ML20237J188
| ML20237J188 | |
| Person / Time | |
|---|---|
| Issue date: | 08/20/1987 |
| From: | Rubenstein L Office of Nuclear Reactor Regulation |
| To: | Bosnak R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| NUDOCS 8708260060 | |
| Download: ML20237J188 (4) | |
Text
_ _ _
August 20, 1987 MEMORANDUM FOR:
R. J. Bosnak, Deputy Director Division of Engineering Office of Nuclear Regulatory Research FROM:
Lester S. Rubenstein, Director Standardization and Non-Power Reactor Project Directorate
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Division of Reactor Projects III, IV, Y and Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
REVIEW 0F FINAL GENERIC EIS ON DECOMMISSIONING OF NUCLEAR FACILITIES i
In response to your request of July 15, 1987, Mr. Erickson of my staff hr i
reviewed and obtained comments on subject EIS from RPB, CEB and PDTSB. We have summarized our mejor comments and those from the above branches in Enclosure No. 1.
We are also providing our marginal comments and those from the above branches in Enclosures 2, 3, 4 and 5.
The summary comments in Enclosure No. I center on radiation levels for release to unrestricted access and the need to recognize a reduction in waste volume by delaying DECON for 50 years.
The NRR comments concentrate on those chapters related to reactor decommissioning.
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WASHINGTON, D. c. 20555 August 20, 1987 MEMORANDUM FOR:
R. J. Bosnak, Deputy Director Division of Engineering Office of Nuclear Regulatory Research FROM:
Lester S. Rubenstein, Director
' Standardization and Non-Power Reactor Project Directorate Division of Reactor Projects III, IV, Y and-Special Projects Office of Nuclear Reactor Regulation
SUBJECT:
REVIEW 0F FINAL GENERIC EIS ON DECOMMISSIONING OF NUCLEAR FACILITIES In response to your request of July 15, 1987, Mr. Erickson of my staff has reviewed and obtained comments on subject EIS from RPB, CEB and PDTSB. We have sumarized our major comments and those from the above branches in Enclosure No. 1.
We ara also providing our marginal comments and those from the above branches in~ Enclosures 2, 3, 4 and S.
The summary coments in Enclosure No. I center on radiation levels for release to unrestricted access and the need to recognize a reduction in waste volume by delaying DECON for 50 years.
j The NRR comments concentrate on those chapters related to reactor j
decommissioning.
1 i'
h.
Lester S.
ub nstein. Director Standardization and Non-Power 1
Reactor Project Directorate j
Division of Reactor Projects III, IV, 1
d V and Special Projects Office of Nuclear Reactor Regulation
Enclosures:
As stated CONTACT:
l P. Erickson NRR/PDSNP Ext. 28280 l
1
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Enclosure No. 1 2
l COMMENTS ON FINAL GENERIC EIS ON DECOMMISSIONING
,l Pages 5 and 6, " Residual Radioactivity Levels For Reactors." The NRC uses Regulatory Guide 1.86 for surface contamination as stated.
In addition, we use 5 microrem/hr above background as measured at one meter for direct radiation measurements. This guidance for direct radiation, as stated in our letters to Stanford University (Referenced in Final GEIS Appendix A, Item 4.1),
should be included in detail.
If possible, an approxima).e schedule should be provided for EPA development of federal requirements on residual radioactivity. Also, the NRC action to develope an interim policy on residual radioactivity should be discussed.
Page 2-12 Section 2.4.3, the advantages of SAFSTOR are discussed. One important advantage should be added. During the 30 to 50 year SAFSTOR period, advances in decommissioning technology should significantly improve the effectiveness of eventual dismantlement resulting in improved safety, reduced occupational exposures, and increased economy. This benefit should also be included in Section 15.1.1.
Pages 2-17 and 2-18. The Final GEIS states that the costs are approximately j
the >me for reducing the residual radioactivity to 25 mrem per year, 5 mrem J
pu f ar or 1 mrem per year. This is not likely.
For example, concrete can be scanfied or scabbed to remove the top layer so that the residual level is 25
{
mrem / year. However, to reduce residual levels to 5 mrem / year or 1 mrem /yr, much more of the concrete must be removed at a substantial cost increase.
j Also, the lowest value that can be determined with an acceptable level of confidence is around 10 mrem / year.
10 mrem / year is also consistent with our present practice in terminating reactor licenses following DECON.
Pages 4-12, first paragraph. The cost comparison for DECON vs SAFSTOR is presented without considering the cost of money. The cost of future dollars for final DECON at the end of a SAFSTOR period discounted to the time of shut-down would show a higher cost for immediate DECON than DECON that is delayed 30 or 50 years. Thus, the SAFSTOR alternative may be the least expensive alternative if future dollars are properly discounted to present day cost.
Page 4-12, second paragraph. The Battelle reports and page 4-20 of the Final GEIS indicate reduction in waste volume by a factor of ten in fifty years.
This is a significant fact in view of the problems with space and cost for low level waste disposal. This potential waste volume reduction should be discussed in the Final CEIS.
Pages 4-17 and 5-17.
It would be helpful for tables 4.3-4 and 5.3-4 to have summary totals of cost and man-rem exposure levels for the three stages of the SAFSTOR process.
)
i i
c i Page 443, Footnote b of table 4.4-2 is garbled and thus does not correspond j
to footu e a cf table 5.4-2.
.~
Page 4-25, item 4.5.
Again, the potential benefit of waste reduction by waiting 50 years should be discussed when comparing decommissioning alternatives.
Pages 5-11 and 12. We have the same comments on the discussion of a BWR as on page 4-12 above (PWR).
Page S-24, item 5.5.
We have the same coment as for page 4-12 above.
Page 7-12.
The waste volume information in the top paragraph should be presented in a table.
Tables 8.3-1 and 8.3-2.
The chapter should clarify why it addresses both reference PWR's and EWR's after accidents but only lists PWR's in the tables.
Page 8-18. Reference 1 is confusing.
If this refers to NUREG-CR-2601, the title is incorrect.
If the title is correct, why isn't NUREG/CR-2601 referenced since it discusses both BWR's and PWR's?
Page 9-18.
The chart is too cryptic and needs appropriate labeling.
Page 11-11. Table 11.4-1 provides estimated lost-time injuries and fatalities for various decommissioning activities. This information is given only for decommissioning a reference UF6 conversion plant and is thus inconsistent with the treatment of other facilities. Similarly, a paragraph on non-radiological safety is included in chapter 12 for the uranium fuel fabrication plant but similar information is not included for other facilities.
Is there a reason for providing such information for some types of plant but not others?
Chapter 15. This chapter repeats too much of the discussion of earlier chapters and should be edited down.
In the same vein, is it really necessary to repeat the definitions for DECON, SAFSTOR, and ENTOMB in each of the facility-specific chapters? The report would be more concise and readable if repetition could be eliminated wherever possible.
The report needs very careful editing. The heavy reliance on references means that the reader needs to have confidence in the authors.
It is hard to maintain confidence after encountering Table 4.3-4, which says that DECON of Ginna would result in 1097 person-rems while DECON of Turkey Point and Trojan combined would result in less than three person-rems. Not only are some of the magnitudes wrong, the units are improper and the four digit precision is not indicative of the uncertainties in the estimate.
Appendix A, page 22. There is no discussion of comment 3.
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