ML20248E297
| ML20248E297 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/1989 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| References | |
| TASK-DG-1006, TASK-DG1006, TASK-RE REGGD-01.XXX, REGGD-1.XXX, NUDOCS 8910050146 | |
| Download: ML20248E297 (11) | |
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t U.S. NUCLEAR REGULATORY COMMISSION September 1989 j..
OFFICE OF NUCLEAR REGULATORY RESEARCH Division 1 i
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Task DG-1006 J
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DRAFT REGULATORY GUIDE
Contact:
C. Feldman (301) 492-3883 RECORDS IMPORTANT FOR DECOMMISSIONING OF NUCLEAR REACTORS I
A.
INTRODUCTION
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The general requirements for applications for license termination and v
eu decommissioning *ofnuclearreactorsarecontainedin10CFR4Part50f" Domestic licensing of Production and Utilization Facilities." On J0ne127jr1988, the NRC amendeditsregulationsin10CFRPart50concerningspecifiDc,riteriafordecom-y
,p missioning nuclear facilities (53 FR 24018).
Amended paragraph 50.75(g) requires s
wa licensees to keep records of information important totsafe-and effective decom-e missioninginanidentifiedlocationuntilthelicense3s>terminatedbytheNRC.
g%gss This section of the rule also identifies the kinds 36flinformation the NRC e
y considers important to decommissioning.
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- 7(v ThisdraftregulatoryguidehasbeendeveIopMinconjunctionwiththe swa decommissioning rule amendments and is being1 published for public comment.
The purposeofthisguideistoprovidegub5bie1 cYncerningthespecificinformation n
w that should be kept and maintained in'the,, decommissioning records required by the p,
w rule ainendments regarding the radiological conditions at the plant that could affect occupational and public hahlth $Nd safety during decommissioning.
Any information collection activities mentioned in this draft regulatory guide are contained as requirements in 10 CFR Part 50, which provides the regu-latory basis for this gui$ehThe information collection requirements in 10 CFR Part 50 have been cleare% e vd'under OMB Clearance No. 3150-0011.
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- Decommissioningimeaniio;safelyremovenuclearfacilitiesfromserviceand reduce residualCradioactivity to a level that permits release of the property for unrestricted isse, and termination of the license, o
This regulatory guide is being issued in draf t form to involve the public in the early stages of the develop-ment of a regulatory position in this area. It has not received complete staff review and does not represent an official NRC staff position.
Public coments are being solicited on the draft guide (including any implementation schedule) and its assoc 1-f
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g sted regulatory analysis or value/ impact statement. Comme'its should be accompanied by appmpriate supporting (v) data. Writtea comments may be submitted to the Regulatory Publications Broch, DFIPS, Office of Administra-tion. U.S. Nuclear Regulatory Comission Washington, DC 20555. Copies of comments received may be examined at the NRC Public Document Room, 2120 L Street NW., Washington, DC. Coments will be most helpful if received by December 29, 1989.
Requests for single copies of draft guides (which may be reproduced) or for placement on an automatic distri-button list for single copies of future draft guides in specific divisions should be made in writis.g to the U.S. Nuclear Regulatory Commission. Washinoton. nc 20m a t tention: Director, Division of Infonnation Support Services.
8910050146 890730 PDR REGGD (61SLnRE D
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DISCUSSION O
In planning for the actual decommissioning of a reactor, it is necessary to have as complete knowledge as possible of the existing radiological conditions in the reactor.
The rule amendments require submittal of a preliminary decommissioning plan about five years before permanent shutdown (10 CFR 50.75(f)) and submittal of a decommissioning plan at the time of permanent cessation of operations
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Both these plans will contain a description of planned decommissioning activities and a description of methods used to ensure protec-tion of workers and the environment against radiation hazards during decommis-sioning.
To develop these descriptions, information such as levels and loca-tions of radiation and quantities of specific radionuclides present in areas of the facility that are to be decommissioned would be inciuded.
Certain areas may not have been normally acrassible during normal operations, but workers could come in contact with them during decommissioning operations.
Knowledge of radiological conditions in and around the reactor will serve to facilitate decommissioning by minimizing occupational exposure and reducing the risk of any public exposure.
Input to the reactor decommissioning plan would include records of spills or other unusual occurrences that took place over the ope, sting life of the reactor where significant contamination may remain, up-to-date drawings of restricted areas where radioactive materials are present, aid potential locations of inac-cessible contamination.
Records of such information would indicate conditions i
in the reactor facility that could adversely affect health and safety, and these records could be used to minimize radiation exposure during decommission-ing activities.
For example, the decommissioning records would contain informa-tion on radiation sources that could otherwise be forgotten over the period of operation, such as buried pipes contaminated with radioactive material.
Hence the amended rule sections require that records be kept of spills or unusual occurrences resulting in significant contamination remaining after cleanup pro-cedures or when contaminants may have spread to inaccessible areas.
The amend-ments also require that records be kept of as-built drawings, modifications of c
structures and equipment in restricted areas where radioactive materials are used or stored, and locations of possible inaccessible contamination.
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REGULATORY P051 TION
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This section describes methods of implementing the general requirements for recor'dkeeping for licensees who must comply with 10 CFR 50.75(g).
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GENERAL
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1.1 The location containing the decommissioning records should be clearly
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identified and designated as containing records and information important to safe decommissioning.
1.2 Information related to decommissioning need not be submitted to the NRC as it is collected and filed, but the necessary documents should be main-tained in appropriate files and be available for inspection upon request by the NRC.
1 1.3 Plant operating procedures should clearly define responsibility for collection, retention, maintenance, updating, and retrieval of the decommis-O) sioning records.
,!LJ 1.4 Decommissioning records should be reviewed periodically by plant management to ensure their completeness and ability to serve their intended l
function.
- 1. 5 The collection, safekeeping, retention, maintenance, and updating of decommissioning records should be included in the overall site quality assur-ance-program, consistent with the coverage for other health and safety records i
systems.
Regulatory Guide 1.88, Revision 2, " Collection, Storage, and Mainte-nance of Nuclear Power Plant Quality Assurance Records," should be used in l
particular for guidance on records administration, storage, preservation, safe-keeping, and retrieval of the decommissioning records.
2.
REFERENCES TO OTHER RECORDS I
Paragraph 50.75(g) indicates that, if records of information relevant to
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decommissioning are kept for other purposes, reference to those records and I
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their locations may be substituted.
If reference is made to other records, the
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following should be considered.
2.1 There should be an entry in the decommissioning records referring to l
the other record.
The reference should be clear and specific, providing at l
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least a one-sentence description of the subject and providing the referenced file location.
1 2.2 The licensee should take measures to avoid loss of the information in k
the original document in the referenced file in case that file is destroyed be-fore the license is terminated, for example, by cross-referencing the original document or its file to the decommissioning records.
Records that are refer-enced but not included in the decommissioning records themselves should be so labeled and marked not to be removed or destroyed without approval by the individual responsible for maintaining deccamissioning records.
2.3 Reference may be made to reports made under other regulatory require-ments concerning spills.
However, the record for decommissioning purposes should specifically consider the contamination levels remaining after any cleanup activities.
3.
CONTENT OF DECOMMISSIONING RECORDS FILE 3.1 Paragraph 50.75(g)(1) requires that records be kept of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site; that the records may be limited to instances when significant contamination remains after any cleanup procedures or when there is reasonable likelihood that contaminants have spread to inaccessible areas; and that the records must include any known information on involved nuclides, quantities, forms, and concentrations.
3.1.1.
The records should contain a description of the spill or i
occurrence, cleanup activities, and the location of the remaining contamination.
Inaccessible areas would be areas beyond those normally encountered in opera-tions, such as cracks in concrete, seepage into wood or tile, seepage into O.
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equipment and components, or areas behind, below, or obstructed by equipment or structures.
The records should contain sketches, diagrams, or drawings marked to show areas of contamination and points where radionuclides and radiation measurements were made.
3.1.2.
The records should contain information related to site charac-terization, including information on radiological spills on the site, residual soil contamination levels, principal contaminant radionuclides, and on-site locations that may have been used for burial of radioactive materials.
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3.1. 3.
The records should clearly indicate the specific radionuclides involved Ond the locations, quantity, form, and concentration of the radionuclides contamination, if known, and the basis for this information.
3.1.4.
Only radionuclides contaminants with half-lives greater than 6 months need be included in the record.
3.1.5.
Only records on contamination that could significantly impsct 9
decommissioning methods, costs, or occupational exposure should be included in the record file.
- 3. 2 According to 10 CFR 50.75(g)(2), records are to be kept of as-built drawings and modified drawings of (1) structures and equipment in restricted areas where radioactive materials are used or stored, and (2) locations of possible inaccessible contamination. If the records reference other required drawings, each relevant document need not be indexed individually.
If drawings are not available, appropriate records on available information concerning these areas and locations are to be substituted.
In complying with these requirements the following should be considered:
3.2.1.
Normal plant as-built drawings are sufficient for meeting the requirements of 10 CFR 50.75(g)(2).
Drawings of restricted areas where radio-active materials are used or stored should include drawings showing the location of structures, systems, equipment, and components in restricted areas as defined in 10 CFR 20.3(14).
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3.2.2 Drawings of areas of possible inaccessible contamination should include buried pipes or other areas obstructed by equipment or structures or as indicated in Regulatory Position 3.1.1.
3.2.3 If other drawings are referenced, it is sufficient to reference the general category of drawings being referenced (for example, drawings of a particular laboratory location, plant structure, or equipment) and the specific location where those drawings are kept (for example, the file room at the facility and specific file number).
3.2.4 If drawings are unavailable, appropriate records of available information may be substituted, including written descriptions of particular f
areas, recent sketches, or photographs.
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CURRENT LICENSEES 1
Current licensees should review their recordkeeping provisions to be sure they meet the requirements of 10 CFR 50.75(g).
Records of spills or other unusual occurrences, if such information exists, and records of existing drawings should be reviewed.
A location for the decommissioning records should be clearly identified and established by either incorporating these existing files in the decommissioning records or by referencing the existing files.
If drawings are not available, alternative records should be created as in Regulatory Position 3.2.4.
Recreation of records on spills and occurrences beyond what is known in existing documentation is not necessary.
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IMPLEMENTATION i
The purpose of this section is to provide information to licensees regarding the NRC staff's plans for using this regulatory guide.
This draft regulatory guide has been released to encourage public partici-pation in its development.
Except in those cases in which a licensee proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the guidance to be described in the active guide re-flecting public comments will be used in the evaluation of a licensee's provi-sions for maintenance of records important to decommissioning for all licensees with operating licenses in effect on or after the implementation date to be specified in the final guide.
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e i-N 3.g DRAFT val _UE/ IMPACT STATEMENT g
'1.
.P_ROPOSED ACTION il.1 Description l0nJune27,_1988, the Commission amended Part 50 to set forth criteria for L
decommissioning (53 FR 24018).
The rule amendment, 10 CFR 50.75(g), requires.
I licensees to keep records of information important to safe and effective,decom-missioning in an identified location until the license is terminated by the'NRC.
The new rule section also indicates general information that the NRC considers important'to decommissioning.
This proposed action is to issue a draft regula-
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toryz guide on recordkeeping for decommissioning.
The draft regulatory guide swould be issued.for comment in support of the amended rules on decommissioning.
!4 1.2 Need In planning for the actual decommissioning of a reactor, it is necessary to have as' complete knowledge as possible of the radiological condition of the reac-to r.-
This information will serve to facilitate decommissioning by_ minimizing occupational exposure and reducing the risk of any public exposure.
The purpose offdecommissioning records is to keep and maintain information concerning con-ta'ination remaining from spills or other occurrences and to maintain up-to-date drawings of restricted areas where radioactive materials are used or stored or of inaccessible areas so that this information can be used when planning for l
I decommissioning.
At the present time there is no published NRC guidance con-I cerning methods for establishing and maintaining decommissioning records in a manner considered acceptable to the NRC staff.
Specific information should be P
~ provided'on details of recordkeeping for decommissioning so that licensees can
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- develop and maintain records required by the rule amendment with a minimum of l
time and effort.
This guide would describe methods acceptable to the NRC staff L
for implementing the general requirements on recordkeeping.
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l 1.3 Value/ Impact 1.3.1 NRC Information in the decommissioning records would not be submitted to the j
NRC, so no staff review is necessary; however, the licensee's records would be subject to routine inspections to verify that the required records are properly maintained.
This regulatory guide would identify criteria for recordkeeping for J
decommissioning.
Application and use of this guidance by NRC staff members who engage in inspections will aid their review of licensee recordkeeping provisir.ns.
The Regulatory Analysis for the decommissioning rule amendments (10 CFR 50.75(g))
estimated the staff time involved in consideration of recordkeeping by licensees.
This guide does not add to this review time but provides guidance for satisfying s
recordkeeping provisions required by the rule, and in so doing minimizes staff time to the extent practicable.
In addition, appropriate information in the records would provide the basis for more acceptable decommissioning plans being submitted to the NRC, which could significantly rec'uce the time required for staff review of those decommissioning plans.
Oi 1.3.2 Other Government Agencies i
State or Federal agencies (for example, a State university) that hold a license from the NRC for a nuclear facility will be affected.
The value/ impact is expected to be similar to that for industry (see Section 1.3.3).
- 1. 3. 3 Industry Industry should benefit from this action because it provides guidance and criteria for meeting the recordkeeping requirements contained in the rule amend-ments on decommissioning.
Publication of a draft guide will allow industry rep-resentatives to participate in iM development of a final regulatory guide by j
submitting comments.
The Regulatory Analysis for the rule amendmenb on decom-missioning estirrated the impact on industry for the implementation of record-keeping requirements.
No additional impact is anticipated as a result of this proposed action since it merely provides guidance for recordkeeping required by the rule and, in so doing, minimizes impact on industry to the extent practical.
The proposed action informs licensees of the type of information that should be kept in decommissioning records, which would minimize their costs.
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1.3.4 Public This proposed action would provide guidance to licensees on information that should be kept in decommissioning records.
Such records would be more
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reliable and complete, which would reduce the potential of leaving excessive residual radioactivity and would reduce occupational exposures Reliable records also reduce the chances for inefficient decommissioning, thus minimiz-ing the cost of decommissioning and increasing the assurance that funds will be available for decommissioning.
Thus, this proposed action would have a beneficial effect on public health and safety.
Issuance of a draft regulatory guide for public comment would also allow for broader input when developing the final guide.
2.
TECHNICAL APPROACH The guide does not set forth any technicai positions, thus this section is not applicable.
3.
PROCEDURAL APPROACH 3.1 Procedural Alternatives NRC procedures that may be used to promulgate the information contained in the guide are:
Regulation Policy statement NUREG-series report Regulatory guide Branch technical position A policy statement or a regulation are not suitable for incorporating the degree of detail that would be presented in the guide.
Branch technical posi-tions (BTP) are sometimes prepared for specific guidance.
However, no BTP is being developed on this subject.
NUREG reports provide information, but they usually contain results of specific studies and are not suitable for providing guidance.
This proposed action is to provide nuclear reactor licensees with information related to keeping records important to safe and effective 9
decommissioning.
Such recordkeeping is required by the recently published rule amendments on decommissioning (53 FR 24018, June 27, 1988).
A regulatory guide is considered the best alternative for accomplishing this purpose.
4.
STATUTORY CONSIDERATIONS 4.1 NRC Authority Authority for the proposed action is derived from the Atomic Energy Act of 1954, as amended, and the Energy Reorganization Act of 1974, as amended and implemented through the Commission's regulations cited in the introduction to the guide.
4.2 Need for Environmental Assessment Issuance or amendment of guides for implementing regulations in Title 10, I
Chapter I, of the Code of Federal Regulations is a categorical exclusion under paragraph 51.22(c)(16) of 10 CFR Part 51.
Thus no environmental impact statement or assessment is necessary.
5.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES The draft regulatory guide would be issued for public comment in support of the rule amendments on decommissioning (53 FR 24018, June 27, 1988, effective date of July 27, 1988).
6.
SUMMARY
AND CONCLUSIONS The proposed regulatory guide should be issued for public comment.
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