decom proposed reg pt2

[ehsnet!hps (HPS)]

Reply-to: Roger.Moroney@p0.f13.n233.z1.fidonet.org (Roger Moroney)
Fido-To: hps

Approach in Preparing the GEIS

In preparing the GEIS, the NRC has presented the decision bases, analyses, and 
preliminary conclusions and recommendations regarding a preferred regulatory 
alternative for establishing radiological criteria for decommissioning.  In summary, the 
approach is as follows:

(1)  A reasonable listing is developed of alternative regulatory actions to establish
     radiological criteria for decommissioning.  The regulatory alternatives considered
     are listed above.

(2)  For each of the regulatory alternatives, the GEIS presents a detailed analysis and
     comparison of:  (1) incremental impacts, both radiological and nonradiological, to
     workers, members of the public, and the environment, resulting from each
     alternative, and (2) the incremental costs associated with each regulatory
     alternative.

(3)  Based on the analyses of impacts and costs, the GEIS provides preliminary
     recommendations on radiological criteria for decommissioning.

Preliminary Recommendations

The following principal preliminary recommendations, discussed below, are presented in 
the GEIS:

(1)  Definition of Decommissioning

     The current NRC definition of decommissioning requires that, at the end of
     operations and completion of decommissioning activities, the license must be
     terminated and the facility must be released for unrestricted use.  It is
     recommended that this definition of decommissioning be revised to provide for
     termination of a license and release of property under restricted conditions (see
     Item #2(c) below).

(2)  Establishment of Radiological Criteria for Decommissioning

     It is recommended that a tiered approach be used for establishing radiological
     criteria for decommissioning.  This tiered approach would combine elements of
     objectives or goals, limits, return to background, and restricted use alternatives. 
     This tiered approach is outlined below.

     (a) Objectives and Use of Natural Background - A proposed rule should establish
     a decommissioning objective.  The objective would be to reduce the concentration
     of individual radionuclides in structures, soils, and other media which could
     contribute to residual radioactivity from licensed operations to a level that is
     indistinguishable from background radiation for that radionuclide.  Based on the
     analyses in the GEIS, it would be extremely difficult as a practical matter to
          demonstrate that such an       objective had been met.  Therefore, the following section describes establishme 
nt
     of a site release limit and demonstration that residual radioactivity at the site is as
     far below the limit as reasonably achievable.

     (b) Limit on Unrestricted Use - A proposed rule should establish a dose limit for
     unrestricted release of the site and should also require licensees to demonstrate
     that residual radioactivity has been reduced below the limit to levels that are as
     low as reasonably achievable.  A total effective dose equivalent (TEDE) of 15
     mrem/yr is considered to be a reasonable dose limit because it provides a
     substantial margin of safety below the NRC's dose limit for members of the
     public.  This limit takes into account recommendations of national and
     international standards setting bodies and those criteria promulgated by the
     Environmental Protection Agency (EPA) and NRC which provide acceptable
     criteria for areas where unrestricted access in the vicinity of facilities is permitted,
     such as generally acceptable environmental standards and the criteria used for
     remediation of contaminated sites under the Superfund program.

     In addition to meeting a limit, licensees should also reduce contamination below
     the limit to levels which are as low as reasonably achievable (ALARA).  Use of
     ALARA allows reduction in the contamination remaining at the site by taking
     into account economics and concomitant risk reduction for site-specific situations. 
     Analyses in the GEIS indicate that there may be situations where there could be
     reductions in impacts which could be achieved below the 15 mrem/yr limit at
     reasonable cost.

     (c) Restricted Use - As noted above, it is recommended that a proposed rule
     should broaden the definition of decommissioning to include release for restricted
     use.  Licensees unable to meet the requirements for unrestricted use would be
     allowed to request permission to release sites for restricted use with subsequent
     termination of the license if they can demonstrate that certain conditions are met. 
     Restrictions on the subsequent use of certain sites could provide an additional
     measure of public protection and be useful in dealing with facilities with site-
     specific differences from the generic analyses.

(3)  Site-Specific Societal or Environmental Issues

     It is recognized that special environmental or cultural issues may be associated
     with a particular decommissioning action which would require more stringent
     implementation of the requirements.  Sites on or contiguous to historical sites or
     Native American lands that contain religious or sacred areas are examples of such
     special issues.  These issues can best be handled on a site-by-site basis as part of
     the decommissioning plan review process, and as part of the NRC's environmental
     review under NEPA.  Where necessary, the provisions for public comment and for
     a site-specific advisory board with representation of local citizens (see Item #5
     below) would provide a mechanism for local citizens and other affected parties to
     be directly involved in addressing these issues.

(4)  Citizen Participation

     It is recommended that the public not only be fully informed of the
     decommissioning actions at a particular site but also be able to effectively
     participate in site decommissioning decisions.  In particular, for decommissioning
     where the licensee does not propose to meet the conditions for unrestricted use, it
     is recommended that licensees obtain advice from affected parties regarding the
     proposed decommissioning.  A means for accomplishing this would be to convene
     a site-specific advisory board.

(5)  Minimization of Contamination

     It is recommended that this rulemaking require that there be specific attention
     given to design features and procedures that facilitate decommissioning the site,
     reduce the amount of radioactive waste, and minimize the overall public risk
     associated with decommissioning.
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