ML23062A701

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Orc 2000 NRC Decommissioning Guidance Feedback Larry Camper
ML23062A701
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Issue date: 10/03/2000
From: Camper L
Office of Nuclear Material Safety and Safeguards
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Download: ML23062A701 (22)


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TO DATE

Larry W. Camper, Chief NRC'S DECOMMISSIONING GUIDANCEDecommissioning Branch, Division of Waste TESTING THE NEW GUIDANCE--FEEDBACK TO DATEManagement U.S. Nuclear Regulatory CommissionLarry W. Camper, Chief Decommissioning Branch, Division of Waste Management (301) 415-7234;

U.S. Nuclear Regulatory Commission NEI/EPRI Decommissioning/Dry Storage(301) 415-7234; lwc @ nrc.gov Planning and Technology ForumOrganization of Agreement States Meeting July 25, 2000October 3, 2000 OVERVIEW

Strategic Plan goals Key guidance documents License Termination Plan (LTP) reviews Stakeholder/public involvement How is it going?

Future actions LTP ACCEPTANCE REVIEW OBSERVATIONS

Completeness not adequacy or accuracy Two rejected LTPs One accepted LTP

- Consistent with SRP in NUREG-1700

- Followed lessons learned Ultimate acceptance LTP ACCEPTANCE REVIEW OBSERVATIONS

Site characterization not sufficiently detailed Final Status Survey Plan lacked sufficient information Decommissioning costs not sufficiently detailed LTP TECHNICAL REVIEW OBSERVATONS

Reviews underway Requests for information (RAIs) are needed Fundamental flaws Face-to-face discussions SRP FOR DECOMMISSIONING

Detailed information for complex site (bounding)

Tailor to complexity and safety significance Early/extensive public interactions with the licensee NOVEMBER STAKEHOLDER/PUBLIC WORKSHOP

Purpose of workshop November 7-8, 2000 Roundtable for stakeholder feedback HOW IS IT GOING?

Regulation "grow in Timing--needs/expectations Gaining experience Some adjustments needed Will be better FUTURE ACTIONS

Consolidate guidance Reexamine Regulatory Guide 1.179 Reexamine Decommissioning SRP (lessons learned)

Scrub decommissioning guidance (risk informed)

Industry/NRC working group Break

More If You Want It.

INSTITUTIONAL CONTROL FOR RESTRICTED RELEASE

Legally enforceable institutional controls so doses will not exceed 25 mrem

Assuming institutional controls are not longer in effect; doses will either:

- Not exceed 100 mrem, or

- Not exceed 500 mrem for special cases INSTITUTIONAL CONTROL (cont)

For 500 mrem cases:

- Further reductions to 100 mrem not technically achievable, prohibitively expensive, or result in net public or environmental harm

- Durable institutional controls

- Five-year rechecks of institutional controls

- Government entity or independent third party responsible for rechecks, control, and maintenance INSTITUTIONAL CONTROL (cont)

Seek advice from affected parties/public on proposed institutional controls

- Doses will not exceed 25 mrem

- Will be enforceable

- Will not impose undue burdens on the local community or other affected parties

Sufficient financial assurance to provide the necessary institutional controls FINANCIAL ASSURANCE REGULATIONS

Reactors Materials

Amounts & Instruments Amounts & Instruments

§ 50.75 § 30.35, § 40.36, § 70.25

Access to Funds Access to Funds

§ 50.82 Controlled in Financial Instruments FINANCIAL ASSURANCE REQUIREMENTS

Sufficient Amount

Funds Reserved for Decommissioning Activities

Funds Available When Needed

NRC Can Direct Payments If Necessary DRAWDOWN OF DECOMMISSIONING FUNDS

Reactors Materials

3% for Planning Notify NRC 30 Days 2

Prior to Withdrawal

1 20% after PSDAR < 10% of Balance Without

100% after Site-Specific Written NRC Approval Cost Estimate

1 2 Post Shut Down Activities Report Applies to trusts and escrows STRATEGIC PLAN GOALS

Maintain safety and protection of the environment Increase public confidence Improve efficiency, effectiveness and realism Reduce unnecessary regulatory burden KEY GUIDANCE DOCUMENTS

NUREG 1700, Standard Review Plan (SRP) for reactor LTP reviews Regulatory Guide 1.179, Standard Format and Content Guide for reactor LTPs SRP for decommissioning plan (DP) reviews Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)

NUREG 1700--SRP FOR REACTOR LTP REVIEWS

Published for public comment Reviewed by CRGR Finalized in May 2000 REGULATORY GUIDE 1.179 STANDARD FORMAT AND CONTENT FOR LTP

General level of detail (consistent with regulation)

Use with SRP (NUREG-1700)

Requires licensee initiative MARSSIM

Multi-agency guidance for survey methodology SRP references MARSSIM SRP provides further guidance on final survey design Positive feedback STAKEHOLDER/PUBLIC INVOLVEMENT

LTR requires licensee interactions with public NEPA requires NRC interactions with public Strategic Plan goal Institute for Environmental Conflict Resolution