ML20198Q102

Working Paper Entitled, Demonstrating Compliance W/Radiological Criteria for Decommissioning Section C.4: Regulatory Position:Alternative Position, for Future Regulatory Guide

ML20198Q102
Person / Time
Issue date:	01/06/1998
From:	NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
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ML20198Q077	List: ML20198Q072 ML20198Q084 ML20198Q102 ML20198Q110
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NUDOCS 9801220344
Download: ML20198Q102 (3)

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DEMONSTRATING COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR DECOMM.ISSIONING SECTION C.4: REGULATORY POSITION:

AlsTERNATIVE CRITERIA FOR LICENSE TERMINATION Omce of Nuclear Regulatory itesearch U. S. Nuclear Regulatory Commission DISCLAIMER This working paper is being developed for a future NRC Regulatory Guide,

" Demonstrating Compliance with the Radiological Criteria for Decommissioning." It is a working draft only and is subject to extensive change. Its purpose is to obtain comments from NRC staff and others. It has received only limited NRC staff review and no NRC i

management approval.

3.4 Alternate criteria for license tennination For a few sites with unique decommissioning problems, the NRC may terminate a license under 10 CFR 20.1404 using an alternate dose criterion greater than 25 millirems (0.25 millisievert) per year up to a maximum of 100 millirems (1 millisievert) per year from all manmade sources except medical.

Ilowever, the NRC expects to do this only under very rare and unusual circumstances.

9001D20344 900112 PDR STPRO ESGOH I or3 PDR 01/06/98 12:28:39 i

i-hupd/techconf. tint govhaderPmodc3 4.html http1/techconf,llnl gov /radcrPmodc3 4 html In order for the NRC to consider a licensee's request to terminate their license using the altetaate criteria option,10 CFR 20.1404(a) requires that the licensee meet all of the following reqmrements:

1. Pmvide assurance that public health and safety would continue to be protected, and that it is unlikely that the dose from all man made sources combined, other than medical, would be more than 100 millirems (1 millisievert) per year.

2. Employ, to the extent practical, restrictions on site use.

3. Redue: doses to Al ARA levels.

4. Submit a decommissioning plan or license tennination plan that indicates the intent to release the site under alternate criteria, includmg information on how advice ofindividuals and institutions in the community who may be affected by the decommissioning has been sought and addressed.

The use of alternate criteria to terminate a license requires the approval of the Commission after consideration of the NRC staffs recommendations that will address any comments provided by the Environmental Protection Agency and any public comments submitted.

3.4.1 Limit on dose from all man made sources combined The licensee should submit a complete and comprehensive analysis of man made sources of radiation exposure, other than medical. The man made sources of radiation that should be included include the following: (1) lonie.ini; radiation from licensed or regulated byproduct, source, or special material, but excluding medical exposures received by patients,(2) ionizing radiation from x ray machines, accelerators, and similar electronic devices producing lonizing radiation, but excluding medical exposures received by patients,(3) ionizing radiation fmm naturally occurring radioactive materials that have been processed, concentrated, and purified, such as sealed sources containing radium or chemical compounds containing radium, and (4) ionizing radiatian from radioactive fallout from weapons testing.

Sources ofionizing radiation not included are: (1) ionizing radiation from natural background, (2) ionizing radiat' smm naturally occurring radioactivity found in building materials,(3) ionizing radiation from naturally occurring radioactivity svhose dose has been changed through some aspect of building design or construction, for example, naturally occurring radon in a building is not considered a man made source regardless of the way in which the design, construction, or operation of the building would affect the radon concentration, and (4) radiation exposure to patients from medical practices.

For radiation exposures that are not associated with the site, the dose to the average member of the critical group can be taken to be the dose to the average member of the U. S. poaulation. The analysis may use infomiation from sources such as NCRP Report 92 "Public Radiation 2xposure from Nuclear Power Generation in the United States," NCRP Report 93, "lonizing Radiation Exposure of the Population of the United States," and NCRP Report 95, " Radiation Exposure of the U. S. Population fmm Consumer Products and Miscellaneous Sources."

The analysis should include site-specific considerations, in general, the annual dose is calculated survey unit by-survey unit. The radiation dose from residual radioactivity in the survey unit should be added to the doses from other man made radiation exposure other than medical, The site specific sources should include the radiation exposure from other nearby sites using radioactive msterials, and radiation exposure from groundwater that has migrated from other areas with man-made sources of residual radioactivity.

This approach will allow the licensee to determine which survey units will be subject to the alternate criteria. The objective is for the area to be subject to the alternate criteria to be as small as possibic.

'llowever, in selecting the area to be released under the alternate criteria, the site should normally have only a single such area and the area should have fairly regular (not gerrymandered) boundaries. This may meen that the area subject to the altemate criteria may include some areas that did not have to be 01/0&98 12:28:39 2 of 3 n

http/hechconf lini gov /radcri' mode)-4.html http/Accheonf.llnl gov /raderi'modc3-4.html released under the alternate criteria.

3.4.2 Practical restrictions on site use 1

The licensee must employ restrictions on site use to the extent practical (10 CFR 20.1404(a)(2)).

l Restrictions that are practical usually means simple deed restrictions that do not require periodic maintenance or financial assurance. Deed restrictions are usually practical because they are relatively easy and inexpensive to impose and do not normally require active control or maintenance. Thus, simple deed restrictions should nonnally be used to meet this requirement for practical restrictions. Therefore, sites released under alternate criteria would gen rally be released under restricted conditions. Examples of simple deed restrictions that are normally practical and which should be considered when appropriate inch.de prohibitions on: residences, farming, using ground water for irrigation, and using ground water for drinking water.

3.4.3 information to be submitted in the decommissionine plan or license termination plan in addition to the information required for release under resti,1ed conditions, release under attemate criteria should include the following additional information: (1) an analysis to demonstrate that the limit on dose from all man made sources of radiation combined will be met, and (2) the practical restrictions on site use that will be used and evaluations for other restrictions that were considered but not used.

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