ML20216C628

Transmits State Agreement Info (SP-98-025) Re Agreement State Views on Cost/Impacts for Closure of Formerly Terminated NRC Licenses

ML20216C628
Person / Time
Issue date:	04/02/1998
From:	Lohaus P NRC OFFICE OF STATE PROGRAMS (OSP)
To:	GENERAL, OHIO, STATE OF, OKLAHOMA, STATE OF, PENNSYLVANIA, COMMONWEALTH OF
References
SP-98-025, SP-98-25, NUDOCS 9804140519
Download: ML20216C628 (4)

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. / * " * % ,t - UNITED STATES

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..,,4 April 2, 1998 f ALL AGREEMENT STATES

~ OHIO,' OKLAHOMA, PENNSYLVANIA '

-L-TRANSMITTAL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-98-025)

Your attention is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION.. ......

PROGRAM MANAGEMENT INFORMATION.. XX AGREEMENT STATE VIEWS ON COST / IMPACTS FOR CLOSURE OF FORMERLY TERMINATED NRC LICENSES 1

TRAINING COURSE INFORMATION........... ...

' TECHNICAL INFORMATION................. .... . ...

OTHER INFORMATION................. ....... . .. .....

Supplementary information Enclosed is a copy of a January 22,1998 Commission paper,

. SECY-98-011 " Potential Funding Assistance For Agreement States for Closure of Formerly Terminated NRC Licenses," and associated March 3,1998 Staff Requirements Memorandum (SRM). Your attention is directed to the recommendations in SECY-98-011 (See page 4) and

. direction provided in the SRM. To assist in better understanding the costs and impacts of your activities to "close" these sites, we request that you provide the following information. .We' i would appreciate your responca to items 1,2 and 3 by June 30,1998. We would appreciate _

your response to item 4 by May 15,1998.

1. Status of your activities to review background materials and license files on sites located in your State to identify sites which may be eliminated from further consideration based on existing available information, and those that will require [

further assessment and possible remediation;

- 2. Identification of the number of sites that may need remediation (or have been remediated), the regulatory efforts necessary to ensure appropriate remediation/

the costs for remediation and difficulties likely to be encountered in requiring ,

y further remediation; j

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. 3. - identification of any assistance, including funding assistance, that you believe is 4

needed from NRC to complete the site file reviews, assessment and remediation activities. If you believe funding assistance is needed, we request your views on the funding mechanism or mechanism which should be considered to fund the 14000o e,tivities-(e.g., generai fund appropriation request by NRC, amendment to Atomic Energy Act, as described in the SRM).

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SP 025 4. Whether you believe the initial site surveys and assessments to determine the scope of potential remediaiton work at sites in your State are themselves so significantly expensive and difficult as to preclude you from undertaking even this preliminary step in the cleanup process, in the absence of funds or some other form of resource assistance form NRC.

As a result of responses to All Agreement States letter SP-97-080, Formerly Licensed Sites and Jurisdcition for Remaining Residual Materials, we note that several States have already provided specific information relating to portions of the above items and we will use and consider that infor.mation in development of our response to the Commission. We are also providing below additional information to assist in your efforts to determine the significance of the " scoring" assigned by the Oak Ridge National Laboratory (ORNL) to each site, and expectations as to what actions would be required to close out particular types of sites with particular scores.

1. The sianificance of the scorina: ORNL uses an expert system to evaluate the likelihood and possible magnitude of contamination at a site associated with a given license. The score assigned by the ORNL exr,ert system does not indicate any absolute risk value.

Instead, the score provides a relative estimate of the likelihood and magnitude of contamination among the licenses. The overalllicense site scores can be compared to provide prioritization guidelines for determining which licenses have the highest review priority. A detailed discussion of the License Evaluation a Document Information System (LEADIS) is' presented in the enclosed paper entitled, "LEADIS - A Computer Decision System For Identifying Potentially Contaminated Nuclear Material Use Sites."

2. NRC actions reauired to close out oarticular tvoes of sites with carticular scores:

Temporary Instruction (TI) 2800/026, " Follow up Inspection of Formerly Licensed Sites identified as Potentially Contaminated," provides guidance to the Regions on how to i close out license files identified by ORNL. We recommend that Agreement States follow guidance set out in this TI, or equivalent g :idance developed by the Agreement State.

NRC staff is currently revisir* Ti 2800/026 to incorporate more specific guidance on dealing with specific types of ..es and on interactions with Agreement States regarding transfer of background information and licensing files for sites in an Agreement State. A copy of Tl 2800/026 is enclosed for your information.

I This information request has been approved by OMB 3150-0029, expi'ation April 30,1998.

The estimated burden per response to comply with this voluntary collection request is 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

Forward any comments regarding the burden estimate to the Information and Records Management Branch (T-6 F34. U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Redui tion Project (3150-0052), Office of Management and Budget, Washington, DC 20503, if a doct'nent does not display a currently valid OMB control number, the NRC may not conduct or spons or, and a person is not required to respond to, a collection of information."

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p '.' f SP-98-025 l if you have any questions regarding this correspondence, please contact me or the individual named below. -

POINT OF CONTACT: Dennis M. Sollenberger TELEPHONE: (301) 415-2819 FAX: (301)415-3502 INTERNET:

.f DMS4@NRC.GO j m

t Paul n

H. Lohaus, Ceputy irector Office of State Programs

Enclosures:

As stated l

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SP-98-025 If you have any questions regarding this correspondence, please contact me or the individual named below.

POINT OF CONTACT: Dennis M. Sollenberger TELEPHONE: (301)415-2819 FAX: (301)415-3502 INTERNET: DMS4@NRC. GOV OriginalSIDned By:

PAUL H. LOHAUS Paul H. Lohaus, Deputy Director i

i Office of State Programs

Enclosures:

As stated l

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Agreement State File DOCUMENT NAME: G:tPHL} SP98025.PHL 75 receive a cop t of thle document let icatejn the box: "C" = Copy without attachment / enclosure "E" = Copt with attachment /enciogpre "N" = No copy OFFICE , OSITh\4 OSP:DDMC ,, 7NMSS:QWM OSP:l?('f/

NAME PLC .es:n$g6T\ DSollenberg&P' ,,

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DATE 03M98 03/f,4'98 03hW98 O!$2/98 c OSP FILE CODE: SP-A 4 i 1

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POLICY !SSUE January 22, 1998. SECY-98-011 FgI: The Commissioners From: L. Joseph Callan Executive Director for Operations Eghingt: POTENTIAL FUNDING ASSISTANCE FOR AGREEMENT STATES FOR CLOSURE OF FORMERLY TERMINATED NRC LICENSES

Purpose:

To provide a status of staff efforts to satisfy Staff Requirements Memorandum SRM-SECY 188, dated November 7,1997 and to obtain Commission approval for future actions regarding potential funding assistance for Agreement States for closure of formerly terminated NRC licenses.

Beckaround-The Commission previously approved the staff's proposal (1) for the discontinuance of detailed reviews by NRC staff of license files and inspections for follow-up on formerly NRC licensed sites identified for further investigation in Agreement States, (2) for the referring of identified cases directly to the Agreement States for follow-up investigation, and (3) to hold the Agreement States responsible for addressing remediation of those sites where excessive contamination is confirmed by inspection (see Staff Requirements Memorandum, SRM-SECY-97-188, dated November 7,1997). SRM-SECY-97-188 also directed the staff to work with the Agreement States to identify a mutually acceptable mechanism to provide Federal assistance to the Agreement States, such as a general fund appropriation outside the NRC fee base, in dealing with these cases. In that regard, the staff was directed to consider how similar funding was made available to Agreement States in the Uranium Mill Tailings Radiation Control Act of 1978

.;- (UMTRCA) and seek input from the Agreement States on the degree to which they would support such an appropriated funds approach. The Commission requested that in presenting the options the staff should also provide any available information regarding the estimated number of sites and the Agreement States affected, the typical regulatory efforts to ensure appropriate remediation and the associated costs, and any difficulties experienced by NRC and the Agreement States in attempting to require further remediation of these sites.

CONTACT: Dennis Sollenberger, OSP NOTE: TO BE MADE PUBLICLY AVAILABLE WHEN 415-2819 THE FINAL SRM IS MADE AVAILABLE QQnWiinAAn

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The Commissioners 2 Discussion:

The staff prepared and sent (see Attachment 1) an All Agreement States letter informing the Agreement States that the NRC has determined that they are responsible for any radioactive mate ial remaining at a site in an Agreement State, including material originally licensed by NRC '

- or its predecessors, where the license was terminated prior to the State becoming an Agreement

. State. The letter also requested any available information or estimates on the impact of these responsibilities on the States' resources. Only a few States (AZ, CO, GA, IL, NC, TN, TX, WA) have responded to date. Califomia has previously corresponded with NRC on the question of.

regulatory responsibility for such sites located in Agreement States. The States' comments can be summarized as follows: (1) the State does not agree with NRC's position that this is an Agreement State responsibility, however, they will protect the citizens in the State, (2) this effort '

is unbudgeted work for the State and no funds are available, (3) the State cannot provide any estimates at this time since they have not yet received the files from NRC to begin a resource estimate, and (4) the State would expect NRC to pay for any remediation and/or source disposci

- costs not covered by former licensees. Additionally, Arizona stated that they were not informed of this potential liability when they signed their Agreement, they do not have any resources to address tnis liability, and they requested that the NRC, as the responsible Federal agency, take the necessary actions to protect the public health and safety of Arizona citizens. Some States have indicated they would take responsibility for the public health and safety and the protection of the environment by conducting the remedial action once funding is provided.

The numbers of sites that may be" contaminated and need follow-up are listed in Attachment 2.

The number of States with a significant number of sites is relatively small with only two States (New York and Califomia) having ten or more sites with loose contamination and four States (New York, Tennessee, Califomia, and Texas) having ten or more sealed source sites pending.

The Commission should note that NRC's contractor, Oak Ridge National Laboratory, is still in the final stage of reviewing formerly terminated licenses.' Thus, additional Agreement State sites that may contain unacceptable levels of contamination or unaccounted for sealed sources will likely be identified. Agreement States will be informed of these sites as information becomes available to NRC staff.

Although the transfer of files will result in some unplanrmd work being transferred to the Agreement States, it appears from the general lack of comment about the appropriated funds approach that a number of States may be able to accommodate this regulatory effort. The most impacted States (Califomia and New York) did not mapond and, along with a few other States, may need assistance in both remediation and regulatory effort. However, the resources required by the States to do this work are still uncertain. The States will need a period of time to evaluate the number and type of sites that remain to be followed-up and to make reasonable estimates for the regulatory effort needed. The significant expense of this work transfer is the field sunrey, site characterization, remedial action planning and the actual remediation of any contaminated site identified. ' Additional costs will be for Agreement State regulatory oversight and review of proposed remedial actions. Cost estimates will not be available until each Agreement State completes the file review and conducts an initial site survey or assessment, or requires the )

responsible party, if known, to conduct the survey or assessment. 1 This process may take a few States up to a year or more to identify which sites are actually contaminated and the status of the site owner or former licensee and whether it may be possible l for the State to seek remedial action under the Comprehensive Environmental, Compensation, I

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i The Commissioners 3 and Liability Act of 1980 (CERCLA), as NRC has considered for a few of its contaminated sites.

In some cases, additional costs associated with site characterization and remediation may have j to be funded by the State, especially if cleanup under CERCLA is not requested or if CERCLA i cleanup is requested and denied. The remediation costs will not be known until the extent of contamination is known for the individual sites.

As the Agreement States compete their evaluation of the files transferred from the NRC Regional offices, NRC staff vill request that information be provided to NRC on the number of l sites that may need reme6ation, the regulatory efforts necessary to ensure appropriate j remediation and their costs, and difficulties likely to be encountered in requiring further I remediation. This contliuing communication with the Agreement States will be accomplished i through our routine pregram of All Agreement States letters and the routine exchange of l information process between NRC and Agreement States. Through this process, staff will identify if funding support is needed and the magnitude of the funding need. Until the Agreement States supply this information, staff believes it is premature to pursue any request to the Administration and Congress for either authorization or appropriation of funds. Information available to staff by January 1999 will be assessed to determine if the need is sufficient to support a request for funds for the purpose of prov; ding support to Agreement States for costs associated with evaluation and remediation of these formerlylicensed sites. One approach could be to incide the authorization for such funds in the NRC legislative package for the 106th Congress, and irdude an appropriation for this purpose in the NRC appropriation request for FY 2001.

l Appropriated Funds Approach '

Per Commission direction, staff evaluated how funding was made available to Agreement States in UMTRCA. In Title ll of UMTRCA, Congress expressly authorized up to $500,000 to be i appropriated (for fiscal year 1980) to the Nuclear Regulatory Commission for making grants to Agreement States to aid in the development of State programs to regulate uranium recovery operations under the new requirements of UMTRCA. The House of Representatives' report accompanying NRC's FY 1980 appropriation billindicated the House Appropriations Committee  ;

provided this 5500,000 for grants to States under Section 207 of UMTRCA of 1978. Each Agreement State involved had to submit information that was evaluated prior to the grant being approved. The costs were associated with required infrastructure changes such as legislation, regulations, laboratory equipment, and survey equipment. The funding was provided to the State prior to entering into the amended Agreement, so that the State could meet the new requirement under UMTRCA. In addition, Title i of UMTRCA provided for a Federal / State cost sharing where the Federal govemment (through the Department of Energy) funded ninety percent and the State funded ten percent of the remedial action costs for certain processing sites at which uranium was produced for sale to any Fed ,ral agency prior to January 1,1971.

Agreement State completion of the work rcquired to review formerly licensed sites does not require the infrastructure changes that the UMTRCA action required. However, the potential costs that the State may encounter to address these sites does have the potential for a significant financialimpact on a State. Following the example of UMTRCA in assuming respons : 31ity for sites formerly licensed by the NRC, Agreement States may be accepting a responsibAty such that the Federal govemment may want to provide financial relief. However, NRC has allocated no funds for this purpose and effectuation of the program may require

{ approval by the Congress (and, for practical purposes, by the Office of Management and

The Commissioners - 4 Budget), depending on the scope of the program and the size of the amounts involved. .The amount needed for such support would be dependent on the number of contaminated sites without responsible parties still in existence, the number of responsible parties without sufficient resources to fund cleanup, and the additional costs for the States to conduct regulatory. reviews and oversight.

Only one Agreement State (IL) responded with comments on the concept of NRC requesting appropriated funds. The illinois comments addressed the potential funding for work already completed by a State and that NRC should work closely with individual States to coordinate the Federal funding with each State's appropriation process.1Two additional Agreement States (TN, WA) have indicated in their response to NRC's All Agreement States letter that they would seek funding from NRC because NRC or its predecessor agency terminated the licenses for these '

contaminated sites. One State (WA) was informally notified that NRC is currently not funding cleanup costs associated with contaminated sites located in Agreement States. Califomia has not yet responded, but that State may also request funding because previous correspondence indicates it believes Agreement States should not have the regulatory responsibility for these sites.

Thus, it appears there may be a need for the Commission to seek an appropriation to assist Agreement States in carrying out their responsibilities with respect to formerly licensed sites.

Authorization for such an appropriation could be requested when information is known about the number of sites, the potential costs to Agreement States, and the amount of financial assistance needed by Agreement States. Money would not be requested to fund costs associated with approved CERCLA cleanups, or cleanups by current site owners or other responsible parties. If the Congress grants NRC this authority, the annual appropriation process would be used for requesting the anticipated funding. This approach could provide NRC the specific information needed to support the authorizing legislation request.

If the contaminated sites are cleaned up by the current site owner or the former licensee, or cleanup is authorized under CERCLA, the need for NRC to make a funding request may not arise. In such a case, the costs to an Agreement State may be small or modest, since those costs would be limited to regulatory review and oversight. The State of Illinois supplied some information for the sites that they have closed out.' This information indicates Agreement State costs for regulatory review and oversight of a number of transferred sites may be modest. For the thirty two sites that did not require site visits or surveys, they expended approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />.- For the other twenty two sites, they have expended 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br />. Only one site required limited remedial action which the site owner completed. The State has yet to perform the final survey before releasing the site for unrestricted use. The State's estimated cost for the

- total regulatory effort including the final survey is $51,500. This would close all the formerly licensed sites that NRC has identified, to date, in the State of Illinois.

Recommendation:

The staff recommends that the Commission:

-1. Endorse the staff's approach of monitoring the Agreement State implementation of the closure of these cases and collection of information on the costs to the Agreement

- States.

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The Cornmissioners 5

2. Note that, upon Commission approval, the staff will consult with the Agreement States

'on funding mechanisms. After the information needed is gathered and the consultation ,

is completed, the staff will present its recommendations, including an assessment of legislative needs.

Resources:

The resources for transfer of the files to the Agreement States and initial coordination with the Agreement States were addressed in SECY-97-188. The ongoing coordination with the Agreement States will be conducted as part of the routine activities of the Office of State Programs. Therefore, at this time, no additional resources are required to implement the actions discussed in this paper. Staff notes that before Agreement States complete their assessments of the transferred files, it is premature to assess the costs to States of remediation, the costs of associated Agreement State program regulatory activities, and the need for Federal funding assistance.

Coordination:

The Office of General Counsel has no legal objection to this paper. The Office of the Chief Financial Officer has reviewed this Commission paper and has no objection.

9 L. Johph Callan Executive Director for Operations Attachments:

1. All Agreement States Letter dated November 14,1997

2. Table of the Number of Potentially Contaminated Sites in Agreement States DISTRIBUTION:

Commissioners SECY NOTE:

Commissioners' completed vote sheets / comments OPA should be provided directly to SECY by c.o.b.

OCA Friday, February 6, 1998.

Commission staff office comments, if any, EDO should be submitted to the Commissioners NLT REGIONS Friday, January 30, 1998, with an information SECY copy to SECY. If the paper is of such a nature that it requires additional review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

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[pu:g t UNITED STATES g

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NOCLEAR REGULATORY COMMISSION j

WASHINGTON. D.C. 30666-4001

.....# November 14, 1997 ALL AGREEMENT STATES OHIO, OKLAHOMA, PENNSYLVANIA TRANSMITi'AL OF STATE AGREEMENTS PROGRAM INFORMATION (SP-97-080)

Your attention is invited to the enclosed correspondence which contains:

INCIDENT AND EVENT INFORMATION...........

PROGRAM MANAGEMENT INFORMATION....XX FORMERLY LICENSED SITES AND JURISDICTION FOR REMAINING RESIDUAL MATERIALS TRAINING COURSE INFORMATION............ ...

TECHNICAL INFORMATION... ..... ..................

OTH ER IN FORMATI ON............................... ....

Supplementary Information: The Nuclear Regulatory Commission (NRC) has been reviewing previously terminated licenses to determine whether there was appropriate documentation that .

the sites were adequately decontaminated prior to termination of the license and release of the site. This project was initiated in 1977 for licenses terminated prior to 1965. Another effort I was initiated in 1989 for licenses terminated after 1965, which was subsequently expanded to )

include all terminated licenses. A number of sites have been identified for which there is insufficient documentation to ensure that the she was adequately decommissioned or to account for all sealed sources. NRC regional offices are currently working to close these records through additional file searches and, when necessary, site surveys. NRC guidance for conducting these follow-up inspections is documented in Temporary Instruction 2800/026 (Tl 2800/026), and copies were provided to the Agreement States.

Radioactive material remaining at a site located within an Agreement State, including material originally licensed by NRC or its predecessors, is the regulatory responsibility of the Agreement State. Therefore, an Agreement State is responsible for conducting detailed license and inspection file reviews, and investigation and remediation of any site, as appropriate, identified through NRC review of previously terminated licenses for which there is insufficient

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documentation to ensure that the site was properly decommissioned or which has inadequate accounting of sealed sources. A number of cases have already been referred to Agreement States for follow up. Additional cases may bs referred in the next few months as our contractor completes its review of old f;ies.

!l ATTACHMENT 1 I hjff~/ONO~ f ,

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- SP-g7- 080 2 E I4 157 After review of the files, some cases require on-site inspections to determine whether excessive contamination may be present. Up to now, NRC has conducted numerous inspections in Agreement States where the States have indicated resource constraints or have indicated that they do not believe they have regulatory jurisdiction. However, in light of our own resource constraints and our position that Agreement States have jurisdiction over these sites, NRC is phasing out detailed reviews oflicense files and follow-up inspechons. Sites that appear to require further investigations or inspections to properly assess the sites will be referred to the appropnate Agreement States for follow up. The States will continue to be responsible for regulation of any needed remediation of any contaminated sites under theirJurisdiction. To maintain a complete database on the status of terminated license sites, Agreement States are requested to report rese!ution of each case to NRC for tracking To minimize the reporting burden on the States, the resolution reports may be in the form of short summaries or copes of pertinent correspondence. These resolution reports should be sent to your respective NRC Regional decommissioning contacts (see Enclosure 1).

Agreement State activities to review and resolve issues associated with terminated licenses referred to them will be examined during Agreement State program reviews conducted using the Integrated Materials Performance Evaluation Program. However, State actions on referred cases will not affect findings of adequacy under the IMPEP unless there appears to be a significant threat to public health and safety resulting from a lack of appropnate State action.

In an effort to reduce the resource impacts on Agreement States, the Commission has directed the staff to work with the Agreement States to identify mutually acceptable mechanisms, such as "a general fund appropriation outside the fee base," for providing Federal assistance to affected Agreement States. To identify the magnitude of an appropriation estimate, we are requesting any available information that you might have on how your State is or may be affected, such as the number of sites in your State that may need remediation, the typical regulatory efforts needed to ensure appropriate remediation and their costs, the associated costs of remediation, and any difficulties exponenced by the Agreement Statea in attempting to require further remediation of these sites. For Agreement States that are beginning this activity, please provide general estimates, and the basis for those estimates, for the infomation needs listed above. Any information available would be most usefulif provided by December 10,1997. .

This information request has been approved by OMB, NO. 3150-002g, expiration April 30,1998. Estimated burden per response to comply with this voluntary collection requsst:

3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, O minutes. Forward comments regarding burden estimate to the information and Fecords Management Branch (T-6 F33), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, and to the Paperwork Reduction Project (3150-0052), Office of Management and Budget, Washington, DC 20503. NRC may not conduct or sponsor, and a person is not

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SP 080 3 NOV 14 1E7 required to respond to, a collection of information unless it displays a currently valid OMB control number.

if you have any questions about this correspondence, please contact me 'or the individual named below.

CONTACT: Dennis M. Sollenberger TELEPHONE: (301) 415-2819 FAX: (301) 415-3502 INTERNET: DMS4@NRC. GOV lc fli( Al Richard L. Bangart, Director Omce of State Programs

Enclosure:

As stated l

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i FORMERLY LICENCED SITES REGIONAL CONTACTS Region 1: Craig Gordon/ Tony Dimitriadis U.S. Nuclear Regulatory Commission 475 Allendale Road King cf Prussia, PA 19406-1415 610-337-5216/6953 CZG@NRC. GOV /AXD1@NRC. GOV Region 11: Bryan Parker U.S. Nuclear Regulatory Commission Atlanta Federal Center,23 T85 61 Forsyth Street, S.W.

Atlanta, GA 30303-2415 404-562-4728 BAP@NRC. GOV Region 111: Bill Snell U.S. Nuclear Regulatory Commission l

801 Warrenville Road '

Lisle, IL 50532-4351 630-829-9871 l WGS@NRC. GOV Region IV: Dean Chaney U.S. Nuclear Regulatory Commission Walnut Creek Field Office 1450 Maria Lane, Suite 300 Walnut Creek, CA 94596-5368 l 510-975-0229  !

HDC@NRC. GOV j l

I ENCLOSURE 1 l

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TERMINATED LICENSE SITES IN AGREEMENT STATES (UPDATED 9/18/97)

Agreement State Sites Sites Sites Sealed Sealed Sealed

, Identified Closed Review Sources Sources Sources l

by ORNL Pending identified Closed Pending by ORNL 1

Region i

1. Maine 2 2 0 1 1 0

2. Maryland 31 31 0 14 7 7

3. Mass. 49 49 0 17 17 0

4. New Hampshire 1 1 0 0 0 0

5. New York 36 26 10 37 18 19 l

l 6. Rhode Island 4 4 0 4 4 0 Region ll

7. Alabama 3 2 1 14 10 4

8. Florida 3 2 1 5 2 3  :

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9. Georgia 3 3 0 2 0 2

10. Kentucky 3 1 2 5 3 2

11. Mississippi 0 0 0 4 3 1 I

12. North Carolina 2 2 0 3 0 3

13. South Carolina 3 3 0 1 0 1 l 14. Tennessee 9 6 3 10 0 10 Region lil

15. Ilinois 35 34 1 22 22 0 l

16. Iowa 0 0 0 3 3 0 Attachment 2 E_ . - - . .

4 TERMINATED LICENSE SITES IN AGREEMENT STATES (UPDATED 9/18/97)

Agreement State Sites Sites Sites Sealed Sealed Sealed identified Closed Review Sources Sources Sources by ORNL Pending identified Closed Pending by ORNL Region IV

17. Arizona 4 0 4 1 0 1

18. Arkansas 1 1- 0 5 4 1

19. Califomia - 95 55 40 43 27 16

20. Colorado 13 9 4 5 0 5 21 Kansas 6 6 0 5 0 5

22. Louisianna 1 0 1 1 0 1

23. Nebraska 2 1 1 1 1 0

24. New Mexico 6 6 0 5 2 3

25. Nevada 4 2 2 4 2 2

26. North Dakota 3 3 0 1 0 1

27. Oregon 2 2 0 2 2 0

28. Texas 10 7 3 27 9 18

29. Utah 6 4 2 5 3 2

30. Washington 6 6 0 7 5 2 s'

2 Attachment 2

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UNITED STATES

, f  %. NUCLEAR REGULATORY COMMISSIO g

} WASHINGTON. D.C. 20666-0001 90 MAR -1 PM 3 21. March 3,1998 OFFICE OF THE SECRETARY MEMORANDUM TO: L. Joseph Callan t

Ex ve ' rector for Operations FROM: Joh Hoyle, b

. cretary

SUBJECT:

STAFF REQUIREMENTS: SECY-98-011 - POTENTIAL FUNDING ASSISTANCE FOR AGREEMENT STATES FOR CLOSURE OF FORMERLY TERMINATED NRC LICENSES The Commission approved the staffs approach of monitoring the Agreement State's progress in closing out the case files associated with sites located in Agreement States that were formeriy licensed by the NRC or its predecessor, and collecting additionalinformation from individual Agreement States regarding the associated costs and potential funding mechanisms to provide Federal assistance. In imp %menting this monitoring and information collection program, however, the staff should e e,o undertake the following additional measures:

inquire of the States during the further consultation on funding mechanisms proposed in SECY 98-011 whether the initial site surveys and assessments to determine the scope of the problem are themselves so significantly expensive and difficult as to preclude the States from undertaking even this preliminary step in the cleanup process, in the absence of other funds or some other form of resource assistance from the NRC.

ensure that the file review being conducted by the Oak Ridge National Laboratory is completed in March 19g8, that the files are subsequently transferred to the States promptly, and that milestones are established on when NRC needs to receive information from Agreement States. The staff should make an initial recommendation on whether NRC should request a general fund appropriation, to cover the associated Agreement State costs for those States providing a response consistent with the FY 2000 budget cycle.

consider the merits of an attemative approach to providing financial assistance to individual Agreement States by developing a narrowly focused amendment to the Atomic Energy Act that would allow the Agreement States to retum their regulatory authority and responsibility for formerly licensed sites to the NRC if the licenses in question had been terminated before the State became an Agreement State and permit ther NRC to receive appropriations off the fee base to cover the costs associated with closure of these sites.

(EDG) (SP) SECY Suspense: 9W98) 9700277 8/25/98 SECY NOTE: This SRM, SECY 98-011, and the related Voting Record will be made publicly available 5 working days after the date of the final SRM.

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The staff should also continue to inform the Commission of any difficulties experienced .)y the NRC or the Agreement States in attempting to require further remediation of these sites.

cc: Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan EDO

-OGC OlG .

CIO CFO OCA OPA Office Directors, Regions, ACRS, ACNW, ASLBP (by E-Mail)

PDR DCS

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LEADIS- A COMPUTER DECISION SYSTEM FOR IDENTIFYING POTENTIALLY CONTAMINATED NUCLEAR MATERIAL USE SITES Elaine A. Zeighami Paul F. Goldberg Kelly M. Spencer Oak Ridge National Laboratory U.S. Nuclear Regulatory Commission University of Tennessee 1060 Commerce Park Two White Flint North 109 Temple Court -

Oak Ridge, Tennessee 37830 Washington,DC 20555 Knoxville, Tennessee 37966 (423)S74-4503 (301)415-7842 (423)241-6032 ABSTRACT Several factors do lead to uncertainty and inconsistency in the closcout and decommissioning The objective of the Terminated License Review process, particularly when considering licenses and sites project is to review all terminated nuclear material issued, used and closed out over a fifty-year period of licenses ever issued in the United States since inception of time. Over that time span, there have been substantial licensing (early 1950's). The review includes two changes in both laws and decommissioning regulations.

objectives: (1) dentify sites with potential for Practices in waste generation and onsite disposal, as well meaningful residual contamination; (2) identify sealed as applicable regulations, have changed over the period.

sources with incomplete accounting that could be a Further, there is a vast diversity of material licenses present public hazard. To date, the project itself has themselves, as ~well as a relatively large volume of identified over 600 sites for further review, leading in licenses and situations that can and do occur in the l- some instances to site revisits and preliminary surveys. licensed uses of radiological materials.

Birty sites not previously known to be contaminated have been identified as having residual contamination in II. T11E LEADIS SYSTEM excess of guidelines through the project and subsequent NRC followup. In addition, several instances have been ne licensing process for nuclear material licenses found of significant sealed sources that had dropped from began in the early 1950's, originally under the auspices of regulatory oversight but were still at the former licensee's the Atomic Energy Commission. Material licensing falls facility. into three basic categories: Part 30, or byproduct material licenses; Part 40 or source material licenses; and Part 70 The first level of the review to identify potential or special nuclear material (SNM) licenses. The term candidate licenses for further examination is carried out 'Part' refers to the Part of Title 10 of the Code of Federal using a computer decision system named LEADIS, Regulations that defines and regulates each material specifically developed for that purpose. His paper category.

provides a description of the structure and logic of the LEADIS system. In 1974, upon creation of the Nuclear Regulatory Commission (NRC), all current and historical files

1. INTRODUCTION regarding material licenses were transferred to the NRC, along with licensing responsibility for material licenses.

' There are thousands of historical radiological Currently, NRC issues and administers all material material use sites in the United States, ranging from licenses in the three categories, except those in agreement locations with only trivial, short-term or low-hazard use states.

to sites at which large quantities of high-hazard materials were used in a variety of ways over extended periods of Both historically and currently, a licensee terminating time. On the other hand, some sites have had multiple a material license or a licensee whose license is uses over the years that employed a wide variety of both involuntarily terminated is required to submit materials and activities. In both instances, many of the documentation regarding both the disposition of the sites are no longer in use, licensed material and the current status of the site. NRC reviews the licensing information and licensee's closecut submittal, generally at the Region level, and determines i i

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the required actions. The actions range from the license (1) THE SITE: Does the available information about )

being terminated after NRC Region file review to the site or sites used under the iicense indicate a need requirements including licensee surveys of a speciGed to re-evaluate the site for possible residual nature, NRC or contractor radiological surveys of the site, contam.ination?

mandated cleanup, ar.d verification surveys. llistorically, (2) Tile SEALED SOURCES: Does the available licenses typically were terminated after region file review. information about the sealed sources possessed under the license allow the evaluator to conclude that the i The NRC decided to undertake review of terminated accounting for the disposition of the sources was material licenses to assure that facilities were properly adequate? If not, does the current hazard of the l decontaminated and pose no threat to public health and sources indicate a need for follow-up to determine safety. This task is complicated by several issues. the fate of those sources remaining unaccounted?

There have been very large numbers of very diverse material licenses issued historically, by multiple agencies, Some licenses have only sealed sources and receive j using different laws and regulations, ne total number is only the scaled source review, assuming no events certainly well over 50,000, counting active licenses. implying loss of containment or other sources of facility Internal procedures have also evolved and changed. No contamination. Licenses with both seated and unsealed ,

(loose) material receive the two types of review computerized data base existed for the historical records.

separately (i.e. both a sealed source review and a site j For all these reasons, it was necessary to develop a review). Licenses with only loose material receive a site i standardized, computerized means of examining, revi:w that can, depending on initial hazard estimates, recorJing and screening the licensing material to perform include a detailed examination of the information and the initial review of licenses. This large undertaking is characteristics of the individual sites used under the ongoing, with initial review and identification of license.

candidate licenses for further review being carried out by Oak Ridge National Laboratory (ORNL). Upon The system uses estimates of potential severity or ]

completion in 1998, a review and evaluation of the meaningfulness of certain problems in a wide variety of available documentation will be complete for close to situations. The evaluation of a site for potential 42,000 terminated material licenses, as will computerized contamination is considerably more complex than for entry ofinformation from over 70,000 physical files. The sealed sources. Consequently, the rule-based aspects of evaluation includes an accounting for sealed sources (if the system are far more extensive for sites than for sealed authorized), as well as an evaluation that assesses both the source evaluations.

likelihood and potential severity of residual site contamination (if materials were authorized as loose). This paper will describe how the system evaluates and identifies potential problem sites, based on the A PC-based computer decision system known as information available for radiological material use at the LEADIS (License Evaluation and Document Information site.

System) has been developed to accomplish the objective of reviewing this information in addition, the use of the 111. UNDERLYING LICENSEINFORMATION system to review all licenses creates a permanent computerized record of the historical licensing material A. Documentation and Evaluation and the project's findings. LEADIS is a program and Although frequently referred to as a site evaluation, collection of data sets that collects, summarizes, the basic unit for a particular evaluation is actually a evaluates, and stores mformation regarding nuclear license number, with the evaluation using all the cu Tently material licenses. The system has been developed by available information about that license. Logistically, the ORNL under the sponsorship of the NRC. available m

. formation at evaluation time may or may not LEADIS uses historical licensing file material to be aH of the cuant pnnadon for se beense, sbee 6e mf rmat,on is , contamed ,m physical folders m, storage I

identify sites that require further NRC review and

. boxes. De folders and boxes were retired (i.e. sent to the ultimately re-survey and action to limit access and/or governmental archival facility) at different times and by require cleanup. At the same time, the system several different sources. File retirement practices, as mdividually evaluates authon, zed sealed sources for both well as licensing practices, have changed considerably current hazard and adequacy of accounting at closcout. over time, complicating the evaluation process.

De system evaluates the available information for a i license in two categories of questions:

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To date over 2000 boxes of files, with an average of instances, the information in the license file is insufGcient f

twenty to twenty-five files per box have been processed. to sfy that the materials were actually possessed. j Some folders contain information for more than one Unless inciation is present to the contrary, materials license, are assumed to ee been possessed under the license at the authorization limit speci0ed.

An inventory record is entered for each primary licensing folder encountered. If a file has licensing One of the principal difficulties in organizing a information for more than one license number, multiple reasonable evaluation scheme for this situation is the fact inventory records are entered, one for each license that material licensing specifications are ordinarily given number. by specifying for each licensed material an upper limit on the amount or activity of the material to be possessed at If the inventory record is the first inventory record any point in time. While the rationale for using this l for that license number, an evaluation is carried out, scheme in licensing specifications is clear, it is not the i provided the available information is sufTicient to do so. most directly relevant materials information from the l Minimum information for an evaluation, as far as the standpoint of potential for subsequent contamination.  ;

system is concemed, is a valid estimate of material The system incorporates estimates of the rapidity of j authorizations. However, unless certain administrative turnover of licensed materials, as well as a conservative j

information and some information about license activities approach to materials hazard scoring, in an attempt to is also available for the license, an evaluation may not be account in the best possible manner for the indirect  !

worthwhile, nat re of the available materials information.

When another folder for an evaluated license is IV. THE SYSTEM SCHEME encountered at a later time, that folder is inventoried and the existing evaluation is examined to determine whether The site evaluation system is a rule-based decision a re-evaluation is necessary based on the subsequent system that has a detailed ' knowledge' about material information. As many as ten per cent of the licenses licenses, as well as the factors leading to both potential require more than one ,cvaluation because of subsequent site contamination and potential hazards from sealed information found after the fisst evaluation. sources. To a limited degree, knowledge is also built into the system about how such factors interact, so that B. Sites of Use the system can combine and compare information about vari us factors to arrive at more complex decisions based A given license number may have only one site of n multiple infonnation.

use during the entire license period, or up to as many as ten or more sites of use. The latter instance is rare, but as W kvel of complexity in the system's logic as well many as two or three sites of use is common.

as the amount of information utilized and requested,

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The system gatners and stores basw information written so that the level of detail and the amount of time about the specific sites of use early m. the evaluation. If required to complete the evaluation is not greater than Justified by the nature of the materials, uses, and justified by the nature of the license / site / sources. The admmistrative considerations for the license, the system variation in complexity depends on two factors: (1) need will generate a detail site module for each site of use'

- in terms of the system's current best estimate of hazard and will guide the user through the detailed evaluation for (2) the amount of information actually available. The that specific site. The structure of the detailed evaluation higher the risk and the greater the amount of available for a specific site is determmed by the user's previously-information, the more detailed the subsequent evaluation.

entered basic site charactenstics stored by the. system.

Thus, for licenses for which the detail is justified, a  ;

3 detailed individually-scored site-s-ecific evaluation and score is obtained for each separate site of use. The ' knowledge' of the system takes essentially three forms: (1) the system's rules for decisions and actions at i C. Materials Authorizations any specific point in the evaluation process, based on the

. . . system's total current knowledge of the license and site; A site evaluation is carned out whenever materials

@ h system's ' branching' rules, i.e. its rules by which were authonzed under the license for possession in Loose it determines the next step based on the present form (often specified as Any, which m the absence of knowledge and position of the evaluation for the given further mfc,rmation is assumed to be bose). In many

f license; (3) the system's underlying factual knowledge score decreases with larger amounts of base, available in the form of data sets containing factual material, and is assigned using a series of information logarithmic-type functions. The functions assign, for example, a zero score to any Several types of underlying information sets are amount below 25 lb., a score of 2 to 400 j available to the system. The information is referenced by pounds, a score of 20 to 10,000 pounds, and a the system to make specific decisions at appropriate scorc of 200 to 1* 10' pounds.

pc' ts :n time, and as underlying information in Special Nuclear Materials - Much the same c4 taltions, type of considerations applied in scoring as

! for source material licenses. In all cases, l Materials Information Data. Score calculation for a custom values were derived, because of the l particular material is carried out using a formula based on enormous range in licensing authorizations, the hazard factors described below. For sealed sources, and because use of dose conversion fa tors the same calculation is used, but the resulting material would have led to scoring that designated score is divided by 10. only certain materials for follow-up Table 1 gives the underlying materials information Standard For byproduct waterials, the system expects a available to the system, and describes the primary ways Unit standard unit of cunes; for source materials, that LEADIS uses the information. pounds; for SNM grams. The materials data contains the expected unit, to allow the system l

Table I to prompt user for those units.

l System information about Materials Ca'egory of Description ofinformation Facilities Information Data. The system has information Information Available regarding types of facilities and activities that are typical of certain licenses, as well as a detailed facilities table.

l I Italflife The activity or amount used in making score The user determines a facility type at inventory time. The calculations is the activity or amount that system then uses information about the facility type, would be remaining at the present time, including informatbn about the general hazard level and assuming that the license authorization limit materials types ordinarily carried out at that type of was possessed at the time of termination. The facility. This information is used to guide the evaluation system uses the material halflife, and the in the initial stages. If necessary, further information is known tennination date of the license to obtained from the user, who can modify the facility calculate this value. characteristics attributed to that particular license.

Hvoroduct mserials: Estimate of hazard is " #'"# "

Estimate derived from the largest of the dose ofhazard conversion factors for inhalation and The system operates using an underlying decision ingestion, as presented in reference 1. For pattern, with specific actions determined by interaction certain special cases of licensed byproduct with the user. The user directs the course of the materials, either (1) values derived from other evaluation, based on his or her information fro n the sources were used, (2) custom values were physical folders. The user serves as a bridge allowing the chosen, or (3) the system takes into account relevant information in the physical files to be transferred the context of the license in scoring. Tritium to the system. At the beginning of the evaluation, the is the most notable example of (3). system has available the information in the inventory Source Materials For uranium and thorium, record, in which the basic facts drawn from the physical l

and their various derivatives, custom values file are recorded. The system acquires and incorporates needed to be used rather than the dose further information, during the process by querying the conversion factors. Source materials are user with specific questions.

licensed from 25 pounds up to hundreds of thousands of pounds. Use of dose conversion C. Evaluation Scoring factors would have resulted in enormous The system uses a numeric scoring scheme to arrive

, scores for source materials. The increment in at a final site score for a given license. Throughout the i l

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evaluation process, the current score is modified based on 8. Was there evidence of meaningful waste the interaction of system and user. The system carries out generation?

the following general process in calculating the final 9. Was there evidence of meaningful onsite license score: disposal j

10. Is there information in the file regarding  !

• Initial materials information: An initial materials cleanup?

score is calculated for each licensed material. The 11. Is there information or evidence in the file calculation of score for individual materials will be pertaining to decommissioning?

discussed in a subsequent section. 12. Was the site closed prior to termination of the e Overall material score: At this point the system license?

calculates the sum ot the individual mr.terial scores.

This sum is then modified by some initial The system saves a record for each site used ,

information regarding the facility type snd the under the license, detailing the characteristics of the activities. The reviewer can also modify this score site, as specified by the evaluator. Thus, a permanent by some initial choices regarding contamination and record of the site (s) specified, and the evaluator's materials. summary of each site, is kept for future reference. In his number, referred to as the Overall Material addition, this information guides setup of the detailed Score, or the Initial score, is used to determine the site evaluation, if one is necessary.

next step. If a detailed site evaluation is triggered,

• Check for characteristics allowine administrative this score is used by the system as its initial site score removal: There are certain characteristics that allow

- for EACH site. the license to be administratively removed from  ;

• Check for indications of contamination: De system further consideration, provided (1) there is no now checks the current inventory record for indication or evidence of possible or potential site preliminary indications of possible problems. It then contamination or significant onsite disposal, (2) there queries the user about preliminary evidence or was no site used under the license that was c osed out indications of contamination or of activities before license termination (referred to as intermediate potentially leading to contamination, such as sewer closeout).

disposal activities, onsite disposal, loss af containment for sealed sources. or significant Eliminating administrative characteristics are:

incineration. If such activities are found, then a detailed evaluation will be mandated. There is not 1. Superceding license - if the material, activities necessarily a change in current score, since the and site or sites used under the license were seriousness of the problem has not yet been assessed. transferred directly to another license. the license This section of the program is intended to prevent is said to be superceded. In this case, to prevent licenses from being eliminated for administrative multiple reviews of the same sites, the evaluation reasons if the characteristics indicate that such is effectively deferred to the other license (which removalis inappropriate. may be active, or may itself have already been e Determine site characteristics: This includes a terminated).

determination at this point of the number of sites, 2. Agreement state transfer - if transfer occurred to when and if closure of the site occurred, and certain an agreement state license, with the same relevant characteristics of the site that can be stipulations as above, then the evaluation is not summarized in a yes/no format. The characteristics carried out except in cases for which the site or of the site are: sites clearly need to be flagged as having potential or known contamination,

l. Was there clear evidence of no material use ? 3. Transfer to general license - A general license is

2. Were there operations conducted in buildings? issued for small devices, and when only exempt

3. Were there operations conducted outdoors? quantities are to be possessed.

4. Is there evidence of contamination outdoors ? 4. Certain administrative reasons for removal from

5. Is there evidence of releases that could lead to consideration - This includes: licenses used at outdoor contamination? power reactors (power reactor sites are not of

6. Was there use of machinery and equipment? primary interest for this project); civil defense

7. Was there use of transportation equipment? licenses (seldom involve loose materials, very low activity); import / export licenses (difficult to evaluate, seldom of primary concern for site

contamination); general licenses (sery rare use The system's final site decision about a license is of significant materials); and mining licenses based on the final overall score for that license number.

(usually multiple unidentified sites, cannot if the license had only one site of use, then the overall reasonably be evaluated), license score is the same as the summary or overall score for the site. If the license has multiple sites of use, then The evaluator has the option of overriding a the final score is the sum of the final scores for each of system's decision to climinate the license. The the sites. NRC's first cut in determining which licenses system also checks to determine that there were no require a re-review is currently based on the overall intermediate site closures during the term of the license score, license. If so, the evaluation continuesfor that site or sites that were closed only. Figure 1 outlines the overall scoring scheme of the e Check for dixoualifrine characteristics - The term LEADIS site evaluation

' disqualifying' is used in this context to mean that the license is to be disqualified from further loose Figure 1 material (site) review. A license is a candidate for Scoring System for Overal! Evaluation of Sites disqualification if it reaches this point in the evaluation w im the following characteristics: lN#O M NNM (1) low materials score (below 5) F - so,- - "- or!,,! - ~g (2) no indications of contamination, disposal or t-----

other problems lF ?SinunedMeenalSedre 37Jl (3) presence of a minimum of some information i regarding disposition of the licensed materials. Initial Y modiM ors (4) no intermediate site closcout e; e Detailed evaluation: If the license ret.ches this point

• in the evaluation without being removed, it now .. ...... .............".......... ....... ....

receives a detailed evaluation of EACli of the use  ; initial Site Score for each site detail enluation .

sites under the license. This portion of the process is described in Section VI. - --

g  %. , 2 g~~g V. SCORING -

Materials Building Outdoor Waste Gen- Onsite nd Operations Operations cration Dispos A. Material Scoring Activitie: /Lontam- /Contam- al The initial score is determined by an overall materials ination  !

ination score. The overall materials score is the sum of the Law uxwe wre nmuned by individual material hazard scores assigned by the system cleanun and twenmmis ionine information to each licensed material. The calculation of each score e - -

is based on decay, specific form of the material, and dose factors in humans'. A license is removed from fr.her evaluation at the time its site score goes to zero. ppm ,

pgg Conversely, if a license is eliminated from further - Sum of tbe Summ Site evaluation, the site score assigned at that time is zero.

For licenses whose characteristics justify a detailed evaluation, a separate site evaluation module is called, which further modifies the site-specific score. B. Overall Scoring Scheme Some licenses do not have an identifiable site. For The ' objective' of the system in a given site evaluation is those cases specified as having no site, but for which the to remove the license and its associated site (s) from overall material score is sufficient to trigger a detailed further consideration for site contamination. Precisely evaluation, a subset of relevant questions is asked, with p how this is done will be outlined in the following the detail module starting with the overall material score.

L sections. The final score calculated in this instance is actually an overall loose material score, and is assigned as the final license site score.

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C. Site Closure VI. STRUCTURE OF A SITE DETAll EVALUATION A site can be designated as being closed out for each site NOT closed out in the period of the e prior to license termination (also called intennediate ' license, the evaluator is queried about whether there is a decommissioning). The licensee is required to need to carry out a detailed evaluation of the site. If the notify the agency that use will no longer occur, and evaluator chooses to evaluate, the site routine is triggered, an amendment issued. In certain instances, however, if not, then the overall material score is assigned to this a site or sites are apparently dropped in the license site.

and amendment process, without information being included in the file regarding the site or the nature of A. Categories of the Site Detail evaluation its closure. With or without notification, a dropped ne are up to six categories included m. the site site is treated at being closed out prior to license detail evaluation. These categories include terminntion.

s nc if no license tr Build pera o s d id ntamination er) a e Outdoor Operations and Outdoor Contammation not closed out at time of license termination (the * " "

usual instance if the license is transferred to another O i D ,, ,

a Cleanup and Decommissionw, An evaluator's indiution of onsite disposal occurring The category Mrerials Handling is triggered each specifically at the site will trigger a detailed evaluation of time a site evaluation is entered. This section asks the site, regardless of the loose material score or the time questions that apply to any site or license. The specific of ci se ut.

evaluation categories are: Building Operations and C ntam n ti n, Outdoor Operations and Contamination, D. System Protocol for Site Closure Waste Generation, and Onsite Disposal. Each category is The system has the protocols described below for triggered only if the evaluator's entered summary for that dealing with sites and the triggering of a detailed site indicated that that category was relevant.

evaluation according to time of closure:

1. Materials Handling and Site Activity. The

1. Site closed PRIOR TO or AT termination. These following information is included in the Materials sites will be evaluated any time the system reaches the Handling section: Rapidity of material turnover ; )

detailed site evaluation stage. Because the time of site Disposition of licensed material at closcout; Activity at closme is collected early in the evaluation, the system th: site. I I

examines the record for site closures before it allows an adn'inistrative remo . .1 of the license. 2. Building Operations. Nature of the operations in buildings; Number of buildings and rooms in actual use; Areas I kely to be problems; Accidents and releases;

2. Site not closed out under current license. If there Evaluator s general assessment of contamination i was a license transfer, site or sites ordinarily are not likelihood" closed out. An assumption oflicense transfer is that sites under the present license are also to be covered under the

3. Outdoor Operations or Contamination. Nature of the outdoor operations; physical areas with highest ,

potential for contamination; Accidents and releases; 1 Any sites closed out prior to transfer will receive the Evaluator's estimate of likelihood of significant  !

detailed site evaluation, if license characteristics (as contamination; i reflect in ove:all materials score, and certain flags that  !

force evaluation) justify the detail. 4. Waste Generation. Types of waste generated; Qualitative estimate of volume generated for each type of If the evaluator over ede the decision to remove, i.e. waste.

the license was r40t removed for administrative reasons, then the decision to carry out a detailed site evaluation is 5. Onsite Disposal. Since the vast majority of j the same as for any other license. onsite disposal involves waste, rather than licensed I

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r material, the onsite disposal module refers back to the (2) For all the sites used under the license, the information on types of waste generated. For each type, comparison of the Summary Site Score for the sites can the system requests the location (s) of the possible delineate which of the sites are identified as having disposal, along with the evaluator's best estimate of contamination potential, and closeout deficiencies.

volume (qualitative)

. . The overall license site scores can be compsed to

6. Cleanup and Decomm.issiomng. For each  !

provide prioritization guidelines for determining which specific category of concern for the site (e.g. buildings, licenses have the highest priority for review and onsite disposal areas), the cleanup and decommissionmg consideration by the responsible agency.

module asks the user to select from a menu of types of information pertaining to cleanup and decommissioning of that area. The menu categories include all types of Vll.

SUMMARY

information or activities that could pertain to the determination of whether the site meets or does not meet This paper has presented a description of the purpose, current standards in that particular category or area of the uses and structure of a computer decision system known site. The selections range from NRC regional letters of as LEADIS. The LEADIS system provides a structured, verification and closeout inspections to cleanup and organized, rapid screening system for evaluating, verification surveys. For each type of information identifying and prioritizing licenses and their sites of use available, the system requests an estimate of how that have a meaningful likelihood of radiological pertinent or thorough was the information or activity. contamination. The decision system in effect enforces a The combination of the general degree of applicm.mity of particular structure in the decision process, creates a that particular information or activity and the evaluator's situation in which all the appropriate concerns for a estimate of thoroughness determines the degree of particular situation must be addressed, and assists the reduction of the category score. evaluator with information in appropriate places. In addition, it carries out information management and The Cleanup and Decommissioning questions occur storage in an automated fashion. Thus, as license in the context of the responses in the first four categories, evaluations are carried out, the underlying data bases are Each site detail category that receives a score triggers the built, resulting in a large addition to the usefulness of the cleanup and decommissioning question set for that entire process, specific module. The responses in the cleanup and decommissioning module for that category modify the The common basis for evaluation of the licenses score for that particular category. permits a comparison of likely risks, and establishes priorities for further review.

B. The Site Score ACKNOWLEDGEMENTS The site score for a particular site is the sum of the five final categcry scores. For a license that does receise This effort was sponsored by the United States a summary site score, this scheme allows several Nuclear Regulatory Commission under FIN Number comparisons that delineate the particular potential , L1596, Review of Terminated Material Licenses.

problem areas identified by the evaluator and system:

(1) For each site used under the license, the system uses REFERENCES the scores to identify in the summary report those particular areas of concern at that site. While this does ' Eckerman, LE., Anthony B. Wulbarst, and Allan not mean that these areas are in fact contaminated, it does C.B. Richardson, Limiting Values ofRadionuclide Intake allow a user of the evaluation to pick out those treas of and Air Concentration and Dose Conversion Factorsfor the facility / site that are of the greatest potential concern. Inhalation. Submersion andIngestion. Federal Guidance Report No. I1, EPA 520/1-88-020, September,1988.

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NUCLEAR REGULATORY COMMISSION I waswinorow, o.c. sones-cooi

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NRC INSPECTION MANUAL Inos/NMSS TEMPORARY INSTRUCTION 2800/026 FOLLOWUP INSPECTION OF FORMERLY-LICENSED SITES IDENTIFIED AS POTENTIALLY CONTAMINATED SALP FUNCTIONAL AREA: N/A f

APPLICABILITY: 2600 and 2800 2800/026-01 OBJECTIVE ,

j To verify the status of formerly-licensed sites for which there is inadequate documentation in the docket file to demonstrate that they were properly decommissioned.

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2800/026-02 BACKGROUND In 1976, the General Accounting Office (GAO) raised concerns about the j decommissioning of sites formerly licensed by the Atomic Energy Commission's (AEC's) regulatory body, which is now the Nuclear Regulatory Commission (NRC).

In its response, NRC agreed to reexamine the files of the terminated licenses.

Between 1977 and 1982, Oak Ridge National Laboratory (ORNL) reviewed the docket files for all fuel cycle and materials licenses teminated before 1965 (approximately) to verify that all sites had been properly decommissioned. This was done under an interagency agreement with the NRC. The files of 16,230 former licensees were reviewed and a total of 12 contaminated sites were identified.

All of the 12 sites had been licensec, pursuant to 10 CFR Part 40 and none represented a significant risk to public health and safet.y. NRC took action to have former licensees decontaminate seven of the sites. The Department of Energy (DOE) accepted responsibility for the other five sites under its Fomerly Utilized Site Remedial Action Program (FUSRAP).

In 1989, GAO issued a report on NRC decommissioning procedures and criteria.

Th's report raised additional concerns about the decommissioning of fomerly-licensed sites. On August 3, 1989, Chairman Carr testified to the House Subcommittee on Environment, Energy, and Natural Resources that NRC would review the recortis of all sites terminated since 1965. ORNL was contracted again to review all docket flies retired between 1965 and 1985. This second study required the creation of a computerized inventory of the docket files in addition to screening the files to determine whether all licensed sites had been properly decommissioned. If documentation were inadequate to verify that a fomerly-licensed site had been properly decommissioned, the status of the site was to be verified by inspection. '

Issue Date: 02/16/95 2800/026

Subsequently, NRC decided that it was necessary to review the files *, o terminateo licenses (Pre-1965 and Post-1985) usingThis the would sameimprove screening criter and to document their status in one computer inventory.

information retrieval and permit comparison of the review findings for all The staff intends to verify by inspection the status terminated license files.of additional sites for which there is inadequate decom also.

2800/026-03 INSPECTION REQUIREMENTS 03.01 When the docket file for a formerly-licensed site or a sealed source license is referred to the region for followup, review the concerns raised by ORNL and verify that there are no errors or misunderstandings in ORNL's findings. First priority shall be given to sites scoring >300, Check regional then sites scoring $300, and then sealed source files.

files and institutional memory regarding legitimate co ORNL.

owner to review its files and institutional memory regarding about the site.

there is reason to believe that State files may help, request the Agreement State to check its files and institutional memory, and forwa any results to the region.

03.02 For each site in question, determine whether a site visit is required toIf the s resolve any of the concerns raised by the file review.

located in an Agreement State, request the Agreement For sealed sourceState to inspect the licensees, site, with NRC- accompaniment if necessary.

a site visit would not be required normally; however, if the site will be inspected because of potential site contamination, an inquiry into the disposition of the sealed sources can be conducted as part of the site visit.

Inform the Regional State Agreements Officer (RSAO) of any requests made to an Agreement State.

03.03 Coordinate all site visits with the appropriate radiological control program within the State, local authorities, the fomer licensee Explain the (if possible), and current site owner before the inspectio 03.04 Detemine if documentation missing from the docket file canCheck be obtaine from additional records that may still be available at the site.

the institutional memory of site operations by interviewing key personnel from the fomer licensee, current site owner (if different), or o knowledgeable individuals.

made by telephone or written correspondence if possible.

03.05 If necessary or desirable to verify the status of the with previous AEC/NRC activities. Detemine whet Notify IMDB/ MSS promptly of any site 'found i

unrestricted use.

contaminated and obtain MSS input on plans to proceed.

NOTE: If significant site contamination is identified, the inspector should contact regional management before leaving the site to discuss the need for barriers, Issue Date: 02/16/95 2800/026 i

C _._ ..

postings, and/or administrative controls to address any immediate health and safety concerns.

03.06 If the former licensee or current site owner will perform remedial actions that are expected to be completed within a few months, monitor the cleanup activities to ensure they meet the intent of 10 CFR Parts .19 and 20, and verify that the site is decontaminated to levels suitable for unrestricted use. Coordinate with IM08/NMSS regarding the transfer of sites requiring long-term remediation to the Site Decommissioning Management Plan (SDMP) or another long-term program.

03.07 When all regional action on a license file is complete, return the file to the NRC File Center, unless otherwise instructed.

2800/026-04 G1JIDANCE 04.01 If an Agreement State cannot support a request to review its files, the region should assist with the review of State files to the extent possible. If there are questions about whether NRC will b* ?.11 owed to review State files, coordinate with the RSA0 and IMNS/NMSS. Obtain copies of official documents for the docket file whenever possible. If official documents are et available, verbal confirmation may be used to close out specific cw a as about contamination if a record of such conversations is placed b the docket file 104 neither of the following conditions apply. Verbal confirmation shall Dg1 be used as a basis for closing out a concern if --

a. The concern raised by ORNL involved the sensitivity of the survey instruments originally used, or

b. The license authorized possession of a large quantity of unsealed material (>100 kilograms of uranium / thorium or >l curie of long-lived byproduct material such as cobalt-60).

04.02 Copies of Agreement State inspection reports should be obtained for the docket files. The region should review Agreement State inspection findings and detemine whether they resolve the concerns about the license file. If an Agreement State cannot support a request to inspect a site in its jurisdiction, the region should offer to provide assistance with inspecting the site. If there are questions about NRC performing an inspection in an Agreement State, coordinate with the RSAO and 1991S/194S5.

The license files involving unaccounted sealed sources are a lower priority and less amenable to resolution. For active sites, or even licensees active at another site, it may be possible to detemine the disposition of the sources. Government licensees in particular may be able to determine the disposition of sources. For licensees no longer active, it may be very difficult to come to any conclusion. Recognizing the difficulties of tracing the disporition of sealri sources when neither documents nor institutional memory remain, the regions should try to resolve these without an undue expenditure of effort and should exercise their judgment as to whether particular sources are of cu..<.ern.

04.03 The inspector should try to arrange mutually agreeable inspection times to ensure that knowledgeable individuals at the site will be available for interview. Non-Agreement States should be invited to accompany the inspector on any site visits. -

Issue Date: 02/16/95 2800/026

04.04 Obtain copies of official documents for the docket - file whenever possible. If official documents are not available, verbal confirmation may be used to close out specific concerns about' contamination if a record of such conversations is placed in the docket file And neither of the conditions listed in 04.01 applies.

.04.05 The initial survey should be a scoping survey to determine whether there is any indication that residual contamination or other radioactive A sample scoping survey plan is provided in material may be present. is Appendix A, including criteria for ' determining wnen remediation required. Guidance on release criteria is provided in' Appendix B.

Inspectors may.also use guidance in Inspection Procedure (IP) 83890 and If radioactive other routine inspection procedures, as appropriate.

. material is found or if the site is too extensive to permit an inspector to reasonably eliminate the possibility of contanination, a detailed site survey 'should be performed. The fonner licensee or current site owner-should be requested to conduct the detailed site survey whenever possible. If neither party is able or willing to pe* form a survey, funds are available unda FIN A9093, " Radiological Evale,ation Assistance for Formerly. Licensed Sites," to have the Oak Ridge Institute for Science and confirmatory surveys perform scoping surveys, Education (0 RISE) ORISE may be requested (during/after to remediation),

evaluate licensee surveysand also.sample analyses. Regions should submit requ technical assistance (RFTAs) in accordance with Manual Chapter (MC) 0312 to obtain services from ORISE.

If the site has not been inspected already, regional management should consider the need for a site visit before an RFTA is submitted.

04.06 Inspectors should use guidance in IP 83890, "C1cseout Inspection and Survey," and other routine inspection procedures as appropriate to monitor remediation activities. Each region shall notify IMDB/NMSS

1. any site found contaminated and discuss transfer of sites promptly requiring long-term remediation to the SOMP or another remediation prograu. The following criteria should be used to determine which sites should be transferred to SDMP for remediation (see NUREG-1444):

a. The responsible organization is not financially viable (e.g., unable to pay for deconmissioning).

b. There are settling ponds, bur.lal sites, or. large amounts of contaminated soil that will be difficult to decommission.

c. There are contarinated structures or other permanent facilities that will be difficult to decommission.

d. There is contamination or potential contamination of the ground water from onsite wastes.

04.07 No guidance. C 2800/026-05 REPORTING REQUIREMENTS Each region shall document its findings regarding the specific concerns identified by ORNL for each site in quarterly status reports to IMD8/ MSS.

Regions should provide the infonnation shown in the example status report provided in Appendix C. IMDB will track each site referred to the region and Issue Date: 02/16/95 2800/026

verify that it is closed out. In addition, each region shall send the IM0B contact statistics on the number of sites referred to the region for followup, number of sites eliminated from concern, number of sites fou'nd contaminated, and number of sites pending a detemination. These figures should be divided into licenses with scores above 300 and scores below 300. This information is required for the Monthly Information Status Report, however it will only be i submitted gearterly. (See Appendix D for guidance.)

Inspections and confirmation surveys should be documented in an inspection report. All site visits, whether for inspection or for other purposes, should be documented including a description of the site and any controls in place.

Status reports and inspection reports shall be forwarded to the contact listed in Section 08 of this temporary instruction (TI). Documents demonstrating that a site is suitable for unrestricted use shall be placed in the docket file for that site and sent to the IMDB contact. l 2800/026-06 COMPLETION SCHEDULE The completion schedule far followup inspections of fomerly licensed sites will vary depending on the resources available and the number of sites requiring followup action. In general, the initial inspection of each site requiring a j site visit should be completed within 9 months of receiving the docket file.

2800/026-07 EXPIRATION This temporary instruction shall remain in effect until December 31, 1997.

2800/026-08 CONTACT j Questions regarding this temporary instruction should be addressed to Paul Goldberg, Project Manager for the Review of Terminated Licenses, at (301) 415-7842.

I 2800/026-09 STATISTICAL DATA REPORTING Staff hour expenditures or administrative effort should be charged to Regulatory j Infomation Tracking System (RITS) number 232BM - Review of Terminated Licenses.

Direct inspection effort should be charged to the retired docket number, the item of major interest code (i.e., IMAT - Materials Inspections), and the inspection procedure element code (i.e., OA - Other Routine Activities, or OR - Other Reactive Activities). Include the temporary instruction number 2800/026X with the appropriate status codes P - Partially Complete, C - Complete, or R -

Completed By Reference, so staff hour expenditures charged to the Ti can be accounted for by site.

Note: The docket ntauber should be listed in the Licensing Tracking System (LTS) with a retired status code 4 to ensure that fee statements are not generated and to allow RITS to recognize the retired docket as being valid for staff time expenditures. Staff should not create fictitious docket numbers for capturing staff hour data. Contact N. Noriarty at 301-415-7876, if assistance with LTS is required, or B. Jones at 301-415-7807, if assistance with RITS is required. ,

Issue Date: 02/16/95 2800/026

2800/026-10 ORIGINATING ORGANIZATION INFORMATION .

10.01 Oroanizational Responsibility. The Operations Branch of the Division of Industrial and Medical Nuclear Safety (IM08/NMSS) initiated this TI.

Resource Estimate. The estimated onsite inspection time necessary to 10.02 interview personnel, check records, and perform an initial scoping survey 1 is 8 hr,urs per site. Actual inspections at a specific site may require substantially more or less time depending on the circumstances. With trip preparation, travel, and report preparation, the total time required is estimated to average 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.

END Appendix A - Sample Scoping Survey Plan Appendix B - Guidance on Relea'se Criteria Appendix C - Example Site Status Report Appendix D - Input for Monthly Information Status Report (MISR)

Issue Date: 02/16/95 2800/026

i APPENDIX A- l SAMPLE SCOPING SURVEY PLAN Licensee: Name Address City, State, Zip Code License No.: XXX-000 (Terminated)

Docket No.: OX0-00000 (Terminated)  !

Insnection Dates: Month Day, 19yr l Insnector(s): Name(s)

Purnose of Inspection: Describe (e.g., To perform a scoping ' survey to l determine whether any radioactive contaminants exist '

onsite, and if necessary, determine., the ga-aral extent of residual activity present on building surfaces and grounds, and adjacent offsite areas.)

I. Determine radionuclide(s) used at the facility:  !'

List isotopes.

A. Review file to determine use areas:  !

Describe areas of use.

4

8. Interview previous or current employees:

Dis .ss ss applicable.

II. Identify affected and unaffected areas: 1 Discuss generally.

A. Affected Areas (Areas that have the potential for contamination):

Define (e.6., labs, machina shops, storage areas, manufacturing areas, locker rooms, emission stacks, offsite areas adjacent to release points where material may have been deposited)

8. Potentici Areas (Areas immediately adjacent to affected areas):

Define (e.g., loading docks, storage areas, hallways, roofs)

C. Unaffected Areas (All remaining arcas not identified as affected or potentially affected):

Define (e.g., offices, lobbies, bathrooms, parking lots)

Issue Date: 02/16/95 A-I 2800/026

III. Detennine survey ii.;truments and efficiency (see NUREG/CR-5849, " Manual for .

Conducting Surveys in Support of License Termination"):

A. If only a few nuclides used, determine efficiency for all nuclides:

See Sample Instrumentation Worksheet.

B. If numerous nuclides used --

1. Determine efficiency of predominately used radionuclides or

2. Determine efficiency based on nuclide present in analyzed samples.

See Saaple Instrumentation Worksheet.

C. List instruments to be used:

Complete before inspection.

IV. Burial Sites A. Determine if facil ty i had onsite burials:

Discuss (e.r.., Based on a review of the docket file and discussions with the fo,mer licensee, it was determined that there was no onsite burial.)

8. If the possibility of subsurface contamination or burials exist, what additional sampling and surveying will be conducted?

Desc.-i be (e.g., 8ecause it has been determined that onsite burial did exist, ORISE has been contacted to perform surveys of this site.)

C. Do groundwater monitoring wells exist? I Discuss (e.g., Because it has been detensined that some onsite burial took place, and onsite groundwater sampling wells exist, water samples will be collected from these wells. In addition, the results of the analysis of previous sample's from these wells will be  !

obtained.) l V. Other A. Photograph site and adjacent areas:

Discuss (e.g., Photos will IIOT be taken.)

VI. Survey A. Areas to be surveyed:

Describe (e.g., survey will include floors, drains, pipes, ducts, cracks, lower 2 meters of walls, ventilation system to extent practicable, areas adjacent to release points, and outside areas adjacent to buildings.)

Guidelines: i Affected areas - 100 percent walkover using 2-meter wide 1 ?ws. '

potential areas - 50 percent walkover using 2-meter wide 1enes.

Unaffected areas - 25 percent walkover using 2-meter wide lanes.

I A-2 2800/026 Issue Date: 02/16/95 l

B. Locations for collection of wipes:

Describe (e.g., Wipes will be collected at each location of elevated measurements or randomly, if no elevated measurements are found.)

C. Collection of residue samples:

Describe (e.g., Samples will be collected of all residues found with elevated readings, including surfaces under paint If samples are potentially contaminated with hazardous biological or chemical materials, the regional office will be contacted for any special instructions on sampling and shipping before collecting the samplo.)

D. Collection of soil / sediment samples:

Describe (e.g., Soil / sediment samples will be collected from outside areas where unsealed licensed material was stored, from areas that were formerly settling ponds, at stoi., and/or sanitary drain outfalls, and in or at the edge of streams or lakes.)

E. Documentation:

See Survey Flan by locatfon.

Describe (e.g., All survey results and locations of elevated readings will be documented with enough detail to be able to relocate any point. Reference will be made to predominant landmarks.)

VII. 16ntification of Contamination:

A. Proride sufficient information for laboratory personnel to identify / track samples and wipes that were collected:

Describe (e.g., Each sample and wipe will be uniquely identified.)

B. Conduct laboratory analysis:

1. Determine the radiological characteristics of the contamination:

Discuss (e.g., Samples will be evaluated to determine exposure rate, and whether they are an alpha, beta, or estiana emitter.)

2. Determine whether contamination is removable or fixed:

Discuss (e.g., Wipes will be counted to determine whether contamination is fixed or removable.)

3. Determine levels of contamination in samples:

Discuss (e.g., Samples will be counted and results reported to the inspector for evaluation.)

VIII. Evaluate survey and laboratory results:

1. Identify survey data and laboratory sample analysis that exceed the maximum guideline criteria:

Discuss. If activity is identified that er.ceeds the maximum reler.se guidelines, remediation is required.

See Saaple Instrumentation Wortsheet. j Issue Date: 02/16/g5 A-3 2800/026 1

4

2. Identify samples that exceed the average (over one square meter), .

but are less than the maximum guidelint criteria:

Discuss. If activity is identified that' exceeds the average release guideline, but is less that the maximum release guideline, the NUREG/CR-5849 area weighted formula will be used to determine 'he contamination level averaged over one square meter. If the area weighted average exceeds the average release guide!ine, remediation is required.

See Sanple Instrumentation Worksheet.

APPROVED BY: Date Branch Chief A-4 Isste Gate: 02/16/95 2800/026

SURVEY PLAN BY LOCATION LOCATION 1 Area: Affectef/Potentfal/

Size: ????? m Unaffected Use: Describe (e.g., U-235 and natural uranium. Uranium tetrafluoride-magnesfun blend was pressed into briquettes using a 3,000 ton Farquhar press.)

?otential for Contamination: Discuss. Modify items 1-4 as necessary.

1. 50 percent surface scan of floor (If items stored in the building cover more than 50 percent of the floor surface, than all available floor surface area will be scanned.)

2. 100 percent surface scan of cracks in floor, support beams (up to 2m high), and drains

3. 50 percent inlets / openings to ventilation system ducts i

4. collect samples of positive areas 2 to 3 times background OTHER. LOCATIONS ONSITE Repeat above (Location 1) as necessary.

i Issue Date: 02/16/95 A-5 2800/026

SAMPLE INSTRUMENTATION WORKSHEET -

Inspector:

Date:

Inspection Location:

Inspection Date:

Isotopes of Interest:

Instrument - Type: Probe:

Serial #: Serial #:

NRC #: NRC #:

Calibratina Date: Size (S): cm' Check Source: Isotope: Serial No.:

NRC Tag No.:

Half Life (Tg ): years x 365 _

days Date: Activity (A,): yCi x 2.2x10' - dpm Current Date minus Source Date (t): years or days Current Check Source Activity: A - A, x exp[-0.693t/Tg]

= x exp[-0.693 x / ] - pCi or dpa Meter Reading with check Source (N): pCi (x 2.2x10' - cpm)

Cpm Efficiency (E): N/A - / -

(x 100 -  %)

Background (B): #Ci (x 2.2x10' = cpm) Date:

cpu Location:

Background (B): pCi (x 2.2x10' - cpm) Date: l cpm Location:

I i

Background (B): pCi (x 2.2x10' - cps) Date- I cpm Location: l l

l 2800/026 A-6 Issue Date: 02/16/95 l l

.- SAMPLE. INSTRUMENTATION WORKSHEET. continued Inspector:

Date:

I

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • 4************************************************

Maximum Release Criteria for Isotope of Interest (X): dpm/100 cm 2 (See Appendix 8 and the guidance in NUREG/CR-5849.)

Instrument Reading That Equals Maximum Release Criteria: ((X/100) x S x E} + B

=

{( /100) x x }+ = cpm 2

Averaae Release Criteria for Isotope of Interest (X): dpm/100 cm Instrument Reading That Equals Average Release Criteria: {(X/100) x S x E} + B

=

{( /100) x x }+ = cpm Meter Source Checks Check Source: Isotope: Serial No.:

NRC Tag No.:

Date Time Meter Readina location l

Issue Date: 02/16/95 A-7 2800/026

~'

APPENDIX B Guidance on Release Criteria l

l l

As stated in the SDMP ,Etion Plan (57 FR 13389, April 16,1992) and NUREG-1444, the guidance for determining whether sites are suitable for unrestricted use consists of the following documents:

l 1. Options 1 and 2 of the Branch Technical Position, " Disposal or Onsite 1 Storage of Thoriusi or Uranium Wastes from Past Operations" (46 FR 52061, October 23,1981).

2. " Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," Policy and Guidance Directive FC 83-23, Division of Industrial and Medical Nuclear Safety, November 4,1983. (Editorial revision issued August 1987.)

l 3. " Termination of Operating Licenses for Nuclear Reactors," Regulatory Guide l 1.86, June 1974, Table 1, for surface contamination of reactor facility structures. Also Cobalt-60, Cesium-137, and Europium-152 that may exist in

concrete, components, structures, and soil should be removed such that the exposure rate is less than 5 micro-roentgen per hour above natural background at 1 meter, with an overall dose objective of 10 millirem per year (cf. Letter to Stanford University from James R. Miller, Chief, Standardization and Special Projects Branch, Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, April 21, 1982, Docket No. 50-141). i

4. The Environmental Protection Agency's (EPA's) " Interim Primary Drinking l Water Standards," 40 CFR Part 141. In accordance with FC 83-23, the maximum  ;

contaminant levels for radionuclides in public drinking water, as l established by EPA, should be used as reference standards for protection of groundwater and surface water resources.

4 EPA's " Radiation Dose Guidelines for Protection Against Transuranium  :

Elements Present in ti.a Environment as a Result of Unplanned Contamination," l (42 FR 60956, November 30, 1977). This document provides guidelines for i l

acceptable levels of transuranium elements in soil.

l l

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Issue Date: 02/16/95 B-1 2800/026

NRC uses the guidelines listed in the following tables as acceptable levels to -

release sites for unrestricted use. Acceptable levels for other radionuclides will be determined on a case-by-case basis.

Table 1. Acceptable Soil Contamination Levels Radionuclide* Maximum Soil Concentration (pCi/gm) _

Hydrogen-g* (no limit, see Table 2)

Cobalt-60 8 6 5 Strontium-Cesium-137l06 15 Plutonium-238g239 --

Americium-241 Radium-226* 5 Radium-228' 5 d 10 Natural Thoriumd Natural Uranium d 10 Depleted Uranium 35 Enriched Uranium 30 Table 2. Acceptable Groundwater Contamination Levels" Radionuclide* Maximus Groundwater Concentration (pCi/ liter)

Hydrogen-3 20,000 Cobalt-60 100 Strontium-90 8 Cesium-137 200 Gross alpha incl. Ra-226 15 5

Ra-226/228 i

• If only one rodiereactide le present, then the maxima concentration le the value tieted in the table. Neuever, if more than ene radienuclide le present, determine for each radienuclide the retteThe betusen sum of j the esemured concentratten (in salt er ereureseter) and the concentration tieted in the table. i the rettee may not escoed one (i.e., mity).

Order Establishing Critorie and scheeste for Decomaleelening the Steenelnare, PA Site (Sofety Light Corporation), 57 FR 6136, February 20, 1992.

U.S. Erwirennentet Protectlen Agency, heetth and Erwirenanntet Protection Standerde for Uranius and Thortus Ritt feitinge, 40 CFR Part 192, Esporte 8 and E, July 1,1991, trench Tethnicet Peeition, DIspeset er oneIte Storese of Thoris or Urante Weetes frem Poet operstlene, 46 FR 52061, October Z3, 1981.

• The values for Pu-230/239 and An-241 provided in the order a,re edetentietty higher than the vetues Caneult currently beise proposed in ImmEG 1500, Worktre Draf t Resutetery guide en meteese criterie.

Ises/istes and LtDP/ Isles if vetume are repaired.

B-2 Issue Date: 02/16/95 2800/026

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APPENDIX C Example Site Status Report Docket no. License no.

Licensee Name:

Site Name:

Site Address:

City: State: Zip: I Regional

Contact:

Phone:

Status Summary:

Issue Date: 02/16/95 C-1 2800/026

,.e

• APPENDIX U.

INPUT FOR MONTHLY INFORMAllON STATUS REPORT (MISR)

STATUS OF SITES JOENTIFIED BY ORNL l Total Sites Eliminated Sites Pending Sites Contaminated l

> 300 i 5-300 Total STATUS OF '.: CENSES WITH SEALED SOURCES NOT ACCOUNTED FOR I l

l Total Eliminated Pending

> 300 l 5-300 Total  ;

I l

l Issue Date: 02/16/95 D-] 2800/026