ML20198A402

Forwards Comments on ANSI/ANS-15-10 Re Decommissioning of Research Reactors with Purpose of Suggesting Course of Action for Next Maint on Std

ML20198A402
Person / Time
Site:	University of California-Davis
Issue date:	12/11/1998
From:	Alexander Adams NRC (Affiliation Not Assigned)
To:	Richards W AIR FORCE, DEPT. OF
References
NUDOCS 9812160256
Download: ML20198A402 (5)

Text

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, December 11, 1998 Dr. Wade J. Richards Chairman, ANS-15 SM-ALC/LIS 5335 Price Avenue McClellan AFB, CA 95652-2504

SUBJECT:

COMMENTS ON ANSl/ANS-15.10 As requested by the ANS-15 standards committee, I have reviewed ANSI /ANS-15.10,

" Decommissioning of Research Reactors," with the purpose of suggesting a course of action for the next maintenance on the standard. I suggest to the committee that a working group be formed to revise the standard. There have been significant changes to the NRC criteria for release of facilities for unrestricted use and termination of license. The application of the new regulations could be complex and the guidance of a standard valuable to NRC licensed non-power reactors.

I have provided some additional comments in the enclosure to this letter, if you have any questions please contact me at 301-415-1127.

Sincerely, original Signed By:

Alexander Adams, Sr. Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-607

Enclosure:

See next page cc w/ enclosure: See next page DISTRIBUTION:

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December 11, 1998 Dr. Wade J. Richards Chairman, ANS-15 SM-ALC/LIS 5335 Price Avenue McClellan AFB, CA 95652-2504

SUBJECT:

COMMENTS ON ANSI /ANS-15.10 As requested by the ANS-15 standards committee, I have reviewed ANSI /ANS-15.10,

" Decommissioning of Research Reactors," with the purpose of suggesting a course of action for the next maintenance on the standard. I suggest to the committee that a working group be formed to revise the standard. There have been significant changes to the NRC criteria for release of facilities for unrestricted use and termination of license. The application of the new l regulations could be complex and the guidance of a standard valuable to NRC licensed non- '

power reactors.

i I have provided some additional comments in the enclosure to this letter. If you have any questions please contact me at 301-415-1127.

Sincerely,

]

l Original Signed By:

Alexander Adams, Sr. Project Manager l Non-Power Reactors and Decommissioning I Project Directorate l Division of Reactor Program Management l Office of Nuclear Reactor Regulation l

l Docket No. 50-607 l

Enclosure:

See next page cc w/ enclosure: See next page DISIRIBUILOR HARD_ COP _Y EMAILCO2X l Docket File 50-607 EHylton CBassett MMendonca PUBLIC TBurdick PDND r/f PDoyle DMatthews TDragoun l JRoe WEresian AAdams SHolmes SWeiss Pisaac 1 f PDN Iss /kl l

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666 4 001 December 11, 1998 Dr. Wade J. Richards Chairman, ANS-15 SM-ALC/LIS 5??5 Price Avenue McGiellan AFB, CA 95652-2504

SUBJECT:

COMMENTS ON ANSI /ANS-15.10 As requested by the ANS-15 standards committee, I have reviewed ANSI /ANS-15.10,

" Decommissioning of Research Reactors,"with the purpose of suggesting a course of action for the next maintenance on the standard. I suggest to the committee that a working group be formed to revise the standard. There have been significant changes to the NRC criteria for release of facilities for unrestricted use and termination oflicense. The application of the new '

regulations could be complex and the guidance of a standard valuable to NRC licensed non-power reactors.

I have provided some additional comments in the enclosure to this letter. If you have any questions please contact me at 301-415-1127.

Sincerely, M .

Alexander Adams, Sr. oje anager Non-Power Reactors an ecommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-607

Enclosure:

See next page cc w/ enclosure: See next page l

i

I McClellan AFB TRIGA REACTOR Docket No. 50-607 l

CC:

Dr. Wade J. Richards l SM-ALC/TI-1 5335 Price Avenue, Bldg. 258 l McClellan AFB, California 95652-2504 Col. Robert Capell HQ AFMC/SGC 4225 Logistics Avenue, Suite 23 Wright-Patterson AFB, Ohio 45433-5762 Lt. Col. Catherine Zeringue HQ AFSC/ SEW 9570 Avenue G, Building 24499 Kirtland AFB, New Mexico 87117-5670 Test, Research, and Training Reactor Newsletter 202 Nuclear Sciences Center University of Florida Gainesville, Florida 32611 l

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COMMENTS ON ANSI /ANS-15.10-1994 AMERICAN NATIONAL STANDARD FOR DECOMMISSIONING OF RESEARCH REACTORS

1. Foreword. The foreword should be updated to capture the current status of NRC rulemaking activities. Rulemaking on release criteria and minor changes to the regulatory process for the decommissioning of non-power reactors are complete. The Commission staff has undertaken an ehort to develop criteria for clearance of equipment and materials having residual radioactivity.

2. Definitions. Some definitions used in the standard differ from those in 10 CFR Parts 20 and 50. The definition of decommissioning reflects that some facilities are decommissioning before the end of their usefullives. The concept of unrestricted use only extends to sites and structures and equipment left on site fcr license termination. It does not extend to waste disposal or reuse of equipment.

3. Section 3.1. A facility may be put into a SAFSTOR-like condition with fuel on site. Also equipment and systems should be maintained that would be needed for future decommissioning activities unless replacement of those systems is anticipated.

4. Section 4.1.7. A change has been made to allow non-profit organizations to self guarantee decommissioning funding.

5. Section 4.2.2. Preliminary decommissioning plans should be submitted twe years prior to the projected end of operations,

6. Section 4.3.4. The list refers to a summary of the environmental assessment. The environmental assessment is written by the regulator. The applicant submits an environmental report.

7. Section 5. Regulations for radiological criteria for license termination (10 CFR 20.1401 -

1406) have been issued. This regulation replaces Regulatory Guide 1.86 and guidance on radiation fields for release for unrestricted use. While the requirements of the rule are simple, the steps to show compliance can be complex involving pathways analysis, ALARA determinations, and statistical evaluations to show the release limits have been met. Consideration should be given to determining if guidance could be developed to assist applicants through the release process.

8. Section 6. Surveillance requirements should also be in place during decommissioning activities.

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