ML20217H737

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Requests Support in Responding to Staff Requirements Memo Associated w/DSI-24 Re Power Reactor Decommissioning.Info Requested Before 971010
ML20217H737
Person / Time
Issue date: 08/22/1997
From: Mendonca M
NRC (Affiliation Not Assigned)
To: Jim Hickey
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20217H730 List:
References
REF-WM-3 DSI-24, NUDOCS 9710170046
Download: ML20217H737 (2)


Text

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August 22, 1997 MEMORANDUM TO:

John W. Hickey, Chief Low Level Waste and Decommissioning Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguards A'

FROM:

Marvin Mendonca, Acting Director Non Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUBJECT:

SUPPORT FO!1 RESPONSE TO COMMISSION REGARDING DSI 24, POWER REACTOR DECOMMISSIONING We request your support in responding to the Staff Requirements Memorandum associated with DSI 24, Power Reactor Decommissioning (attached).

The attachment contains the subject requested scope of work, We request that you provide this information before October 10,1997, so that NRR may adhere to the Commission's schedule. We appreciate your support in this matter. If you need any further clarification of this request, you may contact Singh Bajwa at 4151013 or Tony Markley at 415 3165.

Attachments:

1. Scope of Work
2. SRM, dated April 3,1997 cc: T. Johnson, NMSS 4

9710170046 971011 PDR WASTE WM-3 PDR

4 Office of hiuclear Material Safety and Safe 0uards Scope of Work:

SUPPORT FOR RESPONSE TO COMMISSION REGARDING DSI 24, POWER REACTOR DECOMMISSIONING

=

Requirement:

The Commission requested the staff to " consider public comments received suggesting improvements in existing practices and rulemakings. These should include... data available (e.g., survey costs) from recent decornmissionings, and implementing radiological assessments coincident with licensee's efforts." The Commission also requested that the staff " consider innovative regulatory approaches to decommissioning.... Options that the staff should consider include:

taking a performance based approach by only performing a radiological assessment of the site when it is ready to be released..."

Discussion:

We understand that your staff has significant experience with this subject and would appreciite your input and perspective in responding to the Commission request.

Information Requested:

Provide an historical background discussion of the NMSS efforts to address the decommissioning and radiological release survey issues. Describe the nature of contracted efforts and efforts coordinated with other government agencies, laboratories, etc., to address these issues. Discuss documents produced and consensus achieved. Provide o,erview discussions of MARSSIM (NUREG 1575) and the nonparametric survey methodology discussed in draft NUREG 1505 and their applicability to decommissioning and radiological release surveys. Discuss views on the acceptability of these survey methodologies and provide an analysis of potential resouice savings over current radiological release survey methods. Finelly, discuss the time line for implementation of new survey methodologies.

Discuss any other initiatives and operational practices, with respect in decommissioning and radiological release sur"eys, that reduces the NRC and licensee resource burdens while providirig an equivalent level of safety.

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We appreciate your support and would also appreciate any thoughts, ideas, or innovative approaches that you m::y have for improving the decommissioning regulatory program.

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[ ameer 4 UMTED STATES 4!

'i NUCLEAR RECULATORY COMMISSION wasHmotow.o c. enswooi

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t April 3, 1997 M Cmffamy MEMORANDUM TO:

L. Joseph callan Exe ti Direc for Operations FROM:

John Hoy e Secretary

SUBJECT:

S FF REQUIREMENTS - COMSECY-96-068 STRATEGIC ASSESSMENT ISSUE PAPER:

DECOMMISSICAING - POWER REACTORS (DSI 24)

The Commission supports-achieving finality in decommissioning

-requirements as soon as practicable.

As the industry moves to a

-deregulated environment, decommissioning implementation costs be understood and properly factored into planning decisions must and/or rate recovery mechanisms.

To this end, the Commission approves Option 2, pursue current direction and approaches more aggressively, for Decommissioning - Power Reactors (DSI 24) as the Final Commission View subject to the following comments.

The staff should address the issue of financial assurance for decommissioning.

The staff should also address the issue of site specific decommissioning cost estimates by providing a rulemaking plan for Commission consideration.

(EDO)

(SECY duspense:

4/30/97)

The staff should accelerate-resolution of decommissioning rulemaking issues and consider the option of combining several rulemakings into a single rulemaking, or a few integrated rulemakings, if prac*icable.

Risi-informed performance-based approaches to these rulemakings should be used only to the extent that the staff is ready to proceed with such an approach now.

The' Commission is currently considering the issues of the radiological criteria for decommissioning in SECY-97-046 and the interim storage of greater-than-class-C waste in SECY-97-056.

The staff should consider the public comments received suggesting improvements in existing practices and rulemakings.

These should include lessons-learned (e.g. packaging and transport), data available (e.g.,

survey costs) from recent decommissionings, and implementing radiological assessments coincident with the licensee's efforts.

To the extent that it does not compromise public health and safety, or delay the staff's completion of accelerated

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6 rolemaking, the staff should consider innovative regulatory approaches to decommissioning.

Particular approaches to consider are those which can accelerate decommissioning in a safe manner, but with appropriate NRC oversight at critical stages in the process._ Options the staff should consider include:

taking a performance-based approach by enly performing a radiological assessment of the site when it is ready to be released; placing an inspector onsite during specific phases of decommissioning (e.g. during active dismantlement); and, centralizing reactor decommissioning inspection programs in headquarters.

(EDO)

(SECY Suspense:

12/31/97)

The staff should provide the Commission with an analysis of whether or not the staff-views entombment as a viable decommi sioning option and how this option has been dealt wita previously by the Commission.

If the staff concludes that it is i

not a' viable option, the staff should describe the technical requirements and regulatory actions v..ch would be necessary for entombment to be a viable decommissioning option.

The staff analysis should include the resources involved, potential decommissioning cost savings, and vulnerabilities.

(EDO)

(SECY Suspense:

9/2/97) cc:

Chairman Jackson Commissioner Rogers Commissioner Dicus Commissioner McGaffigan Commissioner Diaz K.

Cyr (OGC)

D. Rathbun (OCA)

H. Bell (OIG)

A. Galante (CIO)

R. Scroggins (CFO) a

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