ML20247B010
| ML20247B010 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1998 |
| From: | Garrick B Advisory Committee on Reactor Safeguards |
| To: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20247A990 | List: |
| References | |
| FACA, NACNUCLE-R-0133, NACNUCLE-R-133, NUDOCS 9805070100 | |
| Download: ML20247B010 (3) | |
Text
ACNWR-0133
/ %, UNITED STATES f g NUCLEAR REGULATORY COMMISSION g r ADVISORY COMMITTEE ON NUCLEAR WASTE
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WASHINGTON, D.C. 20666 g
April 29.1998 ^
The Honorable Shirley Ann Jackson Chairman U.S. Nuclear Regulatory Commission Washington. DC 20555-0001
SUBJECT:
COMMENTS AND RECOMMENDATIONS ON INTERIM GUIDANCE IN SUPPORT OF THE FINAL RULE ON RADI0l'EICAL CRITERIA FOR LICENSE TERMINATION
Dear Chairman Jackson:
Durinc its 99th meeting on March 23-25. 1998, the ACNW heard and discussed a presentation by the Office of Nuclear Regulatory Research on NRC's final rule and regulatory guidance for demonstrating compliance with the radiological criteria for license termination.
The issue of license termination is complex because of the very broad spectrum of licensees and sites. In many cases, such as cealed-source sites. license
' termination is simple. In other cases, license termination can be granted only.with restrictions and financial guarantees. In a few other cases, j license termination may not be granted under any circumstances because of the i magnitude or extent of contamination.
l In the case of a simple license termination, there is no need to use dose- j based models to demonstrate compliance with the final rule. For the more i complex sites, it is appropriate to start the process of decommissioning using a dose-based screening model and to progress to a more detailed site-specific !
analysis as necessary.
l' In this letter. the ACNW has focused on the more complex sites requiring dose- l based models. The much broader task of addressing the whole gacut of types of i' license terminations, especially those cases involving uranium and thorium.
will be addressed in a future letter. f p
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'To gain' insight on the practical application of the new approach, the Committee supports the decision.to introduce the new screening tool and decision methodology and to issue the documents immediately on an interim i basis for 2 years. The Committee considers the new approach using the DandD compu'ter code to be consistent with the trend toward introduction of a risk-informed, performance-based (RIPB) philosophy in essentially all NRC
, . licensing.
The new approach allows licensees to use a simple generic approach for low-risk sites or to use increasingly more realistic and site-specific analyses.
'iteratively as needed, to demonstrate compliance. . The licensee can assess the relative cost and benefits of continuing with addicional data collection, or remediating specific areas in order to achieve compliance.
Although the ACNW has not investigated all potential sources of conservatism s
'in the new DandD. code, we are persuaded that it is not inherently over-conservative as a screening tool. Introduction of regional parameters rather
, than a single set of national parameters could reduce conservatism. The 2-
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year trial period recommended above will allow these and similar concerns to be carefully evaluated.
There are several issues concerning the new approach in its current form that i can and should be addressed. In particular:
- 1. The regulatory guidance documentation is formidable and likely to deter even the most motivated of licensees from using and gaining familiarity with it. The Committee urges that the staff repackage the guidance in a more user friendly, . menu-driven electronic format that includes guidance to licensees on additional relevant NUREGs.
- 2. The approach outlined in the guidance for implementing the as low as reasonably achievable (ALARA) requirement may lead to unnecessary conservatism when using the DandD screening model.
The Committee believes that if a licensee complies with the 25 mrem dose criterion'using the screening methodology, the licensee will have met the intended ALARA requirement. (The'. dose calculated using site-specific analyses is expected to be lower in L
most cases).
- 3. NRC should retain the flexibility to adjust the new DandD model if additional studies invalidate the linear no-threshold dose response hypothesis.
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i 4. Introduction of the new decontamination and decommissioning approach will require significant resources during the 2-year L . , trial period for field testing, training, evaluation, and guidance '!
l development. In particular, the ACNW encourages NMSS to follow-through with its plans to test the DandD code on a complex site.
A strong commitment and adequate resources are needed if NRC is to move forward with RIPB regulation. l I
l The problem of dual regulation, that is, by the Environmental Protection Agency and by NRC, was raised by representatives of the Nuclear Energy ,
Institute during the meeting. This is a serious issue that needs to be resolved. The ACNW believes that by introducing the RIPB approach to license !
termination. the new methodology could assist in alleviating the conflicts i associated with dual regulations as it should lead to more defensible and !!
consistent regulatory decisions. II The ACNW plans to become more familiar with the DandD code and the license termination process. during the next 2 years of testing and will keep the Commission ~ informed of any significant developments.
L Sincerely, L _
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[ g L l F B. John Garrick Chairman L
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