ML20216G052
| ML20216G052 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1998 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20216G005 | List: |
| References | |
| REF-WM-3 2800-026, 2800-26, NUDOCS 9804170320 | |
| Download: ML20216G052 (28) | |
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NRC INSPECTION MANUAL LLDP/NMSS l TEMPORARY INSTRUCTION 2800/026 REVISION 1 l FOLLOWUP INSPECTION OF FORMERLY LICENSED SITES IDENTIFIED AS POTENTIALLY CONTAMINATED SALP FUNCTIONAL AREA: N/A
,, APPLICABILITY: 2600 and 2800 2800/026-01 OBJECTIVE To determine the status of formerly licensed sites for which there is inadequate documentation in the docket file to demonstrate that they were properly decommissioned.
I 2800/026-02 BACKGROUND l
In 1976, the General Accounting Office (GAO) raised concems about the decommissioning of sites formerly licensed by the Atomic Energy Commission's (AEC's) regulalory body, which is now the Nuclear Regulatory Commission (NRC). In its response, NRC agreed to reexamine l
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 terminated before
- 1965 (approximately) to verify that all sites had been properly decommissioned. This was done l under an interagency agreement with NRC. The files of 16,230 former licensees were l reviewed.12 contaminated sites were identified. All 12 sites had been licensed pursuant to 10 l CFR Part 40, and none represented a significant risk to public health and safety. NRC took l action to have former licensees decontaminate seven of the sites. The U. S. Department of l
Energy accepted responsibility for the other five sites, under its Formerly Utilized Site Remedial '
Action Program. l i
In 1989, GAO issued a report on NRC decommissioning procedures and criteria. This report l raised additional concems about the decommissioning of formerly licensed sites. On August 3, !
1989, Chairman Carr testified to the House Subcommittee on Environment, Energy, and i Natural Resources that NRC would review the records of all sites terminated since 1965. ;
ORNL was contracted again to review all docket files retired between 1965 and 1985. This second study required the creation of a computerized inventory of the docket files, in addition to {
a screen of the files to determine whether all licensed sites had been properly decommissioned, j If documentation were inadequate to verify that a formerly licensed site had been properly decommissioned, the status of the site was to be verified by inspection.
Issue Date: 4/15/98 Tl 2800/026, Rev 1
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l ORNL's methodology for identifying licenses of concern uses an expert system to evaluate the i ,
like,lihood and possible magnitude of contamination. In general, an expert system assigns a score based on the nuclides and quantities of material the licensee was authorized to possess.
Site scores are based on the form of the material, and inhalation and ingestion dose factors and decrements for half-life. Scores are modified by information indicating possible contamination of buildings or the environment. Analyses for sealed sources are simpler, because site scores are based only on the isotopes and quantities authorized, decremented for half-life.
Subsequently, NRC decided that it was necessary to review the files of all terminated licenses (pre-1965 and post-1985) using the same screening criteria and to document their status in one computer inventory. This would improve information retrieval and permit comparison of the review findings for all terminated license files. The staff intends to determine, by inspection, the status of all sites located in non-Agreement States for which there is inadequate decommissioning documentation. The responsibility for sites located in Agreement States will reside with the States, unless the site is associated with a Federal license. The responsibility >
for closing out Federal licenses will remain with NRC. Licenses for sites identified by ORNL in Agreement States will be referred to the Agreement States for closure.
2800/026-03 INSPECTION REQUIREMENTS 03.01 Licenses for non-Federal sites located in Agreement States should be referred to the appropriate State.
03.02 Review the concerns raised by ORNL review of the docket file for the formerly licensed site or sealed source license to determine that there are no errors nor misunderstandings in ORNL's findings. First priority shall be given to sites scoring I
>300, then sites scoring 5300, and then sealed source files. Check regional files and l institutional memory regarding legitimate concerns raised by ORNL. If necessary, request the former licensee and/or the current site owner to review its files and institutional memory regarding concerns about the site.
03.03 For sites in non-Agreement States, determine whether a site visit is required to resolve any of the Region concerns raised by the docket file review. Coordinate all site visits with the appropriate radiological control program within the State, the former licensee (if possible), and current site owner before the inspection. Explain the specific issues concerning the site stctus raised by the file review.
03.04 Determine if documentation missing from the docket file can be obtained from !
additional records that may still be available at the site.
03.05 Survey the site for residual contamination or other radioactive material associated with previous AEC/NRC activities, if necessary, to verify the status of the site. Determine whether remedial actions are required to remove radioactive materials in excess of; (1) NRC limits for unrestricted use (refer to memorandum from Weber to Paperiello,
" Preliminary Hazards Analysis for Contaminated Buildings at Formerly Licensed Sites,"
dated September 30,1996); or (2) the criteria in the " Radiological Criteria for License Termination Rule," effective August 20,1997. However, licensees may defer implementation of the rule until August 20,1998. Therefore, before August 20,1998, remediation will be required only if the site fails to meet the criteria of 1 and 2, above.
1 Issue Date: 4/15/98 Tl 2800/026, Rev 1 l
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After August 20,1998, the Regions should use the criteria in the " Radiological Criteria for License Termination Rule" to determine whether remedial action is required. Notify Low Level Waste and Decommissioning Projects Branch (LLDP)/ Nuclear Material Safety and Safeguards (NMSS) promptly of any site found contaminated and obtain i NMSS 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, postings, and/or administrative controls, to address any immediate health and safety concerns. 1 03.06 Monitor the cleanup activities for short-term remedial actions performed by former licensees or current site owners, to ensure they meet the intent of 10 CFR Parts 19 <
and 20, and verify that the site is decontaminated to levels consistent with the criteria presented in Section 03.05. Coordinate the transfer of sites requiring long-term remediation to the Site Decommissioning Management Plan (SDMP) or another long-term program, with LLDP/NMSS.
03.07 Return the file to the NRC File Center, unless otherwise instructed, when all regional action on a license file is complete.
2800/026-04 GUIDANCE 04,01 The Regions should send each Agreement State a letter providing a complete listing of all sites, located in their State, that require additional followup. The letter should also request that the State notify NRC when each license file is closed, and include a brief explanation of the basis for closing each file. When the Regions receive notification that a State has closed a license file, this information should be transmitted to the point of contact identified in Section 2800/026-08. If requested by a State, the original files may be transmitted to the State to assist in closing out the license file. The license file transmittal letter should include a copy of this Tl to show the State how NRC closes its .
terminated license files. )
4 04.02 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 following conditions apply. Verbal confirmation shall Det 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 >1 curie of long-lived byproduct material such as cobalt-60).
l 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: 4/15/98 Tl 2800/026, Rev 1 o
04.04 Check the institutional memory of site operations by interviewing key personnel from I
, , the former licensee; current site owner (if different); or other knowledgeable individuals.
For sealed sources, these inquiries should be made by telephone or written correspondence,if possible.
04.05 The initial survey should be a scoping survey to determine whether there is any l indication that residual contamination or other radioactive material may be present. If j an inspector visits a site for a scoping survey and finds the building (s) is no longer l there, a scoping survey should be performed on the available property. If an inspector is denied access to a property to perform a scoping survey, the inspector shallinform management, who will decide on a course of action on a case-by-case basis. Scoping i surveys may also be conducted at sites where sealed sources cannot be accounted for I through documented or verbal evidence. Inspectors should use professional judgment to determine whether the quantity and activity level of the radioactive materialin the sealed source (s) warrant performing a scoping survey. A sample scoping survey plan I is provided in Appendix A, including criteria for determining when remediation is required. Guidance on release criteria is provided in Appendix B. Inspectors may also use guidance in Inspection Procedure (IP) 83890 and other routine IPs, as appropriate. l If radioactive materialis found or if the site is too extensive to permit an inspector to reasonably eliminate the possibility of contamination, a detailed site survey should be performed. The former licensee or current site owner should be requested to conduct the detailed site survey whenever possible.
04.06 Inspectors should use guidance in IP 83890, " Closeout Inspection and Survey," and other routine inspection procedures as appropriate to monitor remediation activities.
Each region shall notify LLDP/NMSS promptly of any site found contaminated and discuss transfer of sites requiring long-term remediation to the SDMP or another remediation program. 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 decommissioning).
- b. There are settling ponds, burial sites, or large amounts of contaminated soil that will be difficult to decommission.
- c. There are contaminated 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.
Issue Date: 4/15/98 Tl 2800/026, Rev 1 4
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s 28U0/026-05 REPORTING REQUIREMENTS Each region shall document its findings, regarding the specific concerns identified by ORNL, for each site, in quarterly status reports to LLDP/NMSS. Regions thould provide the information shown in the example status report provided in Appendix C. LLDP will track each site referred l to the region and verify that it is closed out. In addition, each region shall send LLDP: (1) the l numbers and names of sites referred to the region for followup; (2) the numbers and names of sites eliminated from concern; (3) the numbers and names of sites found contaminated; (4) the I numbers and names of licenses pending a determination; and (5) the number and names of license files closed by Agreement States, if known. This information should be categorized by sites with scores above 300 and sites with scores below 300. This information is required quarterly for the " Quarterly information Status Report" (see Appendix D for guidance).
Inspections and confirmation surveys should be documented in inspection reports. All site l visits, whether for inspection or for other purposes, should be documented, including a l description of the site and any controls in place. Status reports and inspection reports shall be l l forwarded to the contact hsted in Section 08 of this temporary instruction (TI). Documents
- l. demonstrating that a site is suitable for unrestricted use shall be placed in the docket file for j that site and sent to the Division of Waste Mangement (DWM) contact.
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2800/026-06 COMPLETION SCHEDULE l
1 The completion schedule for followup inspections of formerly licensed sites will vary depending on the resources available and the number of sites requiring followup action.
2800/026-07 EXPlRATION j This Tl shall remain in effect until followup has been completed on all terminated license files identified as potentially contaminated.
2800/026-08 CONTACT l
Questions regarding this Tl should be addrassed to John Buckley, Project Manager for the l Review of Terminated Licenses, at (301) 415-6607. ;
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2800/026-09 STATISTICAL DATA REPORTING Staff hour expenditures or administrativo effort should be charged to Regulatory Information 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 IP element code (i.e., OA "Other Routine Activities,"
or OR "Other Reactive Activities"). Include Tl 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 Tl can be accounted for by site.
Issue Date: 4/15/98 Tl 2800/026, Rev 1 t ,
f e 4 Note: The docket number should be listed in the Licensing Tracking System l (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 M. Moriarty, at 301-415-7876, if assistance with LTS is required.
l 2800/026-10 ORIGINATING ORGANIZATION INFORMATION 10.01 Oraanizational Resoonsibilitv. The Operations Branch of the Division of Industrial and Medical Nuclear Safety (IMOB/NMSS) initiateo this Tl. DWM/LLDP prepared Revision l 1.
- 10.02 Resource Estimate. The estimated onsite inspection time necessary to interview
- personnel, check records, and perform an initial scoping survey is 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per site.
Actual inspections at a specific site may require substantially more or less time, I depending on the circumstances. With trip preparation, travel, and report preparation, the total time required is estimated to average 20 hnurs.
l 2800/026-11 APPENDICES Appendix A " Sample Scoping Survey Plan" Appendix B " Guidance on Release Criteria" Appendix C " Example Site Status Report" Appendix D " Input for Quarterly information Status Report" l l
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APPENDIX A SAMPLE SCOPING SURVEY PLAN l Licensee: Name Address City, State, Zip Code Current Owner: (if different from above)
License No : XXX-000 (Terminated)
- f. ketNo.: OX0-00000 (Terminated) losoection Dates: Month, Day, Year Insoector(s): Narre(s)
Puroose of Insoection: Describe (e.g., To perform a scoping survey to determine whether any radioactive contaminants exist on-site, and if necessary, determine the general extent of residual activity present on building surfaces and grounds, and adjacent off site areas.)
- 1. Determine radionuclide(s) used at the facility:
List isotopes.
1 A. Review file to determine use areas: '
Describe areas of use.
B. Interview previous or current employees: l Discuss as applicable.
1 II. Identify affected and unaffected areas:
Discuss generally.
A. Affected Areas (Areas that have the potential for contamination):
Define (e.g., labs, machine shops, storage areas, manufacturing areas, locker rooms, emission stacks, off-site areas adjacent to release points where material may have been deposited)
B. Potential Areas (Areas immediately adjacent to affected areas):
Define (e.g., loading docks, storage areas, hallways, roofs)
C. Unaffected Areas (All remaining areas not identified as affected or potentially affected): Define (e.g., offices, lobbies, bathrooms, parking lots)
Issue Date: 4/15/98 Tl 2800/026, Rev 1 A-1
o l Ill. Determine survey instruments and ef:iciency (see NUREG/CR-5849, " Manual for l . Cor) ducting Surveys in Support of Licent.e Termination"):
A. If only a few nuclides used, determine efficiency for all nuclides:
See Sample Instrumentation Worksheet.
l B. If numerous nuclides used -
- 1. Determine efficiency of predominately used radionuclides or
- 2. Determine efficiency based on nuclide present in analyzed samples. See Sample Instrumentation Worksheet.
i l C. List instruments to be used:
Complete before inspection.
l j IV. Burial Sites
, A. Determine if facility had on-site burials:
l Discuss (e.g., Based on a review of the docket file and discussicns with l
the former licensee, it was determined that there was no on-site burial.)
- 8. If the possibility of subsurface contamination or burials exist, what additional sampling l and surveying will be conducted?
Describe (e.g., Because it has been determined that on-site burial did j exist, ORISE has been contacted to perform surveys of this site.)
l C. Do groundwater monitoring wells exist?
I Discuss (e.g., Because It has been determined that some on site burial l took place, and on site groundwater sampling wells exist, water samples I
will be collected from these wells. In addition, the results of the analysis of previous samples from these wells will be obtained.)
i V. Other l
l A. Photograph site and adjacent areas:
Discuss (e.g., Photos will NOT be taken.)
VI. Survey ,
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A. Areas to be surveyed:
i Describe (e.g., Survey will include floors, drains, pipes, ducts, cracks, l lower 2 meters of walls, ventilation system to extent practicable, areas j adjacent to release points, and outside areas adjacent to buildings.)
Guidelines: i Affected areas - 100 percent walkover using 2-meter wide lanes. I I
Potential areas - E0 percent walkover using 2-meter wide lanes.
I Unaffected areas - 25 percent walkover using 2-meter wide lanes.
1 asue Date: 4/15/98 Tl 2800/026, Rev 1 !
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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 sample.)
D. Collection of soil / sediment samples.
Describe (e.g., Soll/ sediment samples will be collected from outside areas where unsealed licensed material was stored, from areas that were formerly settling ponds, at storm and/or sanitary drain outfalls, and in or at the edge of streams or lakes.)
E. Documentation:
See Survey Plan by Location.
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.)
Vll. Identification of Contamination:
A. Provide 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.)
- 8. 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 gamma 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 evaluction.)
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Vill. 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 exceeds the maximum release l guidelines, remediation is required.
1 See Sample Instrumentation Worksheet.
l l 2. Identifv wnples that exceed the average (over one square meter), but are less i l than ti.. maximum guideline criteria:
- Discuss. If activity is identified that exceeds the average release guideline, but is less that the maximum release guide;ne, the NUREG/CR-5849 area weighted formula will be used to determine the contamination level averaged over one square meter. If the area weighted average exceeds the average release guideline, remediation is required.
tiee Sample Instrumentation Worksheet.
I APPROVED BY Branch Chief Date !
Issue Date: 4/15/98 Tl 2800/026, Rev 1 1
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SURVEY PLAN BY LOCATION LOCATION 1 Area: Affected/ Potential / Unaffected Size: ????? m2 Use: Describe (e.g., U-235 and natural uranium. Uranium tetrafluoride-magnesium blend was pressed into briquettes using a 3,000 ton Farquharpress.)
Potential 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
- 4. collect samples of positive areas 2 to 3 times background OTHER LOCATIONS ON-SITE Repeat above (Location 1) as necessary.
Issue Date: 4/15/98 Tl 2800/026, Rev 1 A-5 s
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I SAMPLE INSTRUMENTATION WORKSHEET l
l Inspector:
l Date:
Inspection Location:
Inspection Date:
Isotopes of Interest:
Instrument- Type:
Serial #:
NRC #:
l l Probe:
Serial #:
l NRC #:
Calibration Date: l Size (S): cm 2
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Check Source: Isotope: Serial No.:
NRC Tag No.:
Half Life (Tw): years x 365 = days Date: Activity (A ): pCi x 2.2x108 = dpm Current Date minus Source Date (t): years or days Current Check Source Activity: A = A. x exp[-0.693t/Tw]
x exp[-0.693 x / 1= pCi or dpm Meter Reading with check Source (M): pCi (x 2.2x108 = cpm) cpm Efficiency (E): M/A = /
(x 100 = %)
Dackground (B): pCi (x 2.2x10' = cpm) Date:
cpm Location:
l Background (B): pCi (x 2.2x108 = cpm) Date:
cpm Location:
t Background (B): pCi (x 2.2x108 = cpm) Date:
cpm Location:
Issue Date: 4/15/98 Tl 2800/026. Rev 1 A-6
l SAMPLE INSTRUMENTATION WORKSHEET. continued Inspector: _
Date:
Maximum Release Criteria for Isotope of Interest (X): dpm/100 cm 2 (See Appendix B and the guidance in NUREG/CR-5849.)
Instrument Reading That Equals Maximum Release Criteria: {(X/100) x S x E} + B
={( /100) x x 1+ = cpm Averaae Release Criteria for isotope of Interest (X): dpm/100 cm 2 Instrument Reading That Equals Average Release Criteria: {(X/100) x S x E} + B
={( /100) x x 1+ = cpm Meter Source Checks q Check Source: Isotope: Serial No.: l NRC Tag No.:
Date Time Meter Reading _ Location l
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APPENDIX B I
Guidance on Release Criter;a l
l As stated in the SDMP Action 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 l documents:
- 1. Options 1 and i' of the Branch Technical Position, " Disposal or Onsite Storage of Thorium or Uranium Wastes from Past Operations" (46 FR 52061, October 23,1981).
l 2. " Guidelines for Decontamination of Facilities and Equipment Prior to Release for l 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 i Nuclear Safety, November 4,1983. (Editorial revision issued August 1987.)
- 3. " Termination of Operating Licenses for Nuclear Reactors," Regulatory Guide 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 l
, soil should be removed such that the exposure rate is less than 5 micro-roentgan per hour !
l above natural background at 1 meter, with an overall dose objective of 10 millirem per year l (cf. Letter to Stanford University from James R. Miller, Chief, Standardization and Special l Projects Branch, Division of Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear l Regulatory Commission, April 21,1982, Docket No. 50-141).
l 4. The Environmental Protection Agency's (EPA's)" interim Primary Drinking Water Standards," 40 CFR Part 141. In accordance with FC 83-23, the maximum contaminant i l levels for radionuclides in public drinking water, as established by EPA, should be used as reference standards for pro'ection of groundwater and surface water resources.
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S. EPA's " Radiation Dose Guidelines for Protection Against Transuranium Elements Present l in the Environment as a Result of Unplanned Contamination,"(42 FR 60956, November 30,1977). This document provides guidelines for acceptable levels of transuranium elements in soil.
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! NRC's " Radiological Cnteria for License Termination; Final Rule," (10 CFR Part 20, et al., July
( 21,1997) became effective on August 20,1997. However, licensees may defer implementation l of the rule until August 20,1998. After August 20,1998, the Regions should use the criteria l presented in this rule as the basis for releasing formerly licensed sites.
i Issue Date: 4/15/98 Tl 2800/026, Rev 1 B-1 i
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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* Max; mum Soil Concentration (pCi/gm)
Hydrogen-36 (no limit, see Table 2)
Cobalt-606 8 Strontium-90* 5 Cesium-137" 15 Plutonium-238/239" -'
Americium-241* --
Radium-226* 5 Radium-228' 5 Natural Thoriumd 10 Natural Uranium 8 10 Depleted Uranium 8 35 Enriched Uraniumd 30 Table 2. Acceptable Groundwater Contamination Levels"
- Radionuclide' Maximum Groundwater Concentration (pCi/ liter)
' If only one radionuclide is present. then the maximum concentration is the value listed in the table. However. If more than ene radionuclide is present, determir.e for each radionuclide the ratio between the measured concentration (in soil or groundwater) and the concentration listed in the table. The sum of the ratios may not exceed one (i.e., unity),
b Order Establishing Criteria and Schedule for Decommissioning the Bloomsburg PA Site (Safety Light Corporation). 57 FR 6136 February 20. 1992.
- 'l S. Environmental Protection Agency. Health and Environmental Protection Standards for Urantua and Thorium Mill Tailings. 40 CFR Part 192. Subparts B and E. July 1. 1991.
d Branch Technical Position. Disposal or Onsite Storage of Thorium or Uranium Wastes from Past Operations 46 FR 52061. October 23. 1981.
The values for Pu-238/239 and Am-241 provided in the Order are substantially higher than the values currently being proposed in NUREG-1500. Working Draft Regulatory Guide on Release Criteria. Consult IM08/NMSS and LLDP/NMSS if values are required.
Issue Date: 4/15/98 Tl 2800/026, Rev 1 B-2 L
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l Hydrogen-3 20,000 l -
Cobalt-60 100 i Strontium-90 8 l Cesium-137 200
! Gross alpha incl. Ra-226 15 l Ra-226/228 5 l
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, APPENDIX C Examole Site Status Reoort Docket no. License no.
Licensee Name:
Site Name:
l Site Address:
City: State: Zip:
1 Regional
Contact:
Phone: ]
Status Summary:
1 l
issue Date: 4/15/98 Tl 2800/026, Rev 1 l C-1 l l
APPENDIX D INPUT FOR QUARTERLY INFORMATION STATUS REPORT (QISR) l STATUS OF SITES IDENTIFIED BY ORNL Total Sites Eliminated Sites Pending Sites Contaminated
> 300 ,
5-300 Total in addition, the quarterly status reports should list, by name, the sites counted under " Sites l Eliminated."" Sites Pending," and " Sites Contaminated." Each of these lists should also delineate those sites with scores >300, and those with scores from 5 - 300.
STATUS OF LICENSES WITH SEALED SOURCES NOT ACCOUNTED FOR l Total Sites Eliminated Sites Pending !
! 1 i > 300 1
l 5-300 1
Total In addition, the quarterly status reports should list, by name, the sites counted under " Sites l l Eliminated," and " Sites Pending." Each of these lists should also delineate those sites with j scores >300, and those with scores from 5 - 300.
Issue Date: 4/15/98 Tl 2800/026, Rev 1 D-1 l
l I
EXHIBIT 1 DOCUMLNT ISSUING FORM To: Frank P. Gillesoie. Director From: John T. Greeves. Director Division of Inspection and Division of Waste Management, NMSS Support Programs, NRR
- 1. Number and title of document Temocrarv Instruction 2800/026. Revision 1
" Follow-uo Insoection of Fo,meriv-Licensed Sites identified As Potentially Contaminated'
- 2. Type of document 3. Type of action
_ Manual Chapter (MC) _ Inspection Procedure (IP) _New document
_ Appendix 2 Temporary Instruction (TI) 2 Revision
_ Technical Guidance _10 CFR Guidance _ Deletion 4.a. If a new IP is being prepared, state its need or purpose, whether it is for the " Core" inspection Program, the SALP category it applies to, the direct inspection hours needed to perform it, and the inspection frequency,
- b. If a Tl c.,r IP is being revised, state the reason for the revision, and if applicable, the l tosulting change in direct inspection hours or FTE, if any. I l
Core Program: _Yes _No SALP Category: DIE:
Inspection Frequency:
l Sta'ement: The TI reauired revision for the followina reasons: (1) the current version of the Tl exoired OIL1 2/31/97. (2) the coint of contac' identified in Section 2800/026-08 had to be chanced from Paul Goldbera to John Bucklev. and (3) to make the Tl ccnsistent with the Commission's positions exoressed in SECY 97-188. The resultina revisions vill result in a decrease in the direct insoectionhours reauired to close terminated Ik;ense files.
- c. For any proposed addition in direct inspection hours that results from a or b above, state the increase in proposed hours and identify where the proposed corresponding reduction in direct inspection hours is to occur (Note: the total " Core" hours is a 'ixed number and cannot be increased without permission from the NRR Office Director).
DIE increase resulting from 4a or 4b:
Proposed reduction, IP No.:
Issue Date: 09/27/95 E1-1 0040, Exhibit 1 ATTACHMENT 2 s
D Details of reduction:
- d. If new training requirements or the revision of current training requirements are needed as the result of the new IP, Tl or revision of existing procedures, these shou'd be identified. The group responsible for establishing and presenting the training should also be identified.
New training course required? Yes .d_No 1 Revision to existing training course? ._Yes l_No Lead Branch for establishing training:
Training to hs civen by:
I
! Orief description of proposed training:
l i
l l
l S. Proside a floppy disk with the file in the current version of Wordperfect and attach a hard copy of the document.
l
- a. Has document been reviewed by the technical editor? _X.Yes _No if not, state why
- 6. Special exhibits (anything that cannot be put in Wordperfect such as drawings, reductions, or block diagrams) are attached?
Yes _No 2_N/A
- 7. Attach a summary of comments and resolutions. State comment,its source, and if not adopted why. Is summary attached? X Yes _No _N/A 1
I 0040, Exhibit 1 E1-2 issue D.?.te: 09/27/95 1
i j
,s I -
l l
l l 8. All approval signatures must be obtained in the order listed below: Check items 1-7 above and l ensure all documents (floppy disk with file in Wordperfect & hard copy, special exhibits, comment summary and resolution, and any background information) are attached to this form before routing it for approvals.
O
- a. % C Lv Y $5 e.
j ri ipator/Date
[
- b. f.
driqinator dranch' Chief /Date PIPB, Branch Chief /Date
- c. Nf/ ( f F g.
[ Originator Division Dir./Date DISP, NRR, Director /Date d.
j PIPB, Manual Coord./Date l
- 9. Date received by PIPB 10. Change notice number and issue l Manual Coordinator date:
l
! END J
l l
Issue Date: 09/27/95 E1-3 0040, Exhibit 1
COMMENTS RECEIVED ON DRAFT TEMPORARY INSTRUCTION (TI) 2800/26, REV.1
- Comments were requested from Regions I,11, Ill, IV. Substantial comments were received j
only from R IV.
l l
l Comment 1: For the most part, the proposed Tl is a re-issue of the original TI. It does not l
recognize the previous Tl or attempt to include any changes that may be appropriate from ,
J experiences with the original Tl. It is suggested that a conference call between the regions and HQ be held to discuss experiences with the original Tl and what, if anything, needs to be amended.
l Response: The staff agrees with the comment. Section 3.03 was revised to remove requirement to contact local authorities. The staff discussed experiences implementing the TI )
with Rlli and RIV inspectors as requested. As a result, Section 4.05 of the Tl was revised to provide guidance on what to do if access to a site is deni'sd by the current owner.
l Comment 2: Since this Tl will likely be the same guidance that agreement states will be asked l to follow, its contents, expectations, and acceptability from an agreement state perspective need to be considered. Many agreement states are very annoyed at receiving the terminated j license files and considerations of their perspective is essential in issuing the guidance for reviewing the files.
l Response: The staff agrees with the comment. The Agreement State concerns are reflected in i the guidance I Comnient 3: RIV had recently requested some specific' guidance on closure of sealed source l licenses when review and research failed to yield results. The only guidance the Ti appears to I have provided is the statement that " Scoping surveys should also be conducted at sites where l sealed sources cannot be accounted for." This guidance is not adequate, in many cases i surveying to look for a sealed source is not practical. could consume enormous resources, and l equates to looking for a needle in a haystack. The following exanples illustrate the problem:
I
- a. In one case, the only inforrnation we have is that the source was used at the l University of Hawaii (UofH). UofH has over 100 buildings spreari out over l 12-15 different locations state wide.
- b. In another case, multiple site locations were authorized. We would have to visit l each location. l l
- c. In another case, the source was for use at temporary job sites and was stored in a vehicle.
1 1
Attachment 3
In any event, sealed sources would have been shielded and the likelihood of finding one by a survey is extremely small especially where large and/or multiple facilities exist. We believe other factors should be developed to guide the regions on appropriate action.
For example:
- a. An allowance for decay, with some risk assessment related to a dose potential from a realistic likelihood of exposure.
- b. An allowance for the complexity of the survey search; i.e., any effort expected to expend greater than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> would not occur unless an extreme risk is perceived.
- c. An explicit recognition that in many cases it simply isn't possible to reconstruct what happened to a piece of equipment 30 to 40 years ago and it is not in the public interest to expend excessive resources that are unlikely t. yield a positive result. (NOTE: an overall level of priority to the terminated license program is reflected by the extremely smalllevel of resources budgeted to the program:
0.1 FTE in FY 98 for RIV.)
Pesponse: The staff agrees with the comment. The Tl was revised to indicate that inspectors could close out sealed source license files based on verbal evidence, in addition, Section 4.05 was revised to indicate that inspectors should use professionaljudgement to determine when a site visit is required to close out a sealed source license file.
Comment 4: Section 03.01 states that sites located in agreement states should be referred to the state. The Tl needs to recognize and address federallicenses in agreement states. These would be retained by NRC.
R6sponse: The staff agrees with the comment. Sections 02 and 03 were revised to indicte that the responsibility for closing out federal license files for sites located in Agreement States will remain with NRC.
Comment 5: The Tl loosely uses the term site. The Tl needs to be more definitive and distinguished between the term license and site. For example, we do not refer a site to an agreement state, we refer a license.
Response: The staff agrees with the comment. The Tl was revised to consistently use the terms " site" and " license".
Comment 6: To be consistent with the inspection procedure format, Section 03 should be identified as " Inspection Requirements" rather than " Region Responsibilities." Also, the i guidance of Section 04 should track the requirements of Section 03; i.e., paragraph 01 in ;
Section 04 should provide guidance for paragraph 01 of Section 03, etc. As written, there ia no l correlation.
i o
3-Response: The staff agrees with the comment. The title of Section 03 was changed as requested.
Comment 7: Section 03.07 states to monitor the cleanup activities for short-term remedial actions. Although this requirement is essentially as stated in the original TI, it appears to be the subject of another Tl due to the issues involved in remediation, for example, there are licensing requirements, decommissioning plan considerations, legal challenges, and other complexities that would justify a Tl in itself. The guidance of Section 04.04 should also be in a separate Tl.
Response: The staff believes that the guidance presented in Sections 03.07 and 04.04 is of the proper scope to be included in this Tl. If the Regions believe that additional guidance is needed ,
in these areas, Technical Assistance Requests should be submitted to Headquarters for !
evaluation.
Comment 8: Section 05 requires monthly status reports. This is too freque.it and puts an excessive administrative burden upon the regions. Reports should be quarterly.
Response: The staff agrees with the comment. The Tl was revised to require quarterly reports.
Comment 9: Section 06 states that, in general, the initial inspections of each site requiring a site visit should be completed within 9 months of receiving the docket file. Since most files have already beer, transferred to the regions, it will likely not oe possible to accomplish this. It .
is suggested that his requirement be deleted.
t Response: The staff agrees with tne comment. The requirement for completing an initial (
inspection at the site within 9 months of receiving the file has been deleted.
Comment 10: The Tl is schnuled to expire on December 1,19 'B. It is unlikely that RIV will complete this project by December 1,1998. It is suggested this date be changed to December 1,1999.
Response: The staff agrees with the comment. The expiration date of the Tl was revised. The Tl will now expires when all license files have been closed.
Comment 11: Section 03.01 states that the States will be expected to notify NRC when the license file is closed. Will the States be notifying the regions, and if so, what ongoing ,
responsibilities will the regions have relatiu to licenses referred to the states? Will the Office of l State Programs by involved?
Response: The :,taff agrees with the comment. Section 4.01 of the Tl was revised to request I that the States notify NRC when, and how, a license file is closed. Regions are instructed to I transmit this information to the point of contact listed in Section 08.
MEMORANDUM TO: Frank P. Gillespie, Director Division of Inspection and Support Programs, NRR FROM: John T. Greeves, Director Division of Waste Management, NMSS I
SUBJECT:
DWM REVIEW OF TEMPORARY INSTRUCTION 2800/026 I By memorandum dated March 14,1997, Don Cool, Director, Division of industrial and Medical Nuclear Safety, NMSS, requested that DWM review and revise, as cessary, Temporary Instruction (TI) 2800/026, " Follow up Inspection of Formerly Lice ed Sites identified as Potentially Contaminated." Further, he requested that DWM f ard the revised Tl to Gerry Klingler, of your inspection Program Branch.
Attached are copies of the revised Tl (with floppy disk , the Document issuing Form, and the comment resolution package. DWM's revisions are' consistent with the Commission's positions expressed in SECY 97-188, "Formerly License $ites identified for Further Investigation in Agreement States."
If you have any questions regarding the ontents of the TI, please refer to the contact listed I below.
Attachments: As stated CONTACT: John Buckley, DhVM (301) 415-6607 TICKET: DWM-093 DISTRIBUTION: Central File DWM r/f DWM t/f LLDP r/f NMSS r/f MFed:Irline TJohnson CPoland RNelson DCool PGoldberg RJohnson PUBLIC DOCUMENT NAME:s:\dwm\lldp\jtb\dwm- isee previous concurrence r OFC DWM r, n DWM DM E T ED DWM NAME JBuckley/cvkih LBer JhIy EKraus+ JGreeves DATE i / L/98 / /98 [/ 7/98 / /98 / ,
/98 OFFICIAL ' RECORD COPY LSS: YES _ NO 2 ACNW: YES _ NO 2 IG: YES _ NO 2 Delete file after distribution: Yes 1 No _
PDR: YES .A_ NO ._
k
l I
i . MEMORANDUM TO: Frank P. Gillespie, Director j l Division of Inspection and I Support Programs, NRR FROM: John T. Greeves, Director I Division of Waste Management, NMSS
SUBJECT:
DWM REVIEW OF TEMPORARY INSTRUCTION 2800/02 l By memorandum dated March 14,1997, Don Cool, Director, Division of Ind' trial and Medical J Nuclear Safety, NMSS, requested that DWM review and revise, as nece ary, Temporary )
Instruction (TI) 2800/026, " Follow up Inspection of Formerly Licensed ites identified as l Potentially Contaminated." Further, he requested that DWM forwa the revised Tl to Gerry Klingler, of your inspection Program Branch.
Attached is a copy of the revised Ti. DWM's revisions are onsistent with the Commission's positions expressed in SECY 97-188, "Formerly Licens Sites identified for Further Investigation in Agreement States." Further, this revyi ['on incorporates the release criteria of the
" Radiological Criteria for License Termination; FinafRule," became effective on August 20, l 1997. However, licensees may defer impleme ion of the rule until August 20,1998. The Tl instructs the Regions to evaluate sites to det ine if radioactive materials are present in I excess of: (1) the criteria identified in NR ' Action Plan to Ensure Timely Remediation of l Sites Listed in the Site Decommissioning anagement Plan"; or, (2) the criteria in the Radiological Criteria for License Termi tion Rule. Prior to August 20,1998, remediation will be required only if a site fails to mee e criteria of 1 and 2 above. After August 20,1998, sites must meet the criteria in the Radio gical Criteria for License Termination Rule.
l l If you have any questions reg ding the contents of the TI, please refer to the contact listed l belcw. j l
Attachment:
As stated 1
i CONTACT: John B ley, DWM ,
(301) 5-6607 I TICKET: DWM-09 '
DISTRIBUTION: Ce ral File DWM r/f DWM t/f LLDP r/f NMSS r/f l MFederline T ohnson CPoland RNelson DCool PGoldberg RJohnson UBLIC DOCUMENT NA , :s:\dwm\lldp\jtb\dwm-093 f FC Dh DWM , DWM DWM NAME Jduckley/cv LBelh JHickey JGreeves DATE I7./IO/97 lk/I497 / /97 / /97 //
/ OFFICIAL RECORD COPY LSS: YES _ NO 2 ACNW: YES _ NO 2 IG: YES _ NO 2 Delete file after distribution: Yes 2 No _
PDR: YES.L.NO _