ML20217G794
| ML20217G794 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/1997 |
| From: | Brummett E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| References | |
| NUDOCS 9804290210 | |
| Download: ML20217G794 (3) | |
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Waste Mar,agement '97 Workshop "How Clean Is Clean" Tucson, Arizona, March 1, 1997 PROMULGATING DEFENSIBLE DECOMMISSIONING REGULATIONS Elaine S. Brummett U.S. Nuclear Regulatory Commission INTRODUCTION At WM'97, on Monday afternoon (session 9), I will be speaking about the U.S.
Nuclear Regulatory Commission (NRC) inspection and licensing programs activities concerning decommissioning uranium mill sites. At that time, I will give specific examples of developing and applying soil cleanup criteria for Ra-226 and Th-230 under specific circumstances.
For this workshop I want to address the status of the NRC decomissioning rule.
Last year at this workshop, Margaret Federline from the NRC, Division of Waste Management, spoke about our decommissioning standards nearing the final hurdle.
She outlined the proposed decommissioning rule that was published on August 22, 1994, summarized the resulting public comments, and indicated that the final rule and interim implementing guidan'ce should be available during 1996.
As you may know, there has been continued discussions and work on the rule and the revised target date is spring of 1997. My following remarks are excerpts from a speech by Dr. Shirley Ann Jackson, Chairman of the U.S. Nuclear Regulatory Commission, to the Third Annual Nuclear Decommissioning Decisionmakers' Forum on December 10, 1996.
In that speech, Dr. Jackson reviewed development of the proposed rule and indicated her views concerning the final NRC decommissioning rule.
DECOMMISSIONING CLEANUP STANDARDS An important aspect of any successful regulatory program, is having fair, consistent, and cohesive regulatory requirements. The Commission put into place general requirements for decommissioning in 1988.
These regulations i
addressed many of the aspects of decommissioning a nuclear facility, including planning requirements, timing, assurance of the availability of adequate funds, and environmental review requirements.
But, one area that our 1988 regulations did not address was the acceptable levels of residual radioactivity for decommissioned facilities (except for uranium and thorium mill sites with soil radium levels set by the U.S. Environmental Protection Agency in 1983).
As a result, the NRC initiated a rulemaking in 1992 to establish appropriate radiological criteria for decommissioning. Over a j
two-year period, the NRC conducted a series of workshops and meetings across i
the country to discuss the scope, issues, and alternative approaches to the rulemaking.
The discussions involved a broad cross-section of interested entities and individuals, including other Federal agencies. The workshop and scoping discussions were used in the preparation of the proposed rule on radiological criteria for license termination that was published in c
j August 1994 (59 FR 43200).
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O Since the publication of the proposed rule, the NRC has conducted additional public workshops on the implementation of a dose-based standard for decomissioned sites, and on public participation in planning and conducting decomissioning.
As a result, the NRC has received thousands of comments on the subject.
Having completed its analysis of these coments, the NRC staff plans to submit a final rule to the Comission for its consideration in the near future.
i In formulating and promulgating its final rule on radiological criteria for i
license termination, the Comission will give particular consideration to:
(1) an all-pathways dose criterion in the range of 15 to 30 mrem per year; (2) inclusion of specific alternative criteria for certain facilities; (3) elimination of a separate groundwater standard; (4) the appropriate application of ALARA based on the dose criteria selected in the final rule; (5) a greater reliance on institutional controls; and (6) the appropriate value of the maximum dose limit permitted if restrictions should fail.
With regard to the inclusion of a separate groundwater standard in the NRC's final rule, at this point, the Commission is reluctant to include such a requirement, based on current information, because a separate groundwater standard has not been justified on either a technical basis or a cost-benefit basis. Also, the Commission believes that adequate protection of the public can be provided by the establishment of an all-pathways dose criterion that limits the amount of radiation a person potentially can receive from all i
possible sources at a decomissioned site, including doses received from drinking water obtained from groundwater.
Based on information and data currently available to the Commission, a separate groundwater standard appears to have minimal additional safety benefit compared to an all-pathways dose criterion.
Furthermore, the costs associated with this minimal benefit appear to be unreasonably large.
The Commission believes that compliance with an appropriate all-pathways standard would satisfy the Atomic Energy Act requirement to protect public health and safety.
RESULT OF NRC'S STRATEGIC ASSESSMENT The Strategic Assessment and Rebaselining of all of the NRC's activities has taken many hours over the past year.
This effort identified that two of the sixteen issues having the greatest importance to NRC's mission are related to decomissioning activities.
For both of these direction-setting issues (one on reactor decomissioning and a second on nuclear materials facility decommissioning), the Commission is looking for new and innovative approaches that will improve the efficiency and effectiveness of site and facility decommissioning.
For example, with respect to the decommissioning of non-reactor facilities, the Commission's preliminary views were that a variety 2
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of options should be pursued by the NRC that would place appropriate responsibility on licensees to remediate their sites while giving NRC the appropriate tools to deal with problem sites and licensees.
The Commission is also looking at the possibility of implementing a performance-oriented decommissioning review process that provides only residual contamination goals for decommissioning, and allows the licensee to proceed with decommissioning without obtaining prior NRC approval of a decommissioning plan.
The preliminary view of the Commission is that such a process should be tested on a pilot scale for a few selected materials licensees to determine the potential success and effectiveness of this approach.
Based on the results of this pilot program, the Commission could consider, at a later date, whether this approach to decommissioning should be adopted on a broader scale.
The preliminary views of the Commission also favor the possibility of transferring sites that pose little risk, and where little progress is being made toward ultimate site decommissioning, to EPA's Superfund Program.
The Commission would have the NRC staff conduct a risk-informed performance-based assessment to determine those sites that fall into the low-risk category.
CONCLUSION It is critical that the nuclear industry and the regulatory authorities assure the public that the nuclear facilities can not only be constructed and operated safely, but that those same facilities can be decommissioned in a manner that protects public health and safety.
NRC staff realize that the final rule on decommissioning criteria will not please everyone, but it will provide assurance of adequate protection, with enough flexibility to allow cost effective remediation of contaminated sites.
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