decom proposed reg pt1

[ehsnet!hps (HPS)]

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

The NRC is proposing to amend part 20 to include specific decommissioning criteria. 
A Draft Generic Environmental Impact Statement (GEIS) has been issued for comment. The NRC 
is asking for comment in the GEIS, whether these standards should be codified as an ammendment 
to part 20 or to leave things as they are. I have included the summary statement from the 
GEIS below. I apologize for the length of this message but they say it better than I can. This 
will affect all licensees. I have also uploaded the complete text in WP 5.2 for windows 
format. It is available also in ascii but not in one piece. The zipped file is 1.3 MB. I 
don't think we can afford to let this go through without our input(eg the death of BRC). 
Comments may be uploaded directly to the NRC BBS. The # is 1-800-880-6091, 8 N 1 up to 9600 baud.
 That is also where I got this. The name of the file is geis-wp5.zip 
Roger Moroney
                                  SUMMARY

Background

The Nuclear Regulatory Commission (NRC) has the statutory responsibility for 
protecting health and safety and the environment related to the possession and use of 
source, byproduct, and special nuclear material under the Atomic energy Act.  The NRC 
believes that one portion of this responsibility is to assure safe and timely 
decommissioning of the nuclear facilities used in conjunction with NRC-licensed 
activities.  This responsibility can be partially fulfilled by providing guidance to licensees 
on how to plan for and prepare their sites for decommissioning.

Once licensed activities have ceased, existing NRC regulations require licensees to 
decommission their facilities so that their licenses can be terminated and the property 
released for unrestricted use.  This requires that radioactivity in buildings, equipment,
soil, groundwater, and surface water resulting from the licensed operation be reduced to 
levels low enough to allow license termination.  Licensees must then demonstrate by a 
site radiological survey that residual contamination in all facilities and environmental 
media has been properly reduced to acceptable levels.  The NRC conducts confirmatory 
surveys, where appropriate, to verify that sites meet NRC radiological criteria for 
decommissioning.

Proposed Action

The action being considered in this draft Generic Environmental Impact Statement 
(GEIS) is an amendment to the Nuclear Regulatory Commission's regulations in 10 CFR 
Part 20 to include radiological criteria for decommissioning of lands and structures at 
nuclear facilities.

Need for the Proposed Action

Current NRC regulations do not contain explicit radiological criteria for 
decommissioning.  At present, the NRC continues to use criteria and practices described 
in several NRC guidance documents which have been in use for a number of years.  This 
approach ensures protection of public health and safety by guiding decommissioning 
decisions and generally keeping potential radiological doses to a small fraction of NRC's 
public dose limit given in 10 CFR Part 20.  However, both the number and complexity of 
facilities that will require decommissioning are expected to increase.  Therefore, the 
NRC believes that it is necessary for radiological criteria for decommissioning to be 
codified in its regulations to allow it to more effectively carry out its function of 
protecting public health and the environment at decommissioned sites by providing a 
clear and consistent regulatory basis for determining the extent to which radioactive 
contamination must be removed or reduced in lands and structures before a site can be 
released and the license terminated.
 Purpose of this GEIS

Under the National Environmental Policy Act (NEPA), all Federal agencies must 
consider the effect of their actions on the environment.  It is the intent of NEPA to have 
Federal agencies incorporate consideration of environmental issues into their decision-
making process.  To fulfill NRC's responsibilities under NEPA, the Commission has 
prepared this GEIS which analyzes alternative courses of action and the costs and 
impacts associated with those alternatives.

Scope of the Generic Environmental Impact Statement

This GEIS analyzes regulatory alternatives for establishing radiological criteria for 
decommissioning structures and lands of licensed facilities.  The alternative regulatory 
courses of action analyzed in the GEIS include continuation of existing decommissioning 
practices (i.e., the "no regulatory change" alternative) and rulemaking alternatives that 
could amend the NRC's regulations in 10 CFR Part 20.  These rulemaking alternatives 
include setting residual criteria at certain limits or goals using a risk basis, requiring that 
a site's residual contamination be returned to background conditions, requiring that there 
be restrictions on future use of sites, and requiring the use of best available remediation 
technologies.

The scope of the GEIS includes nuclear facilities licensed by the NRC that require 
decommissioning including those involved with the nuclear fuel cycle and those licensed 
to use nuclear material for other non-fuel cycle related purposes.  The types of nuclear 
fuel cycle facilities that require decommissioning include nuclear power plants, nonpower 
reactors, fuel fabrication plants, uranium hexafluoride production plants, and 
independent spent fuel storage installations.  Non-fuel cycle facilities include universities,
medical institutions, radioactive source manufacturers, and companies that use 
radioisotopes for industrial purposes (about 75% of NRC's non-fuel-cycle materials 
licensees use either sealed radioactive sources or small amounts of short-lived radioactive 
materials).

The scope of the GEIS considers both radiological and nonradiological impacts on 
human health and safety, including radiation exposure resulting from occupancy of site 
buildings and residence on site lands and radiation exposure during decommissioning and 
waste transport for disposal.  Nonradiological impacts on humans, such as those resulting 
from conventional workplace accidents and from traffic accidents during transport of 
decommissioning wastes for disposal, are also considered.  Waste disposal impacts, as 
well as impacts on biota, economic impacts, societal impacts, and land use impacts are 
addressed.

The GEIS does not analyze site-specific issues which may arise in the decommissioning 
process.  Instead, its principal intent is to provide a decision analysis leading to 
establishment of technical requirements for acceptable residual radioactive contamination 
levels for decommissioning.  Depending on the particulars of the specific facility, portions 
of the GEIS analysis may be applicable to the NEPA process for a specific site.


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