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 Decommissioning NRC'S DECOMMISSIONING Branch, Division of Waste GUIDANCE TESTING THE NEW Management GUIDANCE--FEEDBACK TO DATE U.S. Nuclear Regulatory Commission (301)

Larry 415-7234; W. Camper, Chief Decommissioning Branch, Division of Waste Management U.S. Nuclear Regulatory Commission NEI/EPRI Decommissioning/Dry (301) 415-7234; lwc@nrc.gov Storage Planning and Technology Forum July 25, 2000 Organization of Agreement States Meeting October 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