ML20150D716

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Forwards Response to 870901 Request for Description of Actions & Schedule for NRR Transfer of Regulatory Responsibility for Reactor Decommissioning to NMSS
ML20150D716
Person / Time
Issue date: 03/21/1988
From: Murley T, Thompson H
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), Office of Nuclear Reactor Regulation
To: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
NUDOCS 8803250097
Download: ML20150D716 (40)
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  1. [o,, UNITED STATES

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5 "l g NUCLEAR REGULATORY COMMISC!ON WASHINGTON. D. C. 20555

/ MAR 211988 f

MEMORANDUM FOR: Victor Stello, Jr. 1 Executive Director for Operations FROM: Thomas E. Hurley, Director l Office of Nuclear Reactor Regulation Hugh L. Thompson, Jr., Director Office of Nuclear Materials Safety and Safeguards

SUBJECT:

TRANSFER OF REGULATORY RESPONSIBILITY FOR REACTOR DECOMMISSIONING FROM NRR TO NMSS The enclosed paper responds to your September 1, 1987 request for a description of the actions and schedule necessary for transfer of the regulatory responsibility for reactor decomissioning from NRR to NMSS.

t Thomas E. Murley, Direc or Office of Nuclear Reactor Regulation a s, e w

lHughL. Thompson,Jr., Director Office of Nuclear Materials Safety and Safeguards

Enclosure:

As stated l

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3 9 i TRANSFER OF REGULATORY RESPONSIBILITY FOR REACTOR DECOMMISSIONING FROM NRR TO NMSS EXECUTIVE

SUMMARY

By memorandum dated September 1,1987, the Executive Director for Operations requested that the Office of Nuclear Reactor Regulation (NRR) and the Office of Nuclear Material Safety and Safeguards (NMSS) identify the actions and schedule for transferring the regulatory responsibility for reactor decommissioning

  • from NRR to NMSS (Enclosure 1). This paper responds to that request.

Within NRC, the responsibilities for decomissioning are currently divided between NRR and NMSS. NRR is responsible for decomissioning associated with reactor licenses and NMSS for decomissioning associated with non-reactor licenses. In the last year, the NRC has taken major actions to shift the focus of its activities from reactor licensing to the regulation of reactor operations. Thus, it is appropriate to begin making arrangements for the future focus of decomissioning and license termination. To that end, NMSS l will be the focal point for all decomissioning activities, and will be responsible for the management of power reactor decomissioning. For the present non-power reactor decommissioning activities will remain in NRR, and will be closely coordinated with NMSS. Through these actions NRC will have a central and clearly identifiable organization to coordinate decommissioning activities within a single office. This centralization will facilitate internal management and allow resources to be used more effectively and efficiently, in accordance with Goal 5 of the Five-Year Plan. The transfer will also give the Agency a visible program in an area that is receiving an increased level of public and political attention.

The decomissioning process focuses primarily on waste management, financial assurance, custodial, and disposal activities rather than on l operational activities. Coordination of all decomissioning activities by NMSS, which is currently responsible for waste management and non-reactor ,

financial assurance and decomissioning, would help ensure the development of consistent Agency-wide policies and guidance and the consistent implementation  !

of the Agency's decomissioning program. The transfer would allow NRR to focus its attention on safety concerns for operating reactors. ,

  • "Decomissioning" means removing a nuclear facility safely from service and reducing residual radioactivity to a level that permits the release of the property for unrestricted use and termination of the license.

Decommissioning is an action that a licensee must perform toward the end of a licensed activity as an integral step in the orderly termination of the license.

CURRENT DECOMMISSIONING PROCESS At present, reactor decommissioning is managed by NRR, according to the regulatory process sumarized in the enclosed flowchart (Enclosure 2).

Assuming that the final rule amendments for decomissioning (SECY-87-309, dated December 17, 1987) are in place, a licensee can opt to utilize one or a combination of the following decommissioning alternatives: DECON, SAFESTOR, and ENTOMB.*

I For power reactors, any of the three alternatives or combinations of alternatives may be acceptable as long as the chosen plan provides for completion of decomissioning within 60 years of permanent shutdown. The '

period can be extended beyond 60 years only when necessary to protect the public health and safety. For non-power reactors, decomissioning plans should provide for the completion of decomissioning without significant delay.

Approval of a delayed completion of decommissioning will be considered only when necessary to protect the public health and safety.

The table below shows the elements that lead to the termination of a license, l the present responsibility for handing those elements, and the proposed future responsibility (see also Enclosure 2).

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  • DECON is the process in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to levels acceptable for unrestricted use of the property.

SAFSTOR is the process in which the nuclear facility is stored and maintained in a safe condition for a period and then decontaminated (deferred DECON) to levels that permit release of the property for unrestricted use.  !

ENTOMB is the process in which radioactive contaminants are encased in structurally long-lived material, such as concrete. The entombed structure is appropriately maintained and continued surveillance is performed until the radioactivity decays to levels permitting unrestricted use of the property.

Organizational Power Reactor Licensee Actions NRC Staff Responsibility Required To Terminate License Action Present Proposed

1. Submittal of application for Issue POL NRR PM* NRR PM has the lead Possession-Only License (POL) with NMSS support
2. Submittal of amendments to Approve TS NRR PM NRR PM 1 Technical Specifications (TS) amendments
3. Submittal of Physical Security Approve NRR PM NRR PM has the lead Plan revisions revisions with NHSS support
4. Submittal of Emergency Approve NRR PM NRR PM has the lead Plan revisions revisions with NMSS support
5. Submittal of Decomissioning Issue SER NRR PM NMSS PM reviews Plan and EA*; Decomissioning 1 approve Plan Plan and prepares SER and EA; NRR PM issues SER and l EA and approves Plan
6. Actions after Decomissioning Manage NRR PM NMSS PM activities Plan is approved NOTE: Until regulatory action has been completed on the documents listed in ,

items 1 through 4, and the Decomissioning Plan has been approved, all j comunication with the licensees will be through the NRR PM.  !

  • SER = Safety Evaluation Report; EA = Environmental Assessment; PM = Project Manager PROPOSED TRANSFER OF REGULATORY RESPONSIBILITY FROM NRR TO NHSS Under the proposed transfer of regulatory responsibility, NMSS would assume the responsibility for the review of a power reactor's Decommissioning Plan and the preparation of the SER and EA. NRR would retain responsibility for modifying the facility Technical Specifications, Physical Security Plan, and Emergency Plan, and would issue the POL. The overall project management responsibility would be transferred to NMSS after these activities have been completed and the Decomissioning Plan is approved. Once the responsibility is transferred to NMSS, all comunications with the licensee would take place through the assigned NMSS Project Manager. NHSS would oversee the implementation of the Decomissioning Plan and the termination of the license when the de-comissioning activities are successfully completed.

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ACTIONS REQUIRED FOR THE TRANSFER OF REGULATORY RESPONSIBILITY ,

The transfer of regulatory responsibility would entail a transition period for planning, organizing, and staffing this effort in NMSS. The initial planning for the transfer of this regulatory responsibility could be performed in the next faw weeks, timed to support the FY 1990 budget. It would include the following:

(ll the actions necessary to ensure that the regulatory framework supports the transfer of responsibility and the deconmissioning anendments (2) the actions necessary to ensure that NMSS has the resources needed to carry out this responsibility (3) identifying and scheduling the workload The proposed NMSS organization for handling this responsibility would also be addressed in support of the FY 1990 budget request. The overall approach will be to make maximum use of the existing Agency organization structure with the addition of a central, clearly identifiable decommissioning management organization established in NMSS to coordinate all Agency decommissioning actions.

The staffing requirements associated with the transfer will be identified based on the assessment of the knowledge, skills, and abilities needed for reactor decommissioning (Enclosure 4). The transfer of regulatory responsibility for power reactor decommissioning from NRR to NMSS would involve at the most one FTE (Full Time Equivalent).

SCHEDULE FOR TRANSFER NMSS would begin immediately to plan for incorporating the proposed reactor decommissioning responsibilities into its FY 1990 budget submittal.

STAFF ANALYSIS

1. INTRODUCTION By memorandum dated September 1,1987 (Enclosure 1), the Executive Director for Operations (EDO) requested that the Office of Nuclear Reactor Regulation (NRR), in conjunction with the Office of Nuclear Materials Safety and Safeguards (NMSS), submit a paper describing the actions and schedule for transferring the regulatory responsibility for reactor decomissioning to NMSS. This paper responds to that request. This paper assumes that the final rule amendments for decomissioning dated December 17, 1987 (SECY-87-309) are in place.

To prepare the requested paper, an NRR/NMSS working group was established.

The working group reviewed the current regulatory process and responsibilities and evaluated alternatives for effecting the transfer of responsibilities.

This paper presents the working group's conclusions and identifies:

regulations and guidance applicable to reactor decomissioning

  • the reactor decomissioning process for licensees and the NRC current organizational responsibilities, including skills needed to complete reactor decommissioning licensing actions
  • 1egal issues related to reactor licenses and materials licenses
  • a forecast of reactor decomissioning actions
  • how the transfer of regulatory responsibility will take place
  • the exclusion of non-power reactors from the transfer ?ction
2. CURRENT FRAMEWORK 2.1 Reculations and Guidance Regulatory requirements for reactor decommissioning are given in Title 10 of the Code of Federal Regulatienc (10 CFR) Parts 2, 20, 50, 51, and 73 as follows:
  • 10 CFR Part 2 provides prosedures relating to license amendments.
  • 10 CFR Part 20 specifies the radiological requirements that apply to operating reactors and reactors undergoing decomissioning.
  • 10 CFR 50.33 requires licensees to submit a report indicating how they will ensure that adequate decomissioning funds will be available when they are needed.

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10 CFR 50.75 provides the criteria for the report required by 10 CFR 50.33.

  • 10 CFR 50.82 specifies the requirements for reactor decomissioning including a description of the contents of a Decomissioning Plan. i
  • 10 CFR Part 51 specifies environmental requirements for operating reactors and for those undergoing decommissioning. l

The NRC staff has also prepared regulatory guidance for reactor decomissioning as follows:

Regulatory Guide 1.86 describes acceptable decomissioning, alternatives and levels of surface contamination acceptable for release of a facility to unrestricted access.

A regulatory guide entitled "Format and Content for Nuclear Reactor Decommissioning Plans" identifies the information needed in a Decomissioning Plan. This guide, now in draft form, will be issued J as a proposed guide soon after the final rule changes on  !

decomissioning are published. Two other guides, entitled "Records Important to Decomissioning" and "Assuring the Availability of Funds for Decomissioning Nuclear Reactors," also will be published as proposed guides soon after the final rule changes.

2.2 Decomissioning Process Enclosure 2 is a flowchart outlining a simplified sequence of the NRC

licensing steps to be taken from the time a licensee decides to permanently shut down a reactor until the NRC issues an order terminating the reactor license. These steps are as follows

(1) After deciding to permanently shut down a reactor, the licensee submits an application for authority to surrender a license voluntarily and to decomission the f acility (10 CFR 50.82). The application must he made

, within 2 years following final shutdown and at least 1 year before the operating license expires. The application must include the following documents:

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(1) An application for the amendment of an Operating License to a Possession-Only License (10 CFR 50.90). Such an amendment l removes authority to operate the nuclear reactor and arovides a basis for additional amendments and approvals as discussec ,,

below.

(ii) A revised Physical Security Plan (10 CFR 50.34(c) and 50.54(p)),

proposed amendment to TS (10 CFR 50.90), and revised Emergency Plan (10 CFR 50.47). These may be submitted separately from the i Decomissioning Plan to allow a reduction in these requirements while the Decomissioning Plan is under review. Revisions to other i license requir eents may also be required. Exemptions from certain 10 CFR Part 50 requirements may also be needed to allow desired revisions.

(iii) Proposed Decomissioning Plan (10 CFR 50.82) that, ameng other items, includes the selected alternative for decomissioning and  ;

its estimated cost.

(2) NRC reviews the application for the license amendment and issues the i POL (10 CFR 50.92) after verifying that the nuclear fuel has been rerreved from the reactor, shipped off the site, or moved to the spent fuel storage pool (10 CFR Parts 50, 60, 61, and 72).

(3) NRC reviews and approves the revised Security Plan, proposed TS, I and the revised Emergency Plan.

(4) NRC reviews and approves the Decomissioning Plan and issues the l amendment to establish the TS that will be in effect during the  ;

decomissioning process. The review is conducted in accerdance with 1 a draft of the Standard Review Plan * (SRP) (SRP 13.7, Enclosure 3), which describes the NRC review process and identifies Branch responsibilities.  ;

NRC also issues an Environmental Assessment (10 CFR 51.30) of the proposed '

Decomissioning Plan, followed by an Environmental Impact Statement or a Finding of No Significant Impact, as appropriate (10 CFR 51.31).

(5) Based on the selected decomissioning alternative, the licensee performs the next step as follows:

(i) If using DECON, the licensee begins actions necessary to dismantle the facility.

(ii) If using SAFSTOR, the licensee proceeds with actions needed to place and maintain the facility in long-term storage. At the end of the storage period the licensee submits the DECON/ Dismantling Plan.

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  • A revised SRP will be developed that conforms with the final decomissioning rule and the transfer of responsibility from NRR to NMSS.

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(iii) If using ENTOMB, the licensee proceeds with the encasement, long-term maintenance, and continued surveillance of the nuclear facility. After complete decay of short-lived trHionuclides, the licensee submits a request for license termination. Residual radioactivity must be shown to meet levels acceptable for license termination or be removed.

(6) The licensee submits a DECON/ Dismantling Plan.

(7) NRC reviews and approves the DECON/ Dismantling Plan. NRC also issues a Safety Evaluation Report and an Environment Assessment followed by an Environmental Impact Statement or a Finding of No Significant Impact, as appropriate, and approves revisions to TS.

(8) The licensee performs DECON/ dismantling the nuclear facility in accordance with the approved plan.

(9) The appropriate NRC Regional Office inspects the facility to determine the levels of radioactive contaminants. If the radiation levels at the nuclear facility and adjoining property are acceptable for the property to be released for unrestricted use, Headquarters issues a license termination order.

2.3 Current Organizational Responsibilities Current reactor decomissioning organizational responsibilities anJ skills ,

are described in a draft SRP (Enclosure 3). This SRP describes the l responsibilities of NRR and NMSS Branches in the review of reactor 1 i

decomissioning licensing actions and identifies the Branches responsible for each technical discipline.

In the current organizational structure, the project management responsibility is assigned to the Standardization and Non-Power Reactor Project Directorate (PDSNP). The lead review responsibility is assigned to the Chemical Engineering Branch (ECEB). ECEB reviews the information in the licensee's  !

Decomissioning Plan, Environmental Report, and application for the termination of a license, and prepares the SER, with inputs from the secondary review branches: Radiological Protection Branch (PRPB), Human Factors Assessment Branch (LHFB), Policy Development and Technical Support Branch (PTSB), Plant Systems Branch (SPLB), Quality Assurance Branch (LQAB), Safeguards Branch i (RSGB), Emer (PEPB), and Structural and Geosciences Branch (ESGB)gency Preparedness BranchIn addition, the Regulatory Branch (LLRB)

a review.

Following the transfer of the regulatory responsibilities to NMSS, NMSS would manage and have lead responsibility for the review of Decomissioning Plans.

It is expected that NMSS would develop sufficient expertise to review the Decomissioning Plans, but it is likely that NRR assistance would be required in the areas of quality assurance, training, and emergency preparedness.

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2.4 Legal Issues, Reactor License Versus Material License To effect the transfer of regulatory responsibility for decomissioned reactors from NRR to NMSS, it is not necessary, as a matter of law, to convert existing facility licenses issued under 10 CFR Part 50 into materials licenses issued under other parts of the Comission's regulations. Under Section 204 of the Energy Reorganization Act of 1974, as amended, which established the Office of Nuclear Material Safety and Safeguards, hiiSS has broad licensing and regulatory authority involving all focilities and materials licensed under the Atomic Energy Act of 1954, as amended. Although this authority does not extend to activities associated with the construction and operation of reactors, it is broad eneugh to enable NMSS to assume regulatory oversight over decommissioned reactors once operation of the reactor has ceased.

Depending upon certain factual circumstances, a nuclear power reactor for which a Possession-Only License has been issued remains a utilization facility within the meaning of the Atomic Energy Act of 1954, as amended. As defined in Sections lly and cc of the Atomic Energy Act of 1954, as amended, the terms "production facility" and "utilization facility" apply to any equipment or device determined by rule of the Commission either:

to be capable of the production of special nuclear material in such quantity as to De of significance to the common defense and security, or in such manner as to affect the health and safety of the public or to be capable of making use of special nuclear material in such quantity as to be of significance to the common defense and security, or in such manner as to affect the health and safety of the public, or peculiarly adapted for making use of atomic energy in such quantity as to be of significance to tie common defense and security, or in such manner as to affect the health and safety of the public. (Emphasis supplied.)

Both definitiens also provide that the terms "production facility" and "utilization facility" mean "any important component part especially designed for such equipment or device as determined by the Comission." To date, the Comission has not made any component part determinations.

By reason of these definitions, a nuclear reactor may still be considered to be a utilization facility under the Act following cessation of operation and issuance of a Possession-Only License because it remains "capable of making use of special nuclear material" or "peculiarly adapted for making use of atomic energy." Even after a decommissioned reactor ceases to fall within the scope of the statutory definition of "utilization facility," under the Act the radioactive materials remaining would still remain subject to Comission regulatory authority over byproduct or special nucicar material.

The Comission's regulations in 10 CFR Part 50 define a utilization facility as any nuclear reactor other than one designed or used for the production of plutonium or V-233. A reactor designed or used for production of plutonium or 9

U-233 is defined to be a production facility. At some point during the decomissioning process, the portions of the facility remaining on the site may no longer qualify as a "nuclear reactor." This does not mean, however, that the Comission's decomissioning regulations as set out in 10.CFR Part 50 are no longer applicable. The Comission's decomissioning regulations, expected to be promulgated shortly in final form, embody a policy determination by the Comission that a nuclear power reactor, even in a SAFSTOR or ENTOMB mode, shall continue to be regulated in accordance with 10 CFR Part 50 -

requirements and procedures until decomissioning has been completed.

To permit the holder of a 10 CFR Part 50 license to convert that license to a 10 CFR Part 72 independent spent fuel storage installation (ISFSI) license, for example, because of the nature of the activities performed by the licensee at the facility site during the course of decomissioning, would enable a 10 CFR Part 50 licensee to avoid its more costly 10 CFR Part 50 obligations to provide financial assurance that sufficient funds will be available to complete the decomissioning process. The objective of the new decommissioning rule would thus be defeated.

For the foregoing reasons, it is both inappropriate and unnecessary to issue a separate materials license (e.g., byproduct material license, special nuclear material license, or independent spent fuel storage installation license under 10 CFR Parts 30, 70 and 72, respectively) during the course of decomissioning.

Instead, the original 10 CFR Part 50 license, amended as appropriate, remains in effect until the Comission decides that it may be terminated and the property released for unrestricted use.

3. FORECAST OF SCHEDULE FOR REACTOR DECOMMISSIONING All licensed power and test reactors that have been permanently shut down have been placed in a SAFSTOR status or are being placed in a SAFSTOR status. No licensee has chosen DECON/0,ismantling as a decomissioning alternative.

Conversely, most licensed research reactors are dismantled within a few months or years of permanent shutdown. No licensed reactor (power, test, or research) has been entombed, although three demonstration power plants owned by the Department of Energy have been entombed.

3.1 Present Status .

l The reactors listed below have no fuel on site and are in a SAFSTOR status; the test and research reactors would not be transferred to NMSS (see Section 5). The reactors in this category are as follows:

Peach Bottom, Unit 1 (power)

Fermi Unit 1 (power)

Vallecitos Boiling Water Reactor (power)

NASA Plum Brook Test Reactor Westinghouse Test Reactor GE EVESR (test)

Saxton (test)

NS Savannah (ship-museum)

Watertown Arsenal (research) l NASA Mockup (research) l l

The reactors listed below have spent fuel on the site and have been or are being placed in a SAFSTOR status. Following the name of each plant is the date licensing approval of its Decomissioning Plan is scheduled to be completed. These reactors are as follows:

Humboldt Bay Unit 3 - May 1, 1988 Indian Point Unit 1 - September 30, 1988 Dresden Unit 1 - July 31, 1989 La Crosse - June 30, 1989 Approximately 45 licensed research reactors have been dismantled: their licenses have been terminated and the reactor sites have been released for unrestricted access.

3.2 License Expiration Dates and Life Extension An examination of license expiration dates for large (1000 MWe) plants indicates that no large power plants are likely to be shut down for decomissioning before 2006. Life extensions for large power plants are likely to move the first large power plant decomissioning action to well beyond 2010.

3.3 Decomissioning Alternatives The alternative likely to be chosen in the fuiare for decomissioning of research reactors is DECON/ Dismantling; the alternative likely to be chosen in the future for power plant decomissioning is SAFSTOR.

The reasons for this statement are as follows:

' decomissioning history -- all seven licensed power reactors involved to date have or will be placed in SAFSTOR for 30 to 52 years

  • the lack of a Federal repository for spent fuel from licensed power reactors until after 2003

' the benefits of the SAFSTOR alternative in reducing radiation exposure levels for dismantling and reducing the volume of low level waste with a 30- to 50-year delay in dismantling

4. HOW THE TRANSFER OF REGULATORY RESPONSIBILITY WILL TAKE PLACE The timing of the transfer of licensing responsibilities will be scheduled to minimize adverse impact on the licensing process. Resources within NRR as well as NMSS would be needed to complete the NRC reviews of power reactor Decomissioning Plans. To terminate a power reactor license, a licensee must submit the following:

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cn application for a Possession-Only License proposed revisions to the Technical Specifications, Security Plan, and Emergency Flan

  • a Decomissioning Plan The NRC review of and decision on the Possession-Only License application would continue to be the responsibility of NRR, and would be handled by the facility Project Manager, with support from NMSS as necessary.

The NRC review and decision on the proposed changes to the TS, the Security Plan, and the Emergency Plan would continue to be the responsibility of NRR, and would be handled by the facility Project Manager with support from NMSS as necessary.

The change to the existing license termination process would occur with the review of the Decommissioning Plan. When the facility Decommissioning Plan is received by the NRR Project Manager, it will be assigned for action to NMSS.

NHSS will manage the review of the Decomissioning Plan and prepare the SER and EA. These will be provided to the NRR Project Manager for appropriate regulatory action.

With the issuance of the SER and EA, the amending and revising of other licensing documents (TS, Security Plan, and Emergency Plan), and the approval of the Decomissioning Plan, the regulatory responsibility for the facility will transfer to NMSS, and an NMSS Project Manager will be assigned. From that point on, all comunications with the licensee will be through the NMSS Project Manager. NMSS will exert regulatory control over the licensee's actions associated with implementation of the Decomissioning Plan, and will terminate the license when the decommissioning activities are successfully completed.

After the Decomissioning Plan has been approved, power reactor decomissioning activities will be directed through NMSS. Decisions associated with the review, approval, and implementation of each power reactor Decomissioning Plan and Decomissioning Funding Plan will be made by the Director of NMSS or the Director's designated representative, in coordination with and with the concurrence of the Director of NRR.

The actual transfer will require . transition period for planning, organizing, and staffing in NMSS.

The initial planning for the transfer of this regulatory responsibility (events and schedules) will be done in the next few weeks, timed to support the FY 1990 budget request. This initial 91anning will be structured to address:

' ensuring that the regulatory framework that supports this transfer (regulations, regulatory guidance, etc.) is provided in a timely manner. This will include actions and schedules for modifying the regulations, existing regulatory guides, standard review plans, i and staff positions and the development of additional 'guidance if  :

needed ensuring that the ability to carry out this responsibility is provided, inclading the trained staff possessing the required expertise ensuring that the total power reac;or decomissioning workload is identified Because of the long lead time required to conduct these actions, work on them will begin imediately to ensure that the NRC is in a position to take tbely regulatory actions on decomissioning. The proposed NMSS organization for carrying out this responsibility will also be addressed in the FY 1990 budget request. The overall approach will be to make maximum use of the existing Agency organizational structure with the addition of a central, clearly identifiable decomissioning management organization established in NMSS. The proposed organization will be consistent with the organizational requirements that are being identified as necessary to carry out the development and execution of NRC's integrated requirements for decomissioning (see page VI.23 of the Five-Year Plan).

The staffing requirements associated with transferring this regulatory l responsibility will be identified in the assessment of the knowledge, skills, and abilities needed for reactor decomissioning that is under way. This assessment will consider the decomissioning regulatory actions that have been done in the past, as well as "costing out" the Standard Review Plan in parallel with its revision. The transfer of regulatory responsibility fc power reactor decomissiening from NRR to NMSS would involve at the most one FTE based on a review of data from the NRC Manpower System records.- Staff manpower expenditure data for 1985, 1986, and 1987 show an average of 1039 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.953395e-4 months <br /> per year for PM time and 1062 hours0.0123 days <br />0.295 hours <br />0.00176 weeks <br />4.04091e-4 months <br /> per year for reviewer time on power reacter decomissioning actions.

5. NON-POWER REACTORS j The transfer of regulatory responsibility for reactor decommissioning would not include non-power (research, test, or training) reactors. For the present non-power reactor decomissioning activities will remain in NRR and will be closely coordinated with NMSS. The staff contemplates that non-power reactor decomissioning responsibility will be transferred to NHSS at some future date. These facilities are a unique group of reactors; most belong to universities. It would seem, from an NRC standpoint, that decomissioning of these reactors would be most efficiently controlled by the Project Managers who 4

handle these reactors. These Project Managers are familiar with the reg-i ulations and decomissioning procedures that apply to these reactors and have i

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established contacts with the non-power reactor community. Licensees in this group usually want to decomission their facilities rapidly so that they can be used for other purposes. This rapid turn-around can be facilitated if the Project Manager expedites the action. -

Non-power reactors are a diverse group of small reactors in which there is generally no fuel on the site during decomissioning. The safety and en-vironmental concerns are considerably less than thosa associated with power reactors. For the decomissioning of most non-power reactors the licensees have chosen the DECON/ Dismantling alternative. The NRC actions involved are short term and primarily administrative because of the reduced safety and environmental reviews required.

Only minimal effort is required by the NRC Headquarters staff after the Decomissioning Plan for a non-power reactor is approved because the NRC Regicns handle the inspections to verify compliance with the Plan. After the facility is dismantlen the Region inspects the facility to verify com311ance with the criteria for release to unrestricted access. Af ter receiv' ng 'the Regional inspection report. NRC Headquarters issues the license termination order. Issuing the termination order and the associated termination of the indemnity agreement and notice to the Federal Register are largely admin-istrative actions, by NRC Headquarters, that follow established practices within NRR.

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REGULATORY PROCESS FOR REACTOR DECOPHISSIONING .

LICENSEE PROVIDES PROPOSED NRC ISSUE AMENDMENT NRC ' AMENDMENT 4

REVIEW TO POSSESSION-TO POSSESSION. -ONLY LICENSE

)NLY LICENSE WC tN0 POSED AMEND TS ALTERANTIVES NRC TS CHANGES SECURITY PLAN ' REVIEW ;

APPROVE SECURI1Y PLAN

-+ 'V EMERGENCY PLAN EMERGENCY PLAN SHORT TERM LICENSEE NRC NRC NRC DECON

> PERFORMS n 3 ,3p f TERMINATES PROPOSED ISSUE SER DECON ___ LICENSE NRC -

DECOPHISSIONING AND EA

REVIEW AMEND TS FOR PLAN ,,

DECOPNISSIONING  ;

APPROVE NRC DECOPHISSIONING gpg LICENSEE NRC ISSUE SER PLAN t '

SAFSTOR PROPOSED AND EA STORAGE REVIEW DECOM PLAN AMEND TS AS REQUIRED APPROVE DECON PLAN ENTOMB LONG TERM STORAGE - DECAY OF SHORT LIVED RADIONUCLIDES e

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3 .

l ENCLOSURE NO. 3 DRAFT SRP FOR REVIEWING DECOMMISSIONING PLANS

  • 13.7 *)ecemmissioning Plans Review Responsibilities Primary - Chemical Engineering Branch (ECEB)

Secondary - Radiation Protection Branch (PRPB)

Human Factors Assessment Branch (LHFB)

Policy Development & Technical Support Branch (PTSB) i Plant Systems Branch (SPLB)

Quality Assurance Branch (LQAB)

Regulatory Branch (NMSS/RB)

Safeguards Branch (RSGB)

Structural and Geosciences Branch (ESGB)

Emergency Preparedness Branch (PEPB) 1 At the license terminaticn stage of review, ECEB reviews the information in the licensee's application for the termination of a license and prepares the i

Safety Evaluation Report (SER) on the acceptability of the decommissioning I plan. For a facility that permanently ceases operation, consistent with 10

  • NOTE: After the decomssioning rule changes have been promulgated in final l form, appropriate conforming changes will be made to this DRAFT SRP.

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CFR 50.82 (Reference 1), an application must be made within two years following permanent cessation of operations, and in no case later than one  !

year prior to expiration of the operating license.

The ECEB review includes:

1. Reviewing the decomissioning plan to ascertain that its content is adecuate to determine that the facility can be decomissioned in a safe manner and that the facility and site will meet criteria for release for unrestricted j use. The decomissioning plan should contain a description of the decomissioning alternative selected, decomissioning organization and responsibilities, training program for licensee employees and contractor personnel, quality assurance program, radiation protection program including ensuring occupational radiation exposures are ALARA and health physics program, contractor assistance, cost estimate and availability of funds, facility status including facility operating history and current radiological status of facility, radioactive waste management including fuel disposal, radioactive waste processing, and radioactive waste disposal, decomissioning activities, tasks, and schedules, safeguards and security, technical and environmental specifications, safety analysis, accident analyses and proposed final radiation survey plan.

l l

2. Reviewing justification of decomissioning alternative selected. The alternatives are defined as follows:

I

l DECON is the alternative in which the equipment, structures, and portions of a facility and site containing radioactive contaminants are removed or decontaminated to a level that permit the property to be released for unrestricted use shortly after cessation of operations.

1 I

SAFSTOR ir the alternative in which the nuclear facility is placed and 1

maintained in such condition that the nuclear facility can be safely stored and subsequently decontaminated (deferred decontamination) to levels that i permit release for unrestricted use.

ENTOMB is the alternative in which radioactive contaminants are encased in a structurally long-lived material, such as concrete. The entombed structure is appropriately maintained and continued surveillance is carried out until the radioactivity decays to a level permitting unrestricted release of the property. This alternative would be allowable for nuclear facilities contaminated with relatively short-lived radionuclides such that all contaminants would decay to levels permissible for unrestricted use within a period of the order of 100 years.

3. Reviewing historical information on operational occurrences that could affect decommissioning safety. Records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site are examined to deternine areas where significant contamination remains or when contaminants may have spread to inaccessible areas, e.g.,

see page into porous materials such as concrete. Records identifying spilled i

or released nuclides, quantities, forms, and concentrations are reviewed.

Plant modifications are reviewed for locations of possible inaccessible contamination such as buried pipes.

4. The proposed changes to the plant Technical and Environmental Specifications are reviewed. Controls and limits on procedures and equipment as well as equipment to protect occupational and public health and safety during decommissioning are received. These controls and limits should be derived from an analysis of the health and safety and environmental assessment of decomissioning the facility. Limits selected for a commitment to action are

. reviewed, l

A secondary review is performed by the following branches: ,

l The Radiological Protection Branch (PRPB) reviews under SRP Sections 12.1 and 12.5 the radiation protection and health physics program to ensure the health I

and safety of the workers.

l The final radiation survey plan is reviewed to provide a basis for verifying that the facility, site, and the contiguous environment meet radioactivity levels that permit release for unrestricted use.

The Radiological Protection Branch (PRPB) reviews under SRP Sections 15.7.1, 15.7.2 and 15.7.3 the accident analysis of the decommissioning activities and tasks. This includes an assessment of the radiological consequences to the workers and general public and their environmental impact. The accidents

considered include: spent fuel handling accident, heavy load drop, spent fuel pool leakage, seismically inducted criticality and radwaste tank leakage.

The Human Factors Assessment Branch (LHFB) reviews under SRP Section 13.1.1, 13.1.3, 13.2 the decommissioning organization and responsibilities as tell as experience and the training program. This includes training program description, administration, and records. LHFB reviews the scope of work to be accomplished by each contractor, the administrative control systems to be used to ensure adequate health and a protection, and the experience of the contractor.

The Policy Development and Technical Support Branch (PTSB) reviews the certification that financial assurance for decommissioning will be provided in an amount which may be more but not less than the amount stated in 10 CFR 50.74 (Reference 2). For the SAFSTOR or ENTOMB mode of decomissioning, PTSB reviews the licensee's certification that reasonable assurants is provided that adequate funds will be available when needed to complete the decommissioning.

The Plant Systems Branch (SPLB) reviews the radioactive waste processing of gaseous, liquid, and solid radwaste under SRP 11.2, 11.3 and 11.4. SPLB reviews the radioactivity concentrations, volumes of radwaste, and systens l l

used to process the radwaste.

As-built drawings and modifications are reviewed to select the best method of radwaste disposal or to facilitate activities to achieve the design objectives.

Equipment and ventilation system design capacities are reviewed to evaluate radioactive effluents processing capabilities to meet the design objectives.

Special provisions to facilitate decommissioning activities are reviewed for conformance with the guidance of Regulatory Guide 1.143 (Reference 3).

Radioactivity in effluents to unrestricted areas are reviewed to meet requirements of 10 CFR 20.106 (Reference 4) and GDC 60 (Reference 5).

The Quality Assurance Branch (LQAB) reviews the proposed Quality Assurance

- (QA) Program for decommissioning activities under SRP Sections 13.1.1, 13.1.3, 13.2, 13.2.2, 13.4, 13.5, 13.5.1 and 13.5.2. LQAB reviews the equipment, shielding and procedures that are subject to the QA controls and audits.

The Regulatory Branch (RB), NMSS, reviews plans for solid radioactive waste disposal at shallow land burial facilities. RB/NMSS reviews procedurest processes, and systems used for disposal of radwaste.

The Safeguards Branch (RSGB) reviews the proposed changes to the NRC approved physical security plan and material control and accountability plan, when requested under SRP 13.6.

The Emergency Preparedness Branch (PEPB) reviews emergency facility description, organizational control of emergencies, and corrective actions that will be carried out in the event of a radiological emergency when the plant is in a SAFSTOR mode when spent fuel is stored onsite per 10 CFR 50.47(b),

(Reference 6) Appendix E to 10 CFR 50 (Reference 7) and NUREG-0654/ FEMA-REP-1 (Reference 8).

The Structural and Geosciences Branch (ESGB) reviews the supplement to the Environmental Report (separate document from Decommissioning Plan) which reflects any new information or significant environmental change associated with the proposed'decomissioning activity per 10 CFR 51.53(b) (Reference 9).

Changes to the plant Technical and Environmental Specifications for decomissioning are reviewed by the cognizant review branches. Controls and limits on decomissioring procedures and equipment to protect occupational and

- public health and safety are reviewed per 10 CFR 50.82(b)(2) (Reference 1).

For those areas of review identified above as being reviewed as. part of ti.!

primary review responsibility of other branches, the accepcance criteria necessary 4 r the review and their methods of application are contained in the  !

referenced SRP section of the corresponding primary branch.

1 II. Acceptance Criteria j ECEB acceptance criteria are based on meeting the relevant requirements of the following regulations:

la. 10 CFR 50.82 (Reference 1) as it relates to the licensee's proposed decomissioning plan,

b. Draft Regulatory Guide, "Format and Content for Nuclear Reactor Decom-missioning Plans" (Reference 10) as it relates to guidance in identifying

l the information needed in a decomissioning plan required by 10 CFR 50.82 (Reference 1).

2. 10 CFR 50.82 (Reference 1), as it relates to application for termination of licenses. Each application for termination of license must be accompanied, or preceded, by a proposed decomissioning plan which includes the choice of the alternative for decommissioning (DECON, SAFSTOR, or ENTOMB) with a description of the activities involved.

. l

3. 10 CFR 50.54 (Reference 11) as it relates to recordkeeping of infctmation important to the safe and ef, active decommissioning of the facility.
4. 10 CFR 50.82 (Reference 1) as it relates to controls and limits on procedures and equipment to protect occupational and public health and safety. .

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5. 10 CFR 50.82 (Reference 1) as it relates to the terminal radiation survey and associated documentation that demonstrates that the facility and site are l suitable for release for unrestricted use. Regulatory Guide 1.86 (Reference
14) provides guidance on methods and procedures considered applicable by the Commission for the termination of reactor licenses. Table I of this Regulatory Guide provides acceptable contamination levels for release for unrestricted use necessary for license termination. Consistent with Regulat'ry Guide 1.86, limits of Sp R/hr above natural background as measured w - y w ,

.g.

at one meter from the contaminated surface, or 10 mR/yr as a total dose to the individual exposed to the contamination are acceptable.

6. 10 CFR 50.33 (Reference 12) as it relates to the licensee providing reasonable assurance that adequate funds be available when needed for decommissioning. Draft Regulatory Guide (Reference 13) provides financial assurance guidance for decommission 1r g. The licensee may submit certification that financial assurance for decommissioning will be provided in an amount

. which may be more but not less than the amount stated in 10 CFR 50.74 (Reference 2) annually for inflation at a rate equal to that stated in 10 CFR 50.74.

Financial assurance may be provided by the following methods (draft Regulatory Guide (Reference 13) and (10 CFR 50.74 (Reference (2)):

prepayment deposit prior to the start of operation into an acecJnt segregated from licensee assets and outside the licensee's administrative control of cash or liquid assets such that the amount of funds would be sufficient to pay decommissioning costs. Prepayment may be in the form of a trust, escrow account, government fund, certificate of deposit, or deposit of government securities.

external sinking fund - fund established and maintained by setting funds aside periodically, in an account segregated from licensee assets and

l l

outside the licensee's administrative control in which the total amount l of funds would be sufficient to pay decommissioning costs at the time termination of operation is expected. An external sinking fund may be in the form of a trust, escrow account, governrent fund, certificate of deposit, or deposit of government securities, a surety method, insurance, or other guarantee method. These methods guarantee that decommissioning costs will be paid should the licensee default. A surety method may be in the form of a surety bond, letter of credit, or line of credit.

Any surety method or insurance used to provide financial insurance for decommissioning must contain the following conditions: 1

1. The surety method or insurance must be open-ended or, if written for specified term, such as five years, must be renewed automatically unless 90 days or more prior to the renewal date, the issuer notifies the Commission, the beneficiary, and the licensee of its intention not to renew. The surety or insurance must also provide that the full face amount shall be automatically paid to the beneficiary prior to the expiration without proof of forfeiture if the licensee fails to provide a replacenent acceptable to the Commission within 30 days after receipt of notification of cancellation.
2. The surety or insurance must be payable to a trust established for decommissioning costs. The trustee and trust m'Jst be acceptable to the Commission. An acceptable trustee includes an appropriate State or Federal government agency or an entity which has the authority to act as a trustee and whose trust operations are regulated and examined by a Federal or State agency.
3. The surety method or insurance must remain in effect until the Commission has terminated the license.  :

l

4. 10 CFR 50.54 (Reference 11) as it relates to conditions of licenses that each holder of an operating license issued on or after (insert a date 2 years after the effective date of the final rule) shall provide financial assurance for decommissioning in accordance with an approved decommissioning funding plan or by means of a certification as provided in 10 CFR 50.33(k)(1) (Reference 12).

Upon approval of a decommissioning funding plan by the Commission, the licensee shall implement procedures for providing financial assurance for decommissioning in accordance with the plan.

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l

5. Regulatory Guide 1.143, (Reference 3) as it relates to special provisions to facilitate decomissioning activities.

I

6. 10 CFR 20.106 (Reference 4) as it relates to radioactivity in liquid 1

and gaseous effluents during the decomissioning operations.  ;

1 1

7. General Design Criterion 60 (Reference 5) as it relates to radioactive waste managenent systems being designed to control

- releases of radioactive materials to the environment, l

III. Review Procedures l

l

1. In the ECEB review of the decomissioning plan, the content of the  !

l plan provided by the licensee is reviewed to determine that the l licensee's facility can be decomissioned in a safe manner. Plans for a final radiation survey should provide a high degree of assurance that residual radioactive contamination levels will meet the criteria for release for unrestricted use that is provided in Regulatory Guide 1.86 (Reference 14). Additional acceptance criteria is provided in subsection II.5 of this SRP section.

1

2. The ECEB review of the decomissioning plan will encompass an evaluation of the justification of the decommissioning alternative (DECON,SAFSTOR, ENTOMB).

l

3. ECEB reviews the historical information on operational occurrences that could adversely affect decomissioning safety and should be ,

i considered when preparing plans and procedures for decomissioning activities.

I

4. ECEB reviews the proposed changes to the plant Technical and Environmental Specifications for decommissioning if either SAFSTOR or ENTOMB are selected. Included in the review are provisions for Technical Specifications involving principal design features, operating limits and requirements for decommissioning l activities which have an effect on plant safety.  !

IV. Evaluation Findings ECEB verifies that sufficient information has been provided and that the review is adequate to support conclusions of the following type, to be included in the staff's safety evaluation report:

The Staff concludes that the decomissioning plan demonstrates that the decomissioning will be performed in accordance with regulations (10 CFR 50.33 (Reference 12), 10 CFR 50.82 (Reference 1) and 10 CFR 51.53 (Reference 9): This conclusion is based on the following:

1. The licensee has conformed to the guidance provided in draft Regulatory Guide (Reference 10) in providing a decommissioning plan

with the information needed by the staff to make a determination that the facility can be decommissioned in a safe manner. The plans for a final radiation survey provides a high degree of assurance that residual radioactive contamination levels meets the criteria for unrestricted use provided in Regulatory Guide 1.86 (Reference 14).

2. The licensee has justified an acceptable decommissioning alternative in accordance with 10 CFR 50.82(b)(1). (Reference 1)
3. The licensee has met the requirements of 10 CFR 50.54(dd)(1) and (2)

(Reference 11) by providing historical information on operational occurrences that could affect decommissioning safety. Plant modifications were reviewed for locations of possible inaccessible contamination. Facility, equipment, and site were examined to determine areas where significant contamination remains or where contamine7ts may have spread to inaccessible areas.

4. The licensee has met the requirements of 10 CFR 50.82(b)(2)

(Reference 1) in providing controls and limits on procedures and equipment to protect occupational and public health and safety during decommissioning. Proposed Technical and Environmental Specifications were reviewed and were found acceptable.

)

5. The licensee has met the requirements of 10 CFR 50.82(b)(2) and (e) l (Reference 1) in providing a radiation protection and health physics program to ensure the health and safety of the workers and public. l I
6. The licensee has met the requirements of 10 CFR 50.82(e) (Reference 1) by providing acceptable analyses of potential accidents which could occur during decommissioning. l 1

1 l

- 7. The licensee has met the requircments of 10 CFR 50.82(e) (Reference 1) by providing a decommissioning organization and training program i

that will ensure worker and general public safety.

8. The licensee has met the requirements of 10 CFR 50.33 (Reference 12) and 10 CFR 50.82 (Reference 1) by providing certification of a financial plan with reasonable assurance that adequate funds will be available when needed to complete decommissioning.
9. The licensee has met the requirements of 10 CFR 50.82(e) (Reference 1) by providing a radioactive waste processing program that will ensure worker and general public safety.
10. The licensee has provided as-built and modification drawings which were reviewed by the Staff to determine the best method of disposal and/or to facilitate decommissioning activities.

I i

11. The licensee equipment and ventilation system design capacities meet the design objectives for radioactive effluent processing capabilities.

1 1

12. The licensee has met the criteria as set forth in Regulatory Guide l 1

1.143 (Reference 3) regarding special provisions to facilitate l l

decomissioning activities. I

13. The licensee has met the requirements of 10 CFR 20.106 (Reference 4)

I regarding radioactivity in effluents to unrestricted areas. j 1

14. The licensee has met General Design Criterion 60 of Appendix A to 10 CFR Part 50 (Reference 5) relative to the design of radioactive l waste management systems to control releases of radioactive material to the environment.
15. The licensee has met the requirements of 10 CFR 50.82(b)(5)

(Reference 1) by providing a Quality Assurance program on decomissioning equipment, shielding, and procedures to protect l

occupational and public health and safety.

16. The licensee has met the requirements of 10 CFR 50.82(e) (Reference 1) by providing adequate procedures, processes, and systems used for disposal of decommissioning radwaste.
17. The licensee has met the requirements of 10 CFR 50.82(e) (Referencc
1) by providing a physical security plan that will ensure occupational health and safety.
18. The licensee's Emergency Plan when the plant is in SAFSTOR when spent fuel is stored onsite in the event of a radiological emergency meets the applicable requirements of 10 CFR 50.47(b) (Reference 6),

Appendix E to 10 CFR Part 50 (Reference 7) and guidance criteria of NUREG-0654) FEMA-REP-1 (Reference 8).

V. Irmlementation The following is intended to provide guidance to applicants and licensees regarding the NRC staff's plans for using this SRP section.

Except in those cases in which the applicant proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, the method described herein will be used by the staff in its evaluation of conformance with Commission regulations.

Implementation schedules for conformance to parts of the method discussed herein are contained in the referenced regulatory guides.

IV. References

1. Proposed 10 CFR 50.82*, "Application for termination of licenses."
2. Proposed 10 CFR 50.74*, "Reporting and Recordkeeping for Decommissioning Planning.
3. Regulatory Guide 1.143, "Design Guidance for Radioactive Waste Management

. Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants."

4. 10 CFR 20.106, "Radioactivity in Effluent to Unrestricted Areas."
5. 10 CFR Part 50, Appendix A, General Design Critericn 60, "Control of releases of radioactive materials to the environment."
6. 10 CFR 50.47, "Emergency Plans."
7. 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."
8. NUREG-0654/ FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, November 1980.

1

9. Proposed 10 CFR 51.53*, "Supplement to Environmental Report."  ;
10. Draft Regulatory Guide, "Format and Content for Nuclear Reactor l Decomissioning Plans." Working Paper B, January 1985.  ;
11. Proposed 10 CFR 50.54*, "Conditions of licenses."
12. Proposed 10 CFR 50.33*, "Contents of Applications; general information." I
13. Draft Regulatory Guide. "Assuring the Availability of Funds for  !

Decomissioning Nuclear Reactors," February 1985.

l

14. Regulatory Guide 1.86, "Termination of Operating Licenses for Nuclear Reactors."

l l

  • NOTE: These references do nofreflect the final decomissioning rule l changes now before the Comission. Appropriate conforming changes will be made after the decomissioning rule changes have been promulgated.

i l

J

l I

l l

ENCLOSURE NO. 4 l

1 i

KNOWLEDGE, SKILLS, AND ABILITIES l FOR REACTOR DECOMMISSIONING ACTIONS l l

l l

SKILLS KNOWLEDGE ABILITIES Project Management Health Physics, Coordinate overall Engineering, Environ- review / program mental Science Decontamination Chemical Engineering, Review proposed l Chemistry, Materials Decontamination '

l Engineering Plan to ensure pro-cess effectiveness Waste Processing Chemical Engineering, Review solid, liquid j Nuclear Engineering and gaseous waste I treatment systems and storage plans Safety / Accident / 3ealth Physics, Review effluent re-Effluent Analysis Nuclear Engineering leases, accident scenarios, final survey data to ensure occupational and pub- i lic exposures are within regulatory i limits Transportation Mechanical Engineer- Evaluate transpor-ing, Nuclear Engineer- tation risks, unique ing, Health Physics transportation prob-lems, packaging plans, spent fuel transport, criticality Waste Classification Health Physics, Nuc- Evaluate plans to lear Engineering develop scaling fac-tors, waste sampling, methods for deter-mining nuclide inven-tories

2 SKILLS KNOWLEDGE ABILITIES Waste Form Chemical Engineering, Evaluate plans to Chemistry, Nuclear qualify solidifica-Engineering, Materials tion processes to Engineering meet 10 CFR Part 61 requirements, evalu-ate proposed waste forms for disposal site acceptability Quality Assurance Quality Assurance Review QA plans Engineering Disposal Site Operations Health Physics, Civil Evaluate disposal Engineering, Mechan- site impacts for ical Engineering handiing unique wastes Training Education Review training programs, admin-istration and recordkeeping Physical Security Safeguards Review changes to Physical Security Plan Emergency Preparedness Emergency Planning Review plans for control of acci-dents Environmental Environmental Engi- Review plans to neering, Economics minimize environ-mental impacts NOTE: The range of the above knowledge, skills, and abilities are represented within HMSS. However, these resources have not been dedicated to decommissioning activities and would need to te considereo in the FY90 budget process.

RAR 21 Ign MEMORANDUM FOR: Victor Stello, Jr.

Executive Director for Operations FRON: Thomas E. Murley, Director Office of Nuclear Reactor Regulation Hugh L. Thompson, Jr., Director Office of Nuclear Materials Safety and Safeguards

SUBJECT:

TRANSFER OF REGULATORY RESPONSIBILITY FOR REACTOR DECOMJilSSIONING FROM NRR T0 NHSS The enclosed paper responds to your September 1, 1987 request for a description of the actions and schedule necessary for transfer of the regulatory responsibility for reactor decounissioning from NRR to NMSS.

Originni signed by, Thom1IsEPN0Eli),YDirector Office of Nuclear Reactor Regulation p n Director Office of Nuclear Materials Safety and Safeguards

Enclosure:

As stated DISTRIBUTION: S7F203

~; Centralfile 9 F. Miraglia S. Bahadur/MNSS G. Beckjord/ REG NRC'a local PDRs D. Crutchfield R. Bernero/NMSS R. Cunningham/NMSS ED0 Reading J. Heltemes, AE0D T. Johnson /NMSS L. Rouse /NHSS PDSNP Reading P. Erickson M. Kearney/NMSSS J. Roberts /NHSS T. Rehm T. Murley L. Rubenstein S. Treby M. Knapp/NMSS H. Thompson /NHSS b I%uA>u q M fhbb O[

[

J. Sniezek J. Mapes Regional Administrators 0 t

  1. q'<l 3,o
  • See previous concurrence NRR/PDSNP* NRR/PDSNP* NRR/0GC* *D/DRSP *NRR/ADP W f

PErickson. LRubenstein JMapes DCrutchfield FMiraglia Wu y 02/25/88 02/25/88 02/25/88 03/07/88 03/09/8" 03 88 ARM /PPMB* NHSS/LLVM* NiiSS/LLMi* NMSS/LLWM* NHSS/LLWM*hMSS/IMNS*

ATHOMAS SBahadur TJohnson MXearney liKnapp JRoberts 02/25/88 02/25/88 02/25/88 02/25/88 03/2/88 02/25/88 NMSS/IMNS* NMSS/IMNS* NMSS/ NMSS/[hI LRouse RCunningham RBern ro HThomtpson M 03/02/88 02/03/88 03/ 3 /88 03/3 /88

  • See preYious Concurrence

met 10RANDUM FOR: Victor Stello, Jr.

Executive Director for Operations FROM: Thomas E. flurley, Director Office of Nuclear Reactor Regulation Hugh L. Thompson, Jr., Director Office of Nuclear Materials Safety and Safeguards SUBJECT

  • TRANSFER OF REGULATORY RESPONSIBILITY FOR REACTOR DECOMMISSIONING FROM NRR TO NMSS /

/

TheenclosedpaperrespondstoyourSeptember1/1987requestfora

/

description of the actions and schedule necessar for transfer of the regulatory responsibility for reactor decommissioning from NRR to NMSS.

/

Thom/as E. Murley, Director 0 fice of Nuclear Reactors Regulation Hugh L. Thompson, Jr., Director Office of Nuclear Materials Safety and Safeguards

Enclosure:

As stated DISTRIBUTION:

Central File F. Miraglia S. Bahadur/MNSS G. Beckjord/ REG NRC & Local PDRs D.Crutchfield R. Bernero/NMSS R. Cunningham/NMSS EDO Reading J. Heltemes, AEOD T. Johnson /NMSS L. Rouse /NMSS PDSNP Reading P. Erick' son M. Kearney/NMSSS J. Roberts /NMSS T. Rehm L. Rube'nstein M. Knapp/NMSS T. Murley S. Treby H. Thompson /NMSS J. Sniezek J.FJapes Regional Administrators NRR/PDSNP*

Peri kson.

NRR/PDS P*

LRubenstein NRR/0GC*

JMapes Mg DCrutchfield I

NR FM NRR glia TMurley 02/k>/88 0246/88 02/$/88 03/]/88 03/ /88 03/ /88 4 ARM /PPMB* NMSS/LLWM* NHSS/LLWM* NMSS/LLWM* NMSS/LLWM*NMSS/IMNS*

ATHOMAS SBahadur TJohnson MXearney MXnapp JRoberts 02/ /88 02/ /88 02/ /88 02/ /88 02/ /88 02/ /88 NMSS/IMNS* NMSS/IMNS* NMSS/h NMSS/

LRouse RCunningham RBernero HThomspson 02/ /88 -

02/ /88 03/3 /88 03/3/88

  • See previous concurrence

MEMORANDUM FOR: Victor Stello, Jr Executive Director for Operations FROM: Thomas E. Hurley, Director '

Office of Nuclear Reacter Regulation l Hugh Thompson, Director Office of Nuclear Materials Safety and Safeguards

SUBJECT:

TRANSFER OF REGULATORY RESPONSIBILITY FOR REACTOR DECOPHISSIONING FROM NRR TO NMSS )

1

The enclosed paper responds to your September 1, 1987 request for a description i

of the actions and schedule necessary for transfer of the regulatory re-1 I

sponsibility for reactor decommissioning from NRR to NMSS.

Thomas E. Murley, Director Office of Nuclear Reactors Regulation Hugh L. Thompson, Director Office of Nuclear Materials Safety and

Enclosure:

As stated DISTRIBUTION:

Central File F. Miraglia S. Bahadur/MNSS G. Beckjord/ PEG NRC & Local PDRs D. Crutchfield R. Bernero/NMSS R. Cunningham/NMSS EDO Reading J. Heltemes, AEOD T. Johnson /NMSS L. Rouse /NMSS PDSNP Reading P. Erickson M. Kearney/NMSSS J. Roberts /NM$S T. Rehm L. Ruberstein fl. Knapp/NMSS 3,4 e k 5/New T. Murley S. Treby H. Thompson /NHSS J. Sniezek J. Mapes Regional Administrators g kachuf:rNRR/DRSP NRR/PbSNP t P RR/0GC b ' NRR/ADP NRR PErickson L instein DCrutchfield FMiraglia TMurley 02p;/88 02/as/88 JMape/s/572Efy" 02/E 88 02/ /88 02/ /88 02/ /88

,f

/

ARM /PPMB,p NMSS/LLWM NMSS NM NMSSh NM $S ATHOMAS) SBahadur TJo MK Oy MKnapp J berts 02/6/ 02/25/88 02 02 88 f/q]B8 02/M788

/

NMS NS d@iSZIMN NMSS/ NMSS/ l Ljouse RCunnin am RBernero HThomspson p

08/2488 02tp'/88, 02/ /88 02/ /88

- .w.

I i

1

ENCLOSURE N0. 1 m arov

  1. ja UNITED STATES
  • ,h NUCLEAR REGULATORY COMMISSION W A$HINGTON, D. C. 20655

, [

5 l SEP 0119fI k...../

MEMORANDUM FOR:

Eric S. Beckjord, Director Office of Nuclear Regulatory Research William G. Mcdonald, Director Office of Administration and Resources Management d homas E. Murley, Director Office of Nuclear Reactor Regulation Hugh L. Thompson, Jr. , Director Office of Nuclear Material Safety and Safeguards FROM:

Victor Stello, Jr.

Executive Director for Operations

SUBJECT:

ACTIONS RESULTING FROM REVIEW 0F ABBREVIATED FY 1989-1992 FIVE-YEAR PLAN As a result of my review of the Abbreviated FY 1989-1992 Five-Year Plan, the following actions should be taken:

1. The Office of Nuclear Material Safety and Safeguards should submit a Commission paper with options and recommendations for implemer ting a program to improve regulatory oversight of medical licensees to me by January 1988.
2. The Office of Nuclear Material ar.d Safety Safeguards in conjunction with the Office of Nuclear Regulatory Research should submit a report on the planned funding level for the FFRDC in FY 1988-1989 to me by September 1987.
3. The Office of Nuclear Reactor Regulation in conjunction with the Office of Nuclear Regulatory Research should submit a paper to me by January 1988, which describes how the integrated safety assessment approach used in the ISAP pilot program will be incorporated into NRC's program for regulating operating reactors.
4. The Office of Nuclear Reactor Regulation in conjunction with the Office of Nuclear Material Safety and Safeguards should submit a paper to me by February 1988 which describes the actions and schedule NR decommissioning the regulatory responsibility would be transferred from NRR to NHSS.

8 0 C,' Ai $3  ? .tg.

l

- Multiple Addressees 2 l

The Office of Administration and Resources Management should conduct a  ;

5.

comprehensive evaluation of all NRC ADP timesharing to determine alter- (

natives and recommendations to reduce data processing cost. These l recommendations should be provided to me by January 1988.

6. The'0ffice of Administration and Resources Management should develop a comprehensive plan by May 1988 to replace NRC's existing IBM 5520 office automation equipment. Implementation would proceed subsequent to receipt of funding, probably beginning in FY 1990.

V'-tor St 1 o, Jr.

Executive Director for Operations cc: R. Scroggins, ARM /FMC l

i

- - _- .

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