eligibility

'10 CFR 20.1403 requires that licensees or responsible parties obtain advice from instrtutions and individuals that may be affected by the decommissioning on specific issues related to institutional controls and financial assurance. However,10 CFR 20.1404 provides for a much broader discussion of the issues associeted 1 with the use of altomate criteria and, as such, licensees must obtain advice on essentially any issue associated with i the use of attemate criteria. 1 DRAFTNMSS Decommissioning SRP - For Review and Comment Only 617/9 9

= .

3 demonstration, description of institutional controls, description of financial assurance, and description of activities undertaken to obtain advice from the public on the proposed institutional contro!s and the results of these activities are adequate to allow the staff to conclude that the licensee or responsible party has complied with the requirements of 10 CFR 20.1403 or 20.1404. The staff will make a quantitative evaluation of the licensee's or responsible party's dose calculations and ALARA demonstrations.

16.1 RESTRICTED USE 16.1.1 ELIGlBILITY DEMONSTRATION ACCEPTANCE CRITERIA j The purpose of the review of the licensee's or responsible party's demonstration that it is eligible to request release of the site under the provisions of 10 CFR 20.1403 is to verify that the licensee or responsible party has demonstrated that further reductions in residual radioactivity at the site to meet the unrestricted release criteria in 10 CFR 20.1402 would: (1) )

result in net public harm; or (2) are not being undertaken because the residual radioactivity levels are ALARA.

I Reaulatorv Reauirements j 10 CFR 20.1403(a) 10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2)

Reaulatory Guidance DG-4006 " Demonstrating Corhpliance with the Radiological Criteria for License Termination",

Section 3.1 and 3.2 Information Recuirements i The information supplied by the licensee or responsible party should be sufficient to enable the staff to fully understand how the licensee has concluded that reducing radioactivity to the unrestricted use levels in 10 CFR 20.1042 would result in net public harm or are not being undertaken because the residual radioactivity levels are ALARA .The staff's review should verify that the following information is included in the licensee's or responsible party's demonstration that it is eligible for requesting license termination under the provisions of 10 CFR 20.1403:

• a demonstration that the benefits of dose reduction are less than the cost of doses, injuries and fatalities; or e a demonstration that the proposed residual radioactivity levels at the site are ALARA DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/9 9

'rz.,,_m g ...h,_ms._.. _m.,,,,,

4

~ EVALUATION FINDINGS Evaluation Criteria If the licensee or responsible party has concluded that further reductions in residual radioactivity levels would result in net public or environmental harm, the staff should verify that the licensee has accurately calculated the benefits vs costs of further remediation using Equation 25 in Section 3.1 of DG-4006. If the licensee or responsible party has concluded that further reductions in residual radioactivity levels are not required because they are ALARA the staff

. should verify that the licensee or responsible party has accurately calculated the benefits of further remediation vs costs using the methodology described in Section 3.1 of DG-4006.

Samole Evaluation Findinas The NRC staff has reviewed the licensee's justification for requesting license termination under restricted conditions in the Decommissioning Plan for the [ insert name and (license number) of facility] located at [ insert location of facility] according to the NMSS Decommissioning Standard

)

Review Plan, Section 16 (Restricted Use/Altemate Criteria).

Based on this review, the NRC staff has determined that the licensee [ insert name] has adequately demonstrated that [ insert onej ithe benefits of dose reduction are less than the cost of doses, injuries and fatalities) or [further reductions in radioactnnty levels at the site are unnecessary because they are ALARA).

SUGGESTED FORMAT-

1. Length: not to exceed 2 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989. Licensees are also' encouraged to submit the information in electronic format.

16.1.2 INSTITUTIONAL CONTROLS

- ACCEPTANCE CRITERIA The purpose of the review of'the description of the institutional controls the licensee or responsible party has provided for the site is to determine if the licensee or responsible party has made provision for legally enforceable institutional controls that will limit the dose to the average member of the critical group to less than 25 mrem /yr.

1 Reaulatorv Reauirements 1

10 CFR 20.1'403(b)

DRAFTNMSS Decommissioning SRP - For Review and Comment Only 617/99 o

t 5

10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2) '

Reaulatory Guidance DG-4006 " Demonstrating Compliance with the Radiological Criteria for License Termination",

Section 4.1 Information Reauirements j

l The information supplied by the licensee should be sufficient to enable the staff to fully j understand what institutional controls the licensee has provided for the site and the manner in which these institutional controls will limit doses to the average member of the entical group to 25 mrem /yr. The staff's review should verify that the following information is included in the description of institutional controls that the licensee has provided for the site:

'e a description of the legally enforceable institutional control (s) and an explanation of how the institutional control is a legally enforceable mechanism; e

. a description of the restrictions on present and future landowners; e )

a description of the parties enforcing and their authority to enforce the institutional control (s);

e a discussion of the durability' of the institutional control (s);

e a description of the activities that the party with the authority to enforce the institutional e controls will undertake to enforce the institutional control (s) q the manner in which the party with the authority to enforce the institutional control (s) will be replaced if that party is no longer willing or able to enforce the institutional control (s)

.e a description of the duration of the institutional control (s), the conditions that will end the

{

institutional control (s) and the activities that will be undertaken to end the institutional - l control (s) e a description of the corrective actions that will be undertaken in the event the institutional control (s) fail; and, l e j a description of the records pertaining to the institutional controls, how they will be 1 maintained and the duration of the post-license termination maintenance period.

f EVALUATION FINDINGS 1 j

l Evaluation Criteria The ' staff should verify that the information summarized under "Information Requirements,"

above, for legally enforceable institutional controls on privately owned land should satisfy the guidance summarized in Section 4.1.1 of DG-4006. For legally enforceable institutional 2

The Commission has stated (see Section B3.3 of the Statements of Consideration for 10 CFR Part 20,Subpart E

• Radiological Criteria for License Termination *) that stringent institutional controls would be needed for sites involving large quantities of uranium and thorium contamination. Typically these would involve legally enforceable deed restrictions backed up by State and local govemment control or ownership, engineered barriers, and as appropriate, Federal ownership ORAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 l

n 6

controls on government owned land, the information should satisfy the guidance in Section 4.1.2 of DG-4006.

Samole Evaluation Findinas

?The NRC staff has reviewed the ' description of the institutional controls in the Decommissioning Plan for the [ insert name and (license number) of facility] located at [ insert location of facility) according to the NMSS Decommissioning Standard Review Plan, Sectum 16 (Restricted Use/Altemate Criteria). Based on this review, the NRC staff has determined that the licensee

[ insert name) has adequately demonstrated that institutional controls are enforceable, durable

'and should ensure that doses to the public comply with the criteria in 10 CFR 20.1403. In -

addition, the licensee or responsible party has made adequate provisions to replace the party ,

charged with enforcing the institutional control in the event that the party is no longer willing or  !

able to enforce the institutional control and has made provisions to address corrective actions at the site.

~

SUGGESTED FORMAT .

1. - Length: not to exceed 10 pages . l

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard .

- Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and

' 70" August 1989. .

j

3. ' 1 pages summarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

)

16.1.3 SITE MAINTENANCE & FINANCIAL ASSURANCE The purpose of the review of the information about the license's site maintenance and financial assurance mecharusm is to ensure that adequate arrangements have been made to ensure that the site will be maintained in accordicce with the institutional controls described above and that sufficient funds are available to allow an independent third party to assume and carry out responsibilities for any necessary control and maintenance of the site after the NRC has terminated the license.

Reaulatory Reauirements 10 CFR 20.1403(c)

, 10 CFR 30.36(g)(4)(ii), 40.42(g)(4)(ii), 70.38(g)(4)(ii) and 72.54(g)(2) I

' R9aulatorv Guidance j

. DG-4006 " Demonstrating Compliance with the Radiological Criteria for License Termination", l

. Section 4.2

. DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

7.'

7 Information Reauirements

The information supplied by the licensee should be sufficient to enable the staff to fully understand what arrangements for. site maintenance and financial assurance mechanism (s) have been provided by the licensee or responsible party. This should include descriptions of how the site maintenance arrangements will ensure that the site will be managed per the institutional controls described above and how the financial assurance mechanism and amount of financial assurance is adequate to allow an independent third party to assume and carry out responsibilities for any necessary control and maintenance of the site after the NRC has terminated the license. The staff's review should verify that the following information is included in'the discussion of financial assurance mechanism in the facility decommissioning plan:

e a description of the arrangement or contract with the party charged with carrying out the actions necessary to maintain control at the site;

-e a demonstration that the contract or arrangement will remain in effect for as long as feasible, and include provisions for renewing or replacing the contract; e- a description of the manner in which independent oversight of the party charged with maintaining the site will be conducted and what entity will conduct the oversight; e' a description of the authority granted to the third party to perform, or have performed, any necessary maintenance activities; '

e . ur'less the party is a govemment entity, a demonstration that the third party is not the party holding the financial assurance mechanism; e a demonstration that all records pertaining to official actions and financial payments l made by the third party are open to public inspection; e a description of the periodic site inspections that will be performed by the third party; e a copy of the financial assurance mechanism provided by the licensee or responsible party'; and, e a demonstration that the amount of financial assurance provided is sufficient to allow an independent third party to carry out any necessary control and maintenance activities 2, EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of site maintenance activities and financial assurance mechanisms. The staff should verify that information pertaining to activities associated with maintenance and control the site is consistent with Section 4.2.1 of DG-4006.

- The staff should verify that information pertaining to the financial assurance mechanism and amount of financial assurance is consistent with the guidance in Section 4.2.2 of DG-4006.

8 Note that the technical review of the acceptability of financial assurance mechanisms is addressed in Section 15 of this SRP. Reviews conducted pursuant to this Section of the SRP are focused on assunng that the licensee or responsible party has provided a financial assurance mechanism that is consistent with the NRC's requirements at 10 CFR 1403(c) and that the amount of financial assurance is appropriate.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 617/99 1

y 8

Samole Evaluation Findinas The NRC staff has reviewed the information regarding site maintenance and financial assurance in the Decommissioning Plan for the [ insert name and (license number) of facility]

located at [ insert location of facility] according to the NMSS Decommissioning Standard Review Plan, Section 16 (Restricted Use/ Alternate Criteria). Based on this review, the NRC staff has determined that the licensee [ insert name] has adequately demonstrated that the site maintenance arrangements and financial assurance mechanism is adequate to ensure that the site will be maintained in accordance with the institutional controls described in the

- decommissioning plan and that sufficient funds are available to allow an independent third party to assume and carry out responsibilities for any necessary control and maintenance of the site after the NRC has terminated the license.

SUGGESTED FORMAT

1. . Length: not to exceed 5 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 1-2 paragraphs summarizing the information in each of the bullets in Acceptance Criteria, above. Licensees are also encouraged to submit the information in electronic format.

16.1.4 OBTAINING PUBLIC ADVICE The purpose of the review of the license's description of activities undertaken to obtain advice from the public on institutional controls is to determine if the advice of individuals and institutions in the community who may be affected by the decommissioning has been sought, evaluated, and as appropriate, incorporated into the licensee's or responsible party's decisions following an analysis of the advice.

ACCEPTANCE CRITERIA Reaulatory Reauirements 10 CFR 20.1403(d) '

10 CFR 30.36(g)(4)(ii),40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2)

Reaulatory Guidance DG-4006 " Demonstrating Compliance with the Radiological Criteria for License Termination",

Section 4.3 DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 I

l

9 information Requirements The information supplied by the licensee should be sufficient to enable the staff to determine whether the licensee or responsible party has adequately sought, managed, and, as appropriate, incorporated, advice from individuals and institutions that may be affected by the decommissioning alternative proposed by the licensee or responsible party.

10 CFR 1403(d)(1) requires that licensees proposing to decommission a site by restricting use of the site shall seek advice from affecte d parties on whether:

- (1) the provisions for institutional controls will provide reasonable assurance that the total effective dose equivalent distinguishable from background radiation will not exceed 25 mrem /yr; (2) the provisions for institutional controls will be enforceable; (3) the provisions for institutional controls will not impose an undue burden on the community or other affected parties; and, (4) sufficient financial assurance has been provided to enable an independent third party to carry out any necessary control and maintenance activities at the site after license termination.

The staff's review should verify that the following information is included in the discussion of how advice was sought, obtained, evaluated, and as appropriate, incorporated for each' of the issues identified above:

e a desenption of how individuals and institutions that may be affected by the decommissioning were identified and informed of the opportunity to provide advice to the licensee or responsible party; e a description of the manner in which the licensee obtained advice from these individuals or institutions; e a description of how the licensee provided for participation by a broad cross-section of community interests in obtaining the advice; e a description of how the licensee provided for a comprehensive, collective discussion on the issues by the participants represented; e

a copy of the publicly available summary of the results of discussions, including individual viewpoints of the participants on the issues and the extent of agreement and disagreement among the participants; e a description of how this summary has been made available to the public; e a description of how the licensee evaluated the advice, and the rationale for incorporating, or not incorporating, the advice from affected members of the community into the decommissioning plan.

' Note that each of the issues do not need to be addressed separately as long as the information required under the bullets is included for each issue DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

10 j_ EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under "Information Requirements",

above is included in the licensee's description of how advice was solicited, obtained, evaluated and as appropriate, incorporated into licensee's or responsible party's decisions and decommissioning plan. The staff should verify that the manner in which advice was sought and obtained and the activities associated with obtaining this advice is consistent with Section 4.3 of DG-4006.

Samole Evaluation Findinas The NRC staff has reviewed the information regarding how advice from individuals and institutions that may be affected by the decommissioning was obtained and summarized in the

' Decommissioning Plan for the [ insert name and (license number) of facility) located at [ insert location of facility) according to the NMSS Decommissioning Standard Review Plan, Section 16 (Restricted Use/ Alternate Criteria). Based on this review, the NRC staff has determiried that the licensee [ insert name) has demonstrated that advice from individuals and institutions that may be affected by the decommissioning was sought, obtained, evaluated, and, as appropriate, incorporated into the licensee's plans for decommissioning its facility in accordance with NRC requirements at 10 CFR 1403(d).

SUGGESTED FORMAT

1. Length: not to exceed 10 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70" August 1989.

3. 4-6 paragraphs sumrnarizing each of the items outlined in Acceptance Criteria, above.

Licensees are also encouraged to submit the information in electronic format.

16.1.5 DOSE MODELING AND ALARA DEMONSTRATION LACCEPTANCE CRITERIA

~

The purpose of the review of the license's estimates of doses from the site after termination of the license to verify that the TEDE to the average member of the critical group will not exceed 25 mrom/yr with the institutional controls in place and that the doses are as low as reasonably achievable. The staff's review will also verify that, if institutional controls are no longer in place, l there is reasonable assurance that the TEDE to the average member of the critical group from l residual radioactive material at the site will not exceed 100 mrem /yr, or 500 mrem /yr provided j that the licensee or responsible party. i i

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

11 i

- demonstrates that further reductions in residual radioactivity necessary to comply with the 100 mrem /yr requirement are not technically achievable, would be prohibitively expensive or would result in net public or environmental harm;

~ makes provisions for durable institutional controls (see footnote 2); and, provides sufficient financial assurance to enable an independent third party to carry out rechecks at the site no less frequently than every 5 years and to assume and carry out responsibilities for any necessary control and maintenance of the controls at the site.

Reaulatorv Reauirements

.10 CFR 20.1403(e) 10 CFR 30.36(g)(4)(ii),' 40.42(g)(4)(ii),70.38(g)(4)(ii) and 72.54(g)(2)

Reaulatory Guidance Dose Modeling:

DG-4006 " Demonstrating Compliance with the Radiological Criteria for License Termination",

Section 1 Section 5 of this SRP i

ALARA: i DG-4006 " Demonstrating Compliance with the Radiological Criteria for License Termination", I Section 3 l Section 7 of this SRP Information Reauirements The information supplied by the licensee should be sufficient to enable the staff to determine whether the residual radioactive material at the site will not result in a TEDE that exceeds 25

- mrem /yr_with institutional controls in place and is ALARA, or that if institutional controls are no longer in place that there is reasonable assurance that the TEDE to the average member of the critical group will not exceed either 100 mrem /yr or 500 mrem /yr, with conditions. The information should also demonstrate that the financial assurance mechanism (s) are adequate for the site. Finally the information should be adequate to allow the staff to determine if the institutional controls and site maintenance activities are adequate.

The staff's review should verify that the following information is included in the dose modeling/ALARA demonstration subsection of the restricted use section of the decommissioning plan:

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 l

12 e a summary of th', dose to the average member of the critical group when radionuclide levels are at *.: e DCGL with institutional controls in place, as well as the estimated doses if they are '.io longer in place; e a summefy of the evaluation performed pursuant to Section 7 of this SRP demonstrating that the a doses are ALARA; e if the r,timated dose to the average member of the critical group could exceed 100 mrer 1/y (but would be less than 500 mrem /yr) when the radionuclide levels are at the DC(il, a demonstration that:

that further reductions in residual radioactivity necessary to comply with the 100 arem/yr requirement are not technically achievable, would be prohibitively expene or would result in net public or environmental harm; provisions for durable institutional controls are in place, and sufficient financial assurance to enable an independent third party to carry out rechecks at the site no less frequently than every 5 years and to assume and carry out responsibilities for any necessary control and maintenance of the controls at the site has been provided.

EVALUATION FINDINGS Evaluation Criteria The staff should verify that the information summarized under"Information Requirements",

above is included in the dose modeling/ALARA demonstration subsection of the restricted use section of the decommissioning plan. The staff should verify that the TEDE to the average member of the critical group when the radionuclide levels are at the DCGL does not exceed 25 mrem /yr with institutional controls in place and that the license estimated the TEDE in accordance with Section 5 of this SRP. The staff should verify that these doses are ALARA and that the licensee has made this evaluation in accordance with the criteria in Section 7 of this SRP. The staff should verify that the TEDE to the average member of the critical group will not exceed 100 mrem /yr when the radionuclide levels are at the ?CGL , without institutional controls, and that the licensee or responsible party has estimated the TEDE in accordance with Section 5 of this SRP.

If the TEDE to the average member of the critical group could exceed 100 mrem /yr., without institutional controls, the staff should verify that the TEDE will not exceed 500 mrem /yr and that the licensee or responsible party has estimated the TEDE in accordance with Section 5 of this SRP. The staff should also verify that the licensee has determined that further reductions in residual radioactivity necessary to comply with the 100 mrem /yr requirement are not technically achievable, would be prohibitively expensive or would result in net public or environmental harm in accordance with Sections 3.2,3.3, and 3.4 of DG-4006. The staff should verify that the institutional controls provided by the licensee or responsible party meet the criteria for a durable

. institutional controls (i.e., government ownership or responsibility as the third party) in Section 4.1.1.3 of DG-4006. The staff should verify that the licensee or responsible party has provided sufficient financial assurance to enable an independent third party to carry out rechecks at the site at no less than every 5 years. The staff should verify that the amount of financial DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

n 1 13 assurance is sufficient to assume and carry out responsibilities for any necessary control and maintenance of the controls at the site in accordance with Section 15 of this SRP.

Samole Evaluation Findinas ib NRC staff has reviewed the information regarding compliance with 20.1403(e) summarized in the Decommissioning Plan for the [ insert name and (license number) of facility] located at

[ insert locabn of facility) according to the NMSS Decommissioning Standard Review Plan, f j

Section 16 (Resi,Sted Use/Altemate Criteria). Based on this review, the NRC staff has determined that the licensee [ insert name] has demonstrated that doses to the public from residual radioactive maMrial after the license is terminated should not exceed 25 mrem /yr, with restriction in place or [ insert one: 100 mrem /yr if restrictions are removed, or 500 mrem /yr, with conditions, if restrictions are removed]. )

1 If doses are estimate to be in excess of 100 mrem /yr, but less than 500 mrem /yr with institutional controls removed insert the following:

l in addition the licensee [ insert neme] has demonstrated that further reductions in residual radioactivity necessary to comply with the 100 mrem /yr requirement [ select as appropriate: are i not technically achievable, are proaibitively expensive, or result in net public or environmental harm). The licensee has also estab'ished durable institutional controls for the site. Finally, the licensee has provided sufficient finaacial assurance to enable an independent third party to carry out rechecks at the site at no less than every 5 years and the amount of financial assurance is sufficient to assume and carry out responsibilities for any necessary control and maintenance of the controis at the site SUGGESTED FORMAT

1. Length: 5-7 pages s

2.. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissionog Plans for Licensees Under 10 CFR 30,40, and 70". August 1989.

3. 3-5 paragraphs summarizing each of the ite,m? outlined in Acceptane C,iteria, above.

Licensees are also encouraged to submit the information in electronic format.

.16.2 ALTERNATE CRITERIA For certain. difficult sites with unique decommissioning problems,10 CFR 20.1404 includes a i provision by which the NRC may terminate a license using alternative dose criteria. The NRC expects the use of altemative criteria to be confined to rare situations. This provision was included in 10 CFR 20.1404 because the NRC believed that it is preferable to codify provisions for these difficult sites in the rule rather than require licensees to seek an exemption outside the ~1 rule. Under 10 CFR 20.1404, the NRC may consider terminating a license under alternative criteria that are greater than 25 mrem /yr (but less than 100 mrem /yr), but the NRC limits the DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6f7/99

14 conditions under which a licensee could apply to the NRC for, or be granted use of, alternative criteria to unusual site-specific circumstances.

ACCEPTANCE CRITERIA The purpose of the reyiew of the licensee's discussion of why it is requesting license termination under the Alternate Criteria provisions of 10 CFR 20.1404 is to determine if the licensee or responsible party can demonstrate that the estimated doses to the public from all man-made sources other than medical will be less than 100 mrem /yr and are ALARA, that appropriate restrictions are in place at the site and that the licensee or responsible party has sought, obtained, evaluated and, as appropriate addressed, advice from individuals and institutions that may be affected by the decommissioning in accordance with the criteria in 10 CFR 20.1404.

Reaulatory Reauirements -

10 CFR 20.1404 10 CFR 30.36(g)(4)(ii), 40.42(g)(4)(ii), 70.38(g)(4)(ii) and 72.54(g)(2)

Reaulatorv Guidance General:

DG-4006 " Demonstrating Compliance with t'he Radiological Criteria for License Termination",

Section 4.4 Dose Modeling:

DG-4006 " Demonstrating Compliance with the Radiological Criteria for License Termination",

Section 1 -

{

Section 5 of this SRP l ALARA:

DG-4006 " Demonstrating Compliance with the Radiological Criteria for License Termination",

Section 3 Section 7 of this SRP information Reauirements

. The information supplied by the licensee should be sufficient to enable the staff to determine 3

whether the residual radioactive material at the site will result in a TEDE that exceeds 25 mrem /yr, but will not exceed 100 mrem /yr (considering all man-made sources other than l

DRAFT NMSS Decommissioning SRP - For Review snd Comment Only 617/99

15 medical), when the radionuclide levels are at the DCGL and is ALARA. The information should I

also demonstrate that the financial assurance mechanism (s) are adequate for the site. Finally, the information should be adequate to allow the staff to determine if the institutional controls, site maintenance activities and the manner in which advice from individuals or institutions that could be affected by the decommissioning was sought, obtained, evaluated, and, as appropriate, addressed in accordance with NRC requirements. The staff should verify that the following information is included in the discussion of why the licensee or responsible party is requesting license termination under the provisions of 10 CFR 20.1404:

e a summary of the TEDE(s) to the average member of the critical group when the radionuclide levels are at the DCGL (considering all man-made sources other than medical);

e a summary of the evaluation performed pursuant to Section 7 of this SRP demonstrating that these doses are ALARA; e

an analysis of all possible sources of exposure to radiation at the site and a discussion of why it is unlikely that the doses from all man-made sources, other than medical, will be more than 100 mrem /yr;

-e  !

a description of the legally enforceable institutional control (s) and an explanation of how the institutional control is a legally enforceable mechanism; l I

e a description of the restrictions on present and future landowners; e a description of the parties enforcing and their authority to enforce the institutional control (s); l e a discussion of the durability of the institutional control (s);

e a description of the activities that the party with the authority to enforce the institutional

)

controls will undertake to enforce the institutional control (s);

e the manner in which the party with the authority to enforce the institutional control (s) will be replaced if that party is no longer willing or able to enforce the institutional control (s); I e a description of the duration of the institutional control (s), the ' conditions that will end the institutional control (s) and the activities that will be undertaken to end the institutional control (s);

e a description of the corrective actions that will be undertaken in the event the institutional control (s) fail; e

. a description of the records pertaining to the institutional controls, how they will be maintained and the duration of the post-license termination maintenance period;  !

e a description of how individuals and institutions that may be affected by the decommissioning were identified and informed of the opportunity to provide advice to the licensee or responsible party; e a description of the manner in which the licensee obtained advice from these individuals or institutions; e .

)

a description of how the licensee provided for participation by a broad cross-section of j community interests in obtaining the advice; l e a description of how the licensee provided for a comprehensive, collective discussion on the issues by the participants represented; e

a copy of the publicly available summary of the results of discussions, including individual viewpoints of the participants on the issues and the extent of agreement and disagreement among the participants; DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99 l

l 1

16 e a description of how this summary has been made available to the public; and, e a description of how the licensee evaluated advice from individuals and institutions that could be affected by the decommissioning and the manner in which the advice was addressed.

I EVALUATION FINDINGS l I

Evaluation Criteria j The staff should verify that the information summarized under "In%rmatiori Requirement , i above is included in the discussion of why the licensee or responsible party is requesting license termination under the provisions of 10 CFR 20.1404. Review of the manner in which I doses to the public should be estimated is addressed in Section 5 of this SRP and the stah l should refer to Section 5 of this SRP to determine if the dose estimates developed by the licensee or responsible party are acceptable. The evaluation of these doses te oetermine if they are ALARA is addressed in Section 7 of this SRP and the staff should refer to Section 7 to review the licensee's or responsible party's demonstration the doses are ALARA. The evaluation of the licensee's or responsible party's financial assurance mechanism (s) is addressed above and in Section 15 of this SRP and the staff should refer to these sections to review the financial assurance mechanisms. Th ; evaluation of institutional controls, site maintenance activities and obtaining advice from individual and institutions that could be affected by the decommissioning are ac' dressed in Section 16.1.3 and 16.1.4 of this SRP Samole Evaluation Findinas -

The NRC staff has reviewed the information regarding the licensee's [ insert name] request to decommission its facility pursuant to 10 CFR 20.1404 summarized in the Decommissioning Plan for the [ insert name and (license number) of facility] located at [ insert location of facility]

according to the NMSS Decommissioning Standard Review Plan, Section 16 (Restricted Use/ Alternate Criteria). Based on this review, the NRC staff has determined that the licensee

[ insert name] has demonstrated that doses to the public from residual radioactive material after the license is terminated should be less than the NRC limits of 100 mrem /yr. and are ALARA.

In addition, the licensee has adequately demonstrated that it has provided appropriate restrictions according to tho provisions of 10 CFR 20.1403 and has adequately sought, managed and addressehdvice from individuals and institutions that may be affected by the

- decommissioning.

SUGGESTED FORMAT

1. Length: not to exceed 10 pages

2. Physical Specifications: As described in Section 3 of Regulatory Guide 3.65 " Standard Format and Content of Decommissioning Plans for Licensees Under 10 CFR 30,40, and 70' August 1989.

3. 1-2 pages summarizinn

• c' the items outlined in Acceptance Criteria, above.

Licensees are also eficema9ed 12 s'abmit the iriformation in electronic format.

DRAFT NMSS Decommissioning SRP - For Review and Comment Only 6/7/99

17 This Standard Review Plan (SRP) is being issued in draft form, for comment, to allow interested members of the public to provide input to NRC staff in the early stages of the development of the SRP. The SRP has not yet received complete NRC staff review and approval and does not represent any official NRC positions. After NRC staff has reviewed, evaluated, and, as appropriate, incorporated, all comments submitted by the public on the draft SRP, the staff will issue the SRP in final form.

l l

I I

l DRAFT NMSS Decommissioning SRP - For Review and Comment only 6f7/99