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{{#Wiki_filter:OVERVIEW OF | {{#Wiki_filter:OVERVIEW OF NRCS LICENSE TERMINATION RULE Presentation at the West Valley Quarterly Public Meeting May 28, 2014 Robert L. Johnson 1 | ||
REGULATIONS AND GUIDANCE | |||
* Regulations: | |||
g 10 CFR 20 Subpart p E ((License Termination Rule (LTR)) | |||
* | * Statements of Consideration (SOC) for LTR | ||
* Guidance: Consolidated Decommissioning Guidance, NUREG-1757, Vol. 1, 2, and 3 | |||
* Commission Commissions s West Valley Policy Statement (WVPS) | |||
* Commissions Orders regarding Shieldalloy o CLI-11-12 and CLI-13-06 o Only for 10 CFR 20.1403(a) 2 | |||
- | |||
- | |||
prohibitively expensive | LTR STATEMENT OF CONSIDERATIONS (SOC) | ||
-NUREG-1757 , Vol. 1; Rev. 2 , Section 17. | * Source of extensive informationrationale for provisions, responses tot comments t | ||
* | * Commission preference for unrestricted release | ||
-Monitoring and maintenance; 5-year rechecks | * Recognition that there may be cases where achieving unrestricted release would not be reasonable (e (e.g., | ||
-Independent third party/government backup to site owner/custodian | g where cost would be excessive) | ||
- | * Flexibility | ||
-Remain licensed, if needed 14}} | - Consistent set of criteria for the range of facilities and site conditions | ||
- License termination approaches available: unrestricted release, restricted release, alternate criteria | |||
- Licensee Li proposes decommissioning d i i i methodsth d ffor meeting ti ddose criteria | |||
- NUREG-1757, Vol. 2, Rev.1, Section 2 3 | |||
GENERAL PROVISIONS, UNRESTRICTED RELEASE | |||
* General provisions p | |||
- 10 CFR 20.1401 | |||
- 1000 year compliance period | |||
- DOE/NYSERDA EIS should analyze beyond 1000 yr (WVPS SOC) | |||
* Unrestricted release license termination | |||
- 10 CFR 20 20.1402 1402 | |||
- 25 mrem/yr and ALARA | |||
* Licensee could p propose p both unrestricted and restricted release for different portions of the site 4 | |||
RESTRICTED RELEASE ELIGIBILITY | |||
* 10 CFR 20.1403(a) ( ) | |||
* Purpose | |||
- Initial eligibility for restricted releasenot approval | |||
- Screen out sites that should be removing contamination to achieve unrestricted release | |||
* A site would be eligible if further reductions in residual radioactivity necessary to comply with the provisions of 20.1402 | |||
- would result in net public or environmental harm or | |||
- were not being made because the residual levels associated with restricted conditions are ALARA. | |||
5 | |||
RESTRICTED RELEASE ELIGIBILITY (CONT.) (CONT ) | |||
* Commissions Orders regarding Shieldalloy | |||
- Series of Shieldalloy lawsuits with associated Court and Commission actions | |||
- Explain original meaning of provision and clarifies the analysis is limited to further removal of residual radioactivity | |||
- Not a comparison of individual doses of restricted and unrestricted release and selection of the lowest dose | |||
- Cost benefit analyses following NUREG-1757, Appendix N | |||
* Costs/benefits of further removal of residual radioactive material from levels proposed to remain onsite to the unrestricted release level | |||
* Net public harm analysis (costs of harm to people and environment compared to benefits, e.g., collective dose averted dollar value) | |||
* ALARA (total costs compared to benefits, benefits e e.g., | |||
g collecti collective e dose averted a erted dollar value) 6 | |||
RESTRICTED RELEASE INSTITUTIONAL CONTROLS (ICs) | |||
* 10 CFR 20.1403 (b) ( ) | |||
* Guidance in NUREG-1757, Vol. 1, Rev. 2 | |||
* Legally enforceable ICs to restrict future site use | |||
* Durable ICs | |||
- For higher risk sites (100-500 mrem/yr or > 100 yr half life | |||
- State or Federal government ownership/control | |||
* Five-year reviews | |||
* Independent p third pparty/government yg entityy backup p | |||
* NRC retains authority to take action if ICs fail (SOC) 7 | |||
RESTRICTED RELEASE ENGINEERED BARRIERS (EBs) | |||
* EBs to mitigate | |||
- Human intrusion | |||
- Adverse natural p processes ((e.g., | |||
g erosion)) | |||
- Release and transport of radionuclides | |||
* Contribute to meeting dose criteria; no prescriptive LTR requirements | |||
* EBs are not ICs and are assumed to degrade rather than immediately and totally fail for the IC fail dose criteria 8 | |||
RESTRICED RELEASE FINANCIAL ASSURANCE | |||
- 10 CFR 20.1403(c) | |||
- NUREG-1757, Vol. 3 | |||
- Purpose: enables independent third party party, including a government custodian, to assume and carryout y responsibilities p for controls and maintenance | |||
- Requirements for amounts and mechanisms (e.g., government entity statement of intent) 9 | |||
RESTRICTED RELEASE ADVICE FROM AFFECTED PARTIES | |||
* 10 CFR 20.1403 (d) | |||
* NUREG- 1757 Vol. 1 | |||
* Seek advice from affected parties on specific questions | |||
* incorporate incorporate as appropriate appropriate , | |||
* Provide a publicly available summary of discussions, d scuss o s, a and d docu document e t ad advice ce in tthe e | |||
decommissioning plan 10 | |||
RESTRICTED RELEASE DOSE CRITERIA | |||
* 10 CFR 20.1403 ((b)) and ((e)) | |||
* NUREG-1757, Vol. 2 | |||
* ICs in effect: 25 mrem/yr plus ALARA | |||
* If ICs no longer in effect ((dosedose caps) caps ) | |||
o Assumption of immediate and total failure o ALARA o 100 mrem/yr or o 500 mrem/yr Further reductions in residual radioactivity necessary to comply with 100 mrem/yry are not technicallyy achievable,, prohibitively p y expensive, or would result in net public or environmental harm o If ICs fail NRC retains authority to take action (SOC) 11 | |||
RESTRICTED RELEASE ALTERNATE CRITERIA | |||
* Alternate criteria license termination | |||
- 10 CFR 20.1404 | |||
- NUREG-1757, Vol. 1; Rev. 2 | |||
- Alleviates the need for exemptions for exceeding doses listed below (SOC) | |||
- Exceed 25 mrem/yr (1402, 1403(b), 1403(d)(1)(i)(A)) | |||
- Not to exceed 100 mrem/yr from all man-made sources | |||
- Restrictions required per 1403; reduce doses to ALARA | |||
- Commission approval after considering public and EPA comments | |||
* Exemptions | |||
- Consider granting exemptions | |||
- WVPS: if LTR compliance is technically impractical or prohibitively expensive, but maintain protection 12 | |||
NO LICENSE TERMINATION | |||
* Keepp under license | |||
- SOC: Alternative to license termination if requirements cannot be met | |||
- WVPS: longlong-term term or perpetual license where LTR requirements are technical impractical or prohibitively expensive | |||
- NUREG-1757, NUREG 1757 Vol Vol. 1; Rev Rev. 2 2, Section 17 17.77 and Appendix M | |||
* Possession only license for long-term control approved by Commission | |||
* Last resort (e.g., if independent third party requirement is not met) 13 | |||
RESTRICTED RELEASE CONCLUSION | |||
* A system of controls to ensure safety | |||
- 25 mrem/yr with restrictions | |||
- Legally enforceable and durable ICs | |||
- EBs designed for site | |||
- Monitoring and maintenance; 5-year rechecks | |||
- Independent third party/government backup to site owner/custodian | |||
- Financial assurance for third party | |||
- Dose caps if ICs fail: safety net | |||
- Remain licensed, if needed 14}} |
Revision as of 04:59, 4 November 2019
ML14143A037 | |
Person / Time | |
---|---|
Site: | West Valley Demonstration Project, P00M-032 |
Issue date: | 05/28/2014 |
From: | Rachel Johnson NRC/FSME/DWMEP/DURLD/SPB |
To: | |
Shared Package | |
ML14143A059 | List: |
References | |
Download: ML14143A037 (14) | |
Text
OVERVIEW OF NRCS LICENSE TERMINATION RULE Presentation at the West Valley Quarterly Public Meeting May 28, 2014 Robert L. Johnson 1
REGULATIONS AND GUIDANCE
- Regulations:
g 10 CFR 20 Subpart p E ((License Termination Rule (LTR))
- Guidance: Consolidated Decommissioning Guidance, NUREG-1757, Vol. 1, 2, and 3
- Commission Commissions s West Valley Policy Statement (WVPS)
- Commissions Orders regarding Shieldalloy o CLI-11-12 and CLI-13-06 o Only for 10 CFR 20.1403(a) 2
LTR STATEMENT OF CONSIDERATIONS (SOC)
- Source of extensive informationrationale for provisions, responses tot comments t
- Commission preference for unrestricted release
- Recognition that there may be cases where achieving unrestricted release would not be reasonable (e (e.g.,
g where cost would be excessive)
- Flexibility
- Consistent set of criteria for the range of facilities and site conditions
- License termination approaches available: unrestricted release, restricted release, alternate criteria
- Licensee Li proposes decommissioning d i i i methodsth d ffor meeting ti ddose criteria
- NUREG-1757, Vol. 2, Rev.1, Section 2 3
GENERAL PROVISIONS, UNRESTRICTED RELEASE
- General provisions p
- 1000 year compliance period
- DOE/NYSERDA EIS should analyze beyond 1000 yr (WVPS SOC)
- Unrestricted release license termination
- 10 CFR 20 20.1402 1402
- 25 mrem/yr and ALARA
- Licensee could p propose p both unrestricted and restricted release for different portions of the site 4
RESTRICTED RELEASE ELIGIBILITY
- Purpose
- Initial eligibility for restricted releasenot approval
- Screen out sites that should be removing contamination to achieve unrestricted release
- A site would be eligible if further reductions in residual radioactivity necessary to comply with the provisions of 20.1402
- would result in net public or environmental harm or
- were not being made because the residual levels associated with restricted conditions are ALARA.
5
RESTRICTED RELEASE ELIGIBILITY (CONT.) (CONT )
- Commissions Orders regarding Shieldalloy
- Series of Shieldalloy lawsuits with associated Court and Commission actions
- Explain original meaning of provision and clarifies the analysis is limited to further removal of residual radioactivity
- Not a comparison of individual doses of restricted and unrestricted release and selection of the lowest dose
- Cost benefit analyses following NUREG-1757, Appendix N
- Costs/benefits of further removal of residual radioactive material from levels proposed to remain onsite to the unrestricted release level
- Net public harm analysis (costs of harm to people and environment compared to benefits, e.g., collective dose averted dollar value)
- ALARA (total costs compared to benefits, benefits e e.g.,
g collecti collective e dose averted a erted dollar value) 6
RESTRICTED RELEASE INSTITUTIONAL CONTROLS (ICs)
- Guidance in NUREG-1757, Vol. 1, Rev. 2
- Legally enforceable ICs to restrict future site use
- Durable ICs
- For higher risk sites (100-500 mrem/yr or > 100 yr half life
- State or Federal government ownership/control
- Five-year reviews
- Independent p third pparty/government yg entityy backup p
RESTRICTED RELEASE ENGINEERED BARRIERS (EBs)
- EBs to mitigate
- Human intrusion
- Adverse natural p processes ((e.g.,
g erosion))
- Release and transport of radionuclides
- Contribute to meeting dose criteria; no prescriptive LTR requirements
- EBs are not ICs and are assumed to degrade rather than immediately and totally fail for the IC fail dose criteria 8
RESTRICED RELEASE FINANCIAL ASSURANCE
- NUREG-1757, Vol. 3
- Purpose: enables independent third party party, including a government custodian, to assume and carryout y responsibilities p for controls and maintenance
- Requirements for amounts and mechanisms (e.g., government entity statement of intent) 9
RESTRICTED RELEASE ADVICE FROM AFFECTED PARTIES
- NUREG- 1757 Vol. 1
- Seek advice from affected parties on specific questions
- incorporate incorporate as appropriate appropriate ,
- Provide a publicly available summary of discussions, d scuss o s, a and d docu document e t ad advice ce in tthe e
decommissioning plan 10
RESTRICTED RELEASE DOSE CRITERIA
- 10 CFR 20.1403 ((b)) and ((e))
- NUREG-1757, Vol. 2
- If ICs no longer in effect ((dosedose caps) caps )
o Assumption of immediate and total failure o ALARA o 100 mrem/yr or o 500 mrem/yr Further reductions in residual radioactivity necessary to comply with 100 mrem/yry are not technicallyy achievable,, prohibitively p y expensive, or would result in net public or environmental harm o If ICs fail NRC retains authority to take action (SOC) 11
RESTRICTED RELEASE ALTERNATE CRITERIA
- Alternate criteria license termination
- NUREG-1757, Vol. 1; Rev. 2
- Alleviates the need for exemptions for exceeding doses listed below (SOC)
- Exceed 25 mrem/yr (1402, 1403(b), 1403(d)(1)(i)(A))
- Not to exceed 100 mrem/yr from all man-made sources
- Restrictions required per 1403; reduce doses to ALARA
- Commission approval after considering public and EPA comments
- Exemptions
- Consider granting exemptions
- WVPS: if LTR compliance is technically impractical or prohibitively expensive, but maintain protection 12
NO LICENSE TERMINATION
- Keepp under license
- SOC: Alternative to license termination if requirements cannot be met
- WVPS: longlong-term term or perpetual license where LTR requirements are technical impractical or prohibitively expensive
- NUREG-1757, NUREG 1757 Vol Vol. 1; Rev Rev. 2 2, Section 17 17.77 and Appendix M
- Possession only license for long-term control approved by Commission
- Last resort (e.g., if independent third party requirement is not met) 13
RESTRICTED RELEASE CONCLUSION
- A system of controls to ensure safety
- 25 mrem/yr with restrictions
- Legally enforceable and durable ICs
- EBs designed for site
- Monitoring and maintenance; 5-year rechecks
- Independent third party/government backup to site owner/custodian
- Financial assurance for third party
- Dose caps if ICs fail: safety net
- Remain licensed, if needed 14