**NRC INSPECTION MANUAL** NMSS/DWMEP

MANUAL CHAPTER 2602

DECOMMISSIONING OVERSIGHT AND INSPECTION PROGRAM

FOR

FUEL CYCLE FACILITIES AND MATERIALS LICENSEES

2602-01 PURPOSE

To establish policies and guidance for the decommissioning oversight and
inspection program for the Office of Nuclear Material Safety and
Safeguards (NMSS) for NRC licensed fuel cycle and materials facilities
and non-licensed materials facilities.[^1]

2602-02 OBJECTIVES

02.01 To provide general guidance for the coordination and regulatory
oversight of NRC licensed fuel cycle and materials facilities undergoing
decommissioning.

02.02 To provide general guidance for planning and conducting
inspections of NRC licensed fuel cycle and materials facilities
undergoing decommissioning.

02.03 To obtain information through direct observation and verification
of licensee activities to determine whether the facility or site is
being decommissioned safely, that radioactive material is safely stored
onsite prior to removal from the site, and that decommissioning
activities are in conformance with applicable regulatory requirements,
licensee and non-licensee commitments, and management controls.

02.04 To ensure that the programs and techniques for license termination
activities are adequate and in accordance with regulatory requirements.
These programs include in part and as necessary, management and
organization effectiveness; self-assessment, auditing and corrective
actions; maintenance and surveillance; radiation protection;
radioactivity measurements; and effluent controls.

02.05 To identify declining trends in licensee performance and perform
inspections to verify that the licensee has resolved the issue(s) before
performance declines below an acceptable level.

02.06 To provide for effective allocation of resources for the
inspection of NRC licensed fuel cycle and materials facilities
undergoing decommissioning

To meet these objectives, and assist individuals involved in
decommissioning nuclear facilities, NRC staff has developed NUREG-1757,
Consolidated NMSS Decommissioning Guidance, Volumes 1-3, which summarize
the regulations, policies, and procedures that the NRC staff shall use
during the decommissioning of NRC licensed fuel cycle and materials
facilities. This manual chapter summarizes the basic framework for the
inspection of these decommissioning facilities, while NUREG-1757
provides the framework for the overall regulatory oversight process used
to ensure an adequate and consistent decommissioning of the
decommissioning facilities.

2602-03 APPLICABILITY

This manual chapter applies to all NRC licensees under 10 CFR Parts 30,
40, 70 and 72 undergoing decommissioning. The principal regulations and
policy governing such decommissioning are: (1) General Requirements for
Decommissioning Nuclear Facilities, Final Rule, 53 FR 24018, June 27,
1988, which incorporated changes into 10 CFR Sections 30.4, 30.35,
30.36, 40.4, 40.36, 40.42, 70.4, 70.25, 70.38, 72.3, 72.18, and 72.38;
(2) Timeliness in Decommissioning of Materials Facilities, Final Rule,
59 FR 36026, July 15, 1994, which incorporated changes into 10 CFR
Sections 30.4, 30.36, 40.4, 40.42, 70.4, 70.38, 72.3, and 72.54; and (3)
License Termination Rule, Final Rule, 62 FR 39058, July 21, 1997, which
incorporated the final rule on "Radiological Criteria for License
Termination" as Subpart E to 10 CFR Part 20. Various guidance documents
are referenced in this inspection program and should be utilized by NRC
inspection staff for applicability to each site undergoing
decommissioning.

2602-04 DEFINITIONS

04.01 [ALARA.]{.underline} Acronym for "as low as is reasonably
achievable," which means making every reasonable effort to maintain
exposures to radiation as far below the dose limits as is practical,
consistent with the purpose for which the licensed activity is
undertaken, and taking into account the state of technology, the
economics of improvements in relation to the state of technology, the
economics of improvements in relation to the benefits to the public
health and safety, and other societal and socioeconomic considerations,
and in relation to utilization of nuclear energy and licensed materials
in the public interest (see 10 CFR 20.1003).

04.02 [Complex Materials Site.]{.underline} A site or facility where the
complexity of the decommissioning will require more than minimal
technical and administrative support from the headquarters program
office. It is expected that these sites will take more than a year to
complete the decommissioning process. Examples of complex materials
sites include: sites with ground water contamination; sites containing
significant soil contamination; sites in which the owners are in
bankruptcy; any site where a decommissioning plan is required; all fuel
cycle facilities undergoing decommissioning; and sites where there is
significant public and/or Congressional interest.

04.03 [Confirmatory Survey.]{.underline} A survey conducted by NRC, or
its contractor, to verify the results of the licensee's final status
survey. Typically, confirmatory surveys consist of measurements at a
small percentage of the locations previously surveyed by the licensee,
to determine whether the licensee's results are valid and reproducible.

04.04 [Decommissioning]{.underline}. The process of removing a facility
or site safely from service and reducing residual radioactivity to a
level that permits (1) the release of the property for unrestricted use
or (2) release of the property under restricted conditions. For licensed
facilities or sites, decommissioning includes termination of the license
or amending the license to remove the facility or site as a location of
use from the license. For non-licensed sites, decommissioning includes
documenting in correspondence to the site owner that the facility or
site is released for unrestricted use.

04.045 [Decommissioning Plan (DP).]{.underline} A detailed description
of the activities that the licensee intends to use to assess the
radiological status of its facility, to remove radioactivity
attributable to licensed operations at its facility to levels that
permit release of the site in accordance with NRC's regulations and
termination of the license, and to demonstrate that the facility meets
NRC's requirements for release.

04.06 [Final Status Survey (FSS).]{.underline} Measurements and sampling
to determine the radiological conditions of a site or facility,
following completion of decontamination activities (if any) and in
preparation for release of the site or facility.

04.07 [Master Inspection Plan.]{.underline} A site-specific plan of
inspection activities that ensures the inspection program is properly
focused and facilitates the efficient allocation of inspection
resources.

04.08 [Significant Decommissioning Activity.]{.underline} Any
decommissioning activity that the NRC feels compelled to observe and
evaluate to ensure the protection of workers, ensure the protection of
public health and safety or the safety of the environment, ensure the
secure use and management of radioactive materials, or ensure openness
in the regulatory process.

2602-05 RESPONSIBILITIES AND AUTHORITIES

05.01 [Director, Office of Nuclear Materials Safety and
Safeguards.]{.underline} Provides overall direction for the
decommissioning fuel cycle and materials inspection program.

05.02 [Chief, Decommissioning Directorate.]{.underline} Coordinates,
develops, and implements decommissioning fuel cycle and materials
inspection requirements and policies.

05.03 [Regional Administrator]{.underline}. In concert with
headquarters, directs the implementation of the inspection program for
decommissioning fuel cycle and materials facilities and sites. Ensures,
within budget limitations, that the regional office staff includes
adequate numbers of inspectors in various disciplines to carry out the
inspection program as assigned and described in this chapter. Applies
inspection resources, as necessary, to deal with issues and problems
that arise at specific facilities undergoing decommissioning.

05.04 All NRC personnel implementing the decommissioning oversight and
inspection program for fuel cycle and materials facilities undergoing
decommissioning shall use the guidance identified in this manual chapter
and NUREG-1757. This includes formerly licensed sites where the license
was terminated, and sites involving source, special nuclear, or
byproduct material subject to NRC regulation for which a license was
never issued. Significant deviations from this guidance shall be
employed only after review and approval by the appropriate NRC
management.

05.05 The responsibility for managing inspection activities and
conducting inspections resides with the regional office in which the
decommissioning facility or site is located. Regional management is
responsible for developing the inspection program for each
decommissioning facility or site under it's jurisdiction. The Division
of Waste Management and Environmental Protection (DWMEP), in the Office
of Nuclear Material Safety and Safeguards (NMSS), will provide overall
program direction to the regional offices for decommissioning
facilities. The Division of Waste Management and Environmental
Protection will provide oversight guidance to the regions to ensure that
decommissioning activities are being conducted in a consistent and
adequate matter to achieve the NRC Strategic Plan.

2602-06 DECOMMISSIONING PROGRAM OVERSIGHT

06.01 [Timing of Decommissioning.]{.underline} NRC regulations at 10 CFR
30.36(d), 40.42(d), 70.38(d), and 72.54(d) describe the conditions under
which a licensed facility would be required to commence decommissioning
operations. Collectively, these are known as the Timeliness Rule. In
short, any separate building or area that has not been used for two
years must be promptly remediated if the remediation activities are
allowed by the existing license. If the remediation activities are not
currently allowed under an existing license, the licensee must develop a
Decommissioning Plan (DP) and submit a request for a license amendment
within one year. The decommissioning process is to be completed within
two years, unless an alternative schedule is approved. Section 5 of the
NUREG-1757 Vol. 1 provides guidance on how to determine if
decommissioning is needed and the actions necessary to achieve it.

06.02 [Radiological Criteria for Decommissioning.]{.underline} On July
21, 1997, NRC published the final rule on "Radiological Criteria for
License Termination" (the License Termination Rule) as Subpart E to 10
CFR Part 20 (62 FR 39058). The License Termination Rule (LTR)
establishes criteria for license termination. The criterion for
termination with unrestricted release is residual radioactivity, which
is distinguishable from background, results in a total effective dose
equivalent (TEDE) to an average member of a critical group that does not
exceed 0.25 millisievert per year (mSv/y) (25 mrem/y). In addition, the
residual radioactivity has been reduced to levels that are as low as is
reasonably achievable (ALARA). For license termination with restrictions
on future land use, the LTR establishes criteria of 1.0 mSv/y (100
mrem/y) or 5.0 mSv/y (500 mrem/y) under certain conditions.

06.03 [Decommissioning Records Management.]{.underline} NRC regulations
prescribe recordkeeping responsibilities for NRC licensees. During
licensed operations NRC requires licensees to maintain records important
to safe and effective decommissioning. For licensees who must submit a
DP, these records should subsequently be used to develop the site
description specific portion of the DP. Following decommissioning and
before license termination, additional NRC regulation prescribe the
disposition of these records, in most cases to NRC. Finally, NRC staff
is responsible for maintaining decommissioning records following license
termination. NRC staff should refer to Section 3 of NUREG-1757 Vol. 3
for information on recordkeeping requirements for decommissioning
facilities.

06.04 [The National Environmental Policy Act of 1969.]{.underline} The
National Environmental Policy Act (NEPA) of 1969 requires Federal
Agencies, as part of their decision-making process, to consider the
environmental impacts of actions under their jurisdiction. Both the
Council on Environmental Quality (CEQ) and NRC have promulgated
regulations to implement NEPA requirements. The CEQ regulations are
contained in 40 CFR Parts 1500 to 1508, and NRC requirements are
provided in 10 CFR Part 51. The NEPA review (also referred to as the
environmental review) process for decommissioning is initiated by a
licensee's request for a license amendment to decommission. NRC staff
should refer to Section 15.7 of NUREG-1757 Vol. 1 and NUREG-1748,
Environmental Review Guidance for Licensing Actions Associated with NMSS
Programs, for information on the appropriate procedures to follow to
comply with NEPA.

06.05 [Decommissioning Groups.]{.underline} Activities to decommission a
site depend on the type of operations conducted by the licensee and the
residual radioactivity present. Generally, the staff will evaluate the
decommissioning of nuclear facilities using one of seven review
processes (referred to as "Groups"). Typically, Groups 1 and 2 will not
require a DP and will be able to demonstrate compliance with 10 CFR Part
20.1402. Group 3 sites will require an abbreviated DP, without a
site-specific dose modeling analysis. Group 4 through 7 sites and all
Part 72 licensees are required to submit a DP with site-specific dose
modeling in accordance with NRC regulations in 10 CFR 30.36(g)(1),
40.42(g)(1), 70.38(g)(1), or 72.54(d). Although it is anticipated that
most licensees will fall under the decommissioning types as outlined, it
should be expected that the actions may not always be appropriate for
each licensee. The intent is to present the generally appropriate
actions to be taken by NRC staff, recognizing that the unique nature of
some facilities may require site- specific modifications to the
procedures. The staff shall ensure that any departure from these
established procedures is reviewed and approved by NRC management and
documented in writing prior to their implementation. NUREG 1757 Vol. 1,
Sections 7 through 14, contain guidance for the determination of the
appropriate decommissioning review process and the actions and oversight
required by group.

06.06 [Decommissioning Plans.]{.underline} The objective of the DP is to
describe the activities and procedures that a licensee intends to
undertake to remove residual radioactive material attributable to
licensed activities at the facility to levels that meet NRC criteria in
sufficient detail to allow NRC staff to determine whether
decontamination of the facility can be accomplished safely. To the
extent that licensed material is mingled with elevated (i.e., above
background levels) naturally occurring radioactive material (NORM) the
elevated NORM is also remediated in decommissioning. NRC regulations at
10 CFR Parts 30, 40, 70, and 72 require that certain information be
provided by licensees in the DP. NUREG 1757 Vol. 1, Sections 16 through
18 provide a description of the contents of specific DP modules, as well
as evaluation and acceptance criteria for use in reviewing DPs and other
information submitted by licensees to demonstrate that the facility is
suitable for release in accordance with NRC requirements.

a.  [Site Characterization.]{.underline} NRC requirements for
    decommissioning under 10 CFR 30.36(f)(4), 40.42(f)(4), 70.38(f)(4),
    and 72.54(f)(1), require that proposed DPs include \"\...a
    description of the conditions of the site or separate building or
    outdoor area sufficient to evaluate the acceptability of the plan.\"
    Licensees can develop this information using institutional knowledge
    about radioactive material use at their facility, by performing a
    site characterization survey, or by a combination of these methods.
    Some licensees may require heightened attention by NRC staff during
    characterization planning. For these licensees it may be appropriate
    for NRC staff to meet with the licensee prior to, or during, site
    characterization. NRC staff should refer to NUREG-1757 Vol. 2 for
    additional discussion of site characterization.

b.  [Financial Assurance for Decommissioning.]{.underline} NRC
    regulations at 10 CFR 30.35, 40.36, 70.25, and 72.30 specify the
    requirements for certain licensees to provide financial assurance
    for decommissioning. The requirement to provide financial assurance
    is based on the authorized possession limits specified in the NRC
    license. In general, above a threshold quantity of radioactive
    material, the licensee must provide increasing amounts of financial
    assurance as its authorized possession limit increases. Financial
    assurance may be provided in certain proscribed amounts where the
    authorized possession limit falls within specified bounds. NRC staff
    should refer to Section 4 of NUREG-1757 Vol. 3 for additional
    discussion of financial assurance.

c.  [Final Status Survey Plans.]{.underline} Licensees wishing to
    terminate their licenses must demonstrate to NRC that residual
    radioactive material at their facility attributable to past licensed
    operations does not exceed NRC criteria for release of the facility.
    NRC regulations at 10 CFR 30.36(f)(4), 40.42(f)(4), 70.38(f)(4) and
    72.54(f)(4) require that all DPs contain a description of the
    planned final radiation survey to demonstrate that the facility
    meets NRC\'s criteria for release and termination of the license. In
    addition, NRC regulations at 10 CFR 30.36(I), 40.42(I), 70.38(I) and
    72.54(k) describe the information that must be submitted to NRC to
    support a demonstration that a licensed facility is suitable for
    release from regulatory control.

d.  [License Termination.]{.underline} The final action required by the
    licensee after it has completed remediation and adequately
    demonstrated that the facility is suitable for release in accordance
    with NRC\'s requirements is the submission of NRC Form 314. If the
    licensee has satisfied all of the conditions for remediating its
    site, NRC staff terminates the license for the site. For sites with
    non-radiological contamination, NRC should inform the State agency
    that may have jurisdiction over any hazardous chemical contamination
    and the U.S. Environmental Protection Agency about the intent to
    terminate the license. In addition, the termination is intended as
    final agency action and should include appropriate language in the
    termination letter to reflect this intent.

e.  [Restricted Use and Alternate Criteria.]{.underline} NRC staff will
    review the information supplied by the licensee to determine if the
    description of the activities undertaken by the licensee is adequate
    to allow the staff to conclude that the licensee has complied with
    the applicable requirements of 10 CFR 20.1403, or 10 CFR 20.1404 for
    those licensees who intend to request termination of their
    radioactive materials licenses using either the restricted use or
    alternate criteria provisions of Subpart E. The basic requirement
    for license termination under restricted conditions is that the
    licensee provide institutional controls that limit the calculated
    dose to 0.25 mSv/y (25 mrem/y). Further, the licensee must reduce
    residual radioactivity so that if these controls fail, the
    calculated dose would not exceed 1 mSv/y (100 mrem/y). In rare
    instances, the calculated dose may exceed 1 mSv/y (100 mrem/y), but
    it may not exceed 5 mSv/y (500 mrem/y). Additional institutional
    controls would be established to meet regulatory requirements. In
    the unlikely event that a licensee is not able to reduce residual
    radioactivity to a level that limits the calculated dose such that
    it is not in excess of 0.25 mSv/y (25 mrem/y) with restrictions in
    place, the licensee may request permission from the Commission to
    use alternate criteria. NRC staff should refer to NUREG-1757 Section
    17.7 for guidance on restricted use and alternate criteria.

f.  [Partial Site Decommissioning.]{.underline} A licensee who has
    submitted a DP that has not yet been approved or a licensee who has
    an approved DP may opt to release a portion of its site early. For
    the case of partial site release, the licensee must submit a request
    for a license amendment to the extent that the actions are not
    described in the DP. A site enters into partial site decommissioning
    in one of two ways: the licensee requests a portion of its facility
    be removed from the license, or; a licensed facility is required per
    10 CFR 30.36(d)(1-4), 40.42(d)(1-4), 70.38(d)(1-4), and
    72.54(d)(1-3) to begin decommissioning at a portion of its facility.

2602-07 DECOMMISSIONING INSPECTION PROGRAM

07.01 [Program Discussion]{.underline}. The decommissioning fuel cycle
and material inspection program covers a diverse range of
decommissioning activities. The level of complexity varies from complex
sites requiring remediation of ground water contamination to the less
complex sites only requiring verification a radiological laboratory
meets the unrestricted release criteria prior to license termination. It
is anticipated that fuel cycle facilities will require a defined,
substantial decommis­sioning effort, requiring the submittal of a
decommissioning plan. In contrast, most of the non-fuel cycle materials
licensees have facilities which, for the most part, will not require
submittal of a formal decommissioning plan for NRC review and approval
and will not be a major effort. Because of this wide range of
decommissioning activities and safety considerations, this manual
chapter promulgates inspection program requirements and guidance
necessary to provide reasonable assurance that NRC regulatory oversight
contributes to public health and safety for a broad array of
decommissioning activities. This inspection program focuses on ensuring
that:

-   Licensee documents are adequately implemented, maintained, and
    reflect the status of decommissioning.

-   Licensee activities, organization, and controls are effective to
    provide reasonable assurance that decommissioning can be conducted
    safely and in accordance with regulatory requirements.

-   NRC staff project oversight and inspection resources are effective,
    consistent, and appropriately focused.

-   Licensee radiation and radioactivity measurement programs provide
    accurate quantification and classification of radioactivity.

The management of decommissioning sites will be shared between the
regions and the headquarters program office. Normally, DWMEP will
project manage the complex materials decommissioning sites, and
non-complex materials decommissioning sites will be managed in the
regional offices.

07.02 [Timing and Frequency of Inspections]{.underline}. The
decommissioning inspection program is formally initiated when the
licensee is required to begin decommissioning under NRC regulations. The
inspection program continues until the site, including all buildings and
other structures and outdoor areas, are remediated in accordance with
NRC requirements and the appropriate licensing action is completed,
which could be license termination or amendment, or documentation the
site is being released for unrestricted use if it is a non-licensed
entity.

The frequency of inspections will vary depending on the decommissioning
activities taking place. In determining the inspection frequency, the
region should factor in the radiological history of the licensee, the
licensee's past performance, the licensee's planned schedule of
activities, the potential for the decommissioning activities to affect
the health and safety of workers and the public, and the level of public
interest. Inspections should be scheduled to allow the inspector to
observe, at a minimum, all significant decommissioning activities.
Inspection of significant activities can include activities such as:
observing the removal or dismantlement of equipment that possess a high
source term; conducting confirmatory measurements that coincide with the
licensee's surveying activities, particularly for situations where no
other reasonable opportunity will exist; verifying licensee compliance
with license commitments, decommissioning plans, regulatory
requirements, or procedures; following up on previously identified
violations or other identified weaknesses; evaluating performance
following a significant change in the licensee or contractor work force;
a routine inspection prior to an upcoming public meeting or; a special
inspection to address public concerns. It is expected that once a region
has developed an acceptable level of confidence in a licensee's
performance, the frequency of inspections would be reduced. Periodically
verifying continued good performance and compliance with regulatory
requirements and commitments is acceptable and expected. However, the
inspector should not repeatedly review the same area when no procedural
or program changes have occurred, or no performance problems have been
noted.

Some sites have separate buildings and outdoor areas where licensed
activities have ceased and are being decommissioned, while licensed
activities continue to be conducted at other site locations. In these
cases, inspections of the locations being decommissioned can be
coordinated with inspections of routine operations or be performed
independent of operations at the discretion of the inspection staff.

Although inspections are expected to be conducted at sites that are
being actively remediated, there are times when inspections or site
visits are warranted even though there is little to no site remediation
taking place. For example, when a significant amount of public, State
and/or Congressional interest exists, inspections and visits may be
warranted to ensure that regional staff and management have first hand
knowledge of the condition of a site as well as familiarization with
licensee personnel. In other cases, no inspection activities may be
needed. For example, a formal inspection is normally not necessary for a
license termination for a medical practitioner licensed to use a sealed
source, where the decommissioning effort is essentially the removal of
the source from the licensee\'s facility. In addition, if no
decommissioning activites are being conducted at the site, such as if
the site owner is developing a decommissioning plan, an inspection is
not warranted. The minimum inspection frequency for a site in a standby
or possession-only status with no ongoing remediation activities will be
determined by DWMEP management on a case-by-case basis and in
conjunction with Regional office management prior to the Regional staff
performing the inspections. For sites where major decommissioning
activities are occurring such as the active remediation of structures,
soils, or groundwater, inspections shall be scheduled to conform to
significant decommissioning activities. Because of the nature and
variance of decommissioning activities it is not efficient or effective
to establish minimum inspection frequencies applicable to every
situation. For major decommissioning efforts that involve large
quantities of contaminat­ed soil, groundwater contamination, onsite
disposal, extensive surface contamination, dismantlement of major
buildings and structures, or the potential for significant worker or
public exposures, at least one inspection should be conducted while the
site is being characterized. For such major efforts, the inspection
schedule should also include an inspection during remediation of key
buildings, equipment, and outdoor areas, and during and after the
licensee\'s final survey. In general, inspections may be conducted more
frequently if necessary to verify that work and public exposures are
maintained ALARA.

07.03 [Master Inspection Plan.]{.underline} At the onset of the
decommissioning of a complex materials site, a Master Inspection Plan
(MIP) should be developed. The purpose of the MIP is to ensure that the
inspection program is properly focused and that sufficient resources are
available to conduct the inspections when necessary. The MIP should be
based on the expected schedule of licensee activities, and should
include inspections of all significant decommissioning activities. The
regional lead inspector is responsible for developing the MIP, and he or
she shall obtain the agreement of the cognizant DWMEP Project Manager
(PM) for those complex sites being project managed by DWMEP before
conducting the inspection. The inspection schedule provided in the MIP
should be reviewed every 6-12 months and modified as needed to reflect
changes in licensee schedules.

The MIP should provide the inspections that are planned, the activity or
program area being inspected, the procedure(s) that will be used to
conduct the inspections, and the approximate time frame for when the
inspection is expected to occur.

Some factors that should be considered while developing and implementing
a master inspection plan include: unique or challenging decommissioning
approaches and procedures or hydrological conditions (such as diversion
of the radiological effluent stream, excavation of contaminated soils
from below a water table, or dredging of soils from outfalls or
intakes); licensee performance; staffing plans; public interest;
transportation of radioactive waste; effectiveness of management
oversight and contractor control; decommissioning funding, and; the
timing and scheduling of significant decommissioning activities.

07.04 [Periodic Management Visits to Meet with Licensee
Representatives]{.underline}

For significant decommissioning projects, NRC headquarters and regional
management should consider visiting the facility to understand the
licensee\'s plans to decommission their facility. Licensee programs for
the control and handling of radioactive materials, licensee staffing,
public interest, experience and expertise, and the master inspection
plan, are possible topics of discussion.

As decommissioning progresses, additional site visits may be held
periodically or prior to major changes in the status of decommissioning
to gain licensee management insights and perspectives. The intent of
these visits is to understand licensee plans and schedules, and the
controls implemented to provide quality, cost management, and safety.
Performance elements involving radiation dose, curie removal and
transportation, scheduler accuracy, and nuclear and radiological safety
could be discussed to ascertain the licensee\'s assessment of their own
performance. Discussions could include the dissemination of press and
public information; status of site radiological surveys, results and
problems; problems associated with staffing and contractors; and,
storage and transportation of radioactive material.

The NRC maintains an "open door" policy with regard to access by the
public or state or local officials to the NRC staff or to publicly
available electronic documentation concerning a licensee's performance.
Some local officials or community groups may desire increased
interaction with the NRC's staff and inspectors. The degree of
interaction that is considered necessary to ensure openness in the NRC's
decommissioning program is expected to vary widely depending on the
situation at each decommissioning site. In each case where inspectors
are utilized for this purpose, regional management must carefully
balance the use of inspection resources to complete inspections with the
need to enhance public confidence.

07.05 [Extent of Licensee Decommissioning Activities]{.underline}. When
a licensee is able to use existing approved procedures to perform
decommissioning activities, the inspector should be able to perform
inspections using the same routine inspection procedures that were used
during operational inspections. In these cases, a closeout inspection
using Inspection Procedure (IP) 83890 can be used when license
termination is requested. A few of the non-fuel cycle facilities,
however, such as manufacturers of radiochemicals and certain research
and development institutions, will typically require significant
decommissioning efforts by the licensees and significant inspection
activities by NRC inspection staffs. For these decommissionings,
activities should be inspected using IP 87104, and supplemented with
other procedures as necessary. Section 07.14 lists specific existing
inspection procedures applicable to decommissioning.

07.06 [Security and Control of Contaminated Material]{.underline}.
Inspections conducted throughout decommissioning shall continue to
assess licensee security and control of contaminated material.
Inspections shall verify that contaminated material at licensed and
unlicensed sites undergoing decommissioning is secured and controlled in
accordance with 10 CFR 20.1801, and posted in accordance with 10 CFR
20.1902. Containers of contaminated materials shall be labeled in
accordance with 10 CFR 20.1904 and 20.1905. Contaminated materials in
buildings shall be secured and controlled by locking buildings, rooms,
or areas. Contaminated materials in outside areas shall be secured and
controlled by fencing or soil covers. Eight foot cyclone-type fencing is
generally acceptable. Other fencing types, such as barbed wire fences,
may be sufficient in low population, rural areas. Three to four foot
thick soil covers over contaminated soil, slag, or tailing piles are
also generally acceptable. Access to buildings, rooms, or indoor and
outdoor areas having contaminated materials shall be limited only to
individuals having the licensee\'s or responsible party\'s permission
for access.

Normally, decommissioning activities will not involve materials subject
to safeguards requirements. On decommissioning sites that do involve
materials subject to safeguards requirements, safeguards inspections
should be coordinated with decommissioning inspections on an as needed
basis.

07.07 [Inspection Coordination]{.underline}. Prior to performing
inspections at a site undergoing decommissioning, the regional inspector
should coordinate inspection activities, as appropriate, with the
following personnel and organizations:

-   For sites that are project managed by DWMEP, inform the cognizant
    DWMEP Project Manager (PM) who has responsibility for the site of
    the inspection. Offer the PM an opportunity to accompany the
    inspector during inspection.

-   For sites that are project managed by the regional office,
    coordinate with the regional lead inspector (or PM) who has
    responsibility for the site. If the inspector conducting the
    inspection is also the lead inspector (or PM), coordinate the
    inspection with regional management for overall content and
    scheduling considerations.

-   Contact the licensee and discuss inspection plans (unless the
    inspection is unannounced).

-   For sites with an NRC-approved decommissioning plan, where the
    environmental assessment for the decommissioning plan identifies
    Federal, State and other organizations interested in or affected by
    site activities, contacts should be made in accordance with
    established procedures at each site.

-   Coordinate with the U.S. Environmental Protection Agency or the
    appropriate State agency if the decommissioning involves hazardous
    wastes.

-   Coordinate requests for technical assistance for survey work to be
    performed by an NRC contractor through DWMEP. It is recommended that
    the need for contractor support be determined early in the
    decommissioning process to assist in resource planning.

07.08 [Scope of Inspections - General]{.underline}. It is recommended
that all significant activities of a particular site undergoing
decommissioning, including prior to, during, and after remediation, be
identified and inspected. Major efforts in the inspection program should
be focused on those activities where either data or experience indicate
that potential problems may exist. In most cases, field sampling and
independent measurements performed by inspection staff should be
consistent with that performed during routine surveys associated with
the use of licensed materials during operations at the site.

Inspectors should review environmental data related to airborne and
liquid effluent releases and groundwater sampling for compliance with
NRC standards and requirements. Airborne and liquid effluents should
meet 10 CFR Part 20 requirements. Groundwater monitoring should be
performed at sites with substantial volumes of contaminated soils, known
groundwater impacts, or onsite disposal areas. If groundwater
concentrations exceed US EPA interim maximum contamination levels for
radionuclides in public drinking water systems (40 CFR Part 141), NRC
hydrological staff should be consulted to evaluate the significance of
the groundwater contamination and the need for further groundwater
monitoring programs.

07.09 [Scope of Inspections Prior to Dismantlement]{.underline}. During
the typical decommissioning effort, there are planning and preparation
activities that occur prior to dismantlement and demolition that may
require inspection. Inspections may be conducted to: ensure proper
implementation of NRC-approved site characterization plans; audit the
Special Nuclear Material (SNM) inventory cleanout (for SNM licensees);
and ensure adequate management and security controls for the duration of
the decommissioning effort. In addition, the inspector should review the
license for any new conditions that may have been added for
decommission­ing.

07.10 [Scope of Inspections During Remediation and
Dismantlement]{.underline}. The remediation of structures, soil,
sediment, surface waters and groundwater, the dismantlement of buildings
and other structures, and the disposal of waste constitute the majority
of a typical decommissioning effort for sites with widespread
contamination. Inspections shall be conducted against NRC regulations,
approved decommissioning plans, and license conditions for key
decommissioning activities that are important for health and safety.
These activities may include: physical security; criticality safety;
essential systems and services; radiation protection for workers;
material control and accountability, if applicable; environmental
programs related to possible offsite releases of radioactive materials;
fire protection; onsite waste management prior to offsite disposition;
transportation of radioactive wastes for disposal; and implementation of
a licensee quality assurance program carried on throughout the
decommissioning process.

07.11 [Scope of Inspections After Remediation]{.underline}.
Decommissioning activities after remediation of the site include a
licensee-conducted final status survey and in some cases, an NRC
confirmat­ory survey.

a.  [Licensee Final Survey.]{.underline} As part of the decommissioning
    plan, the licensee will prepare a final survey plan. The purpose of
    the final survey will be to demonstrate compliance with the NRC
    decommissioning criteria. The final survey should include the
    licensed premises and offsite areas that were or may have been
    contaminated by the licensee\'s operations. Although the formal NRC
    review and acceptance of a licensee\'s final survey plan and report
    is performed by the NRC licensing Project Manager (or other
    equivalent staff), it is recommended that inspectors have adequate
    familiarity with these licensee documents to facilitate planning and
    executing inspections. As necessary to ensure confidence in the
    licensee\'s survey results, the inspection may include independent
    NRC analysis of the licensee\'s samples.

> A final survey and report may not be required if a licensee can
> demonstrate the absence of radioactive contamination in some other
> manner, such as documentation that the licensee used only sealed
> sources that never showed evidence of leakage.
>
> In most cases where a licensee is only decommissioning a few rooms or
> laboratories, the final status survey consists of conducting 100
> percent scans of the floors, walls, tabletops, and equipment, and the
> collection of wipe samples. Typically, a confirmatory survey is not
> required in these cases. However, depending on the adequacy of the
> surveys conducted, the quality of the final status survey report, the
> licensee's history of use, the isotopes used, the form of the
> isotopes, whether there were documented past spills, the potential for
> contamination in drains, or any other issue, the inspector must
> determine whether an NRC confirmatory inspection would be appropriate.
> If an inspection can be conducted during the licensee's final status
> survey (during which side-by-side surveys can be conducted) the need
> for a confirmatory inspection would in most cases be eliminated.
> However, many licensees have completed the final status survey prior
> to informing the NRC of the desire to release the areas for
> unrestricted use, so this is not possible.

b.  [Confirmatory Surveys.]{.underline} The purpose of the NRC
    confirmatory survey is to perform an audit of the licensee\'s final
    survey results to independently confirm that the licensee\'s final
    survey report is accurate and representative of site conditions. In
    most cases a comprehensive confirmatory survey will be performed
    following the decommissioning of a complex material site. However,
    based on the frequency, types, and results of in-process
    inspections, Regional management may decide that a confirmatory
    inspection is not necessary. Examples where a confirmatory survey
    would almost always be conducted would be: (1) an in-process
    inspection of the licensee\'s final survey program identifies
    multiple weaknesses; (2) repetitive violations are identified during
    the decommissioning process; (3) significant public or Congressional
    interest exists; or (4) in-process inspections were not conducted.

> NRC confirmatory surveys should not be used to demonstrate, for the
> licensee, compliance with NRC residual contamination standards. The
> licensee always retains responsibility for compliance. The licensee\'s
> final survey plan and report should be adequate to demonstrate the
> condition of the site before any confirmatory survey is conducted by
> NRC or its contractor. Licensee surveys and NRC confirmatory surveys
> may be conducted in phases as decommissioning proceeds.
>
> Prior to arranging a confirmatory survey, the inspector should review
> the documentation of decommissioning activities and the results of the
> licensee\'s final radiological survey. Any questions or concerns that
> the inspector might have concerning the survey should be communicated
> to the licensee (through the DWMEP PM where appropriate) for
> substantiation or clarification. When such issues are resolved to the
> inspection staff\'s satisfaction, a written confirmatory survey plan
> should be prepared, and the survey conducted at the earliest possible
> date. Unresolved issues related to the adequacy of the licensee\'s
> final survey report should be communicated to DWMEP staff before
> conducting a confirmatory survey.
>
> Confirmatory surveys may be performed by regional staff or by
> technical assistance contract support. In most cases, contractor
> support will not be necessary. The use of a contractor may be
> justified if one of the following conditions exist: (1) the
> licensee\'s final survey involves unique or complex technical issues,
> (2) the confirmatory survey is expected to require significant
> resources to complete field surveys and sampling, or (3) the
> confirmatory survey is a very high priority that cannot be completed
> by NRC staff in a timely manner. In addition to the three conditions
> listed above, there may be other site-specific considerations that
> justify the use of a contractor. Contractual support should be
> coordinated through DWMEP. Inspectors should be onsite for at least
> part of the confirmatory surveys performed by contractors. .
> Coordination with contractors should be initiated at the earliest time
> to develop high quality plans for the confirmatory surveys. Regional
> staff shall contact the HQ staff manager responsible for the contract
> to arrange the confirmatory survey

c.  [Multi-Agency Radiation Survey and Site Investigation
    Manual.]{.underline} For most sites that are undergoing significant
    decommissioning activities, particularly at those sites where a
    decommissioning plan has been approved, the final status survey is
    performed using the guidance provided in NUREG-1575, (Rev 1)
    Multi-Agency Radiation Survey and Site Investigation Manual
    (MARSSIM). MARSSIM provides a standardized approach for planning,
    conducting, evaluating, and documenting radiological surveys to
    demonstrate compliance with regulatory requirements. Because MARSSIM
    uses a statistically derived decision making process to assess and
    interpret the adequacy of the survey and sample results, under
    certain conditions, a confirmatory survey may not be necessary.
    However, this increases the need for the inspector to verify the
    adequacy of the licensee's survey and sampling program. This is done
    by evaluating the licensees survey, sampling and counting
    procedures, as well as the adequacy of the analytical laboratory
    counting the samples. Inspections should also be conducted when the
    licensee is conducting surveys and collecting samples so that
    side-by-side surveys can be performed, split samples can be
    collected, and the licensee's survey and sampling technique's can be
    observed and evaluated. The goal is verify that the final status
    survey demonstrates compliance with the License Termination Rule.

07.12 [Basic Inspection Process]{.underline} In addition to the
information given below, additional guidance regarding the basic
inspection process can be found in Inspection Manual Chapter 2800. All
inspections should be conducted in a similar manner in accordance with
headquarters staff instructions and regional administrative processes.

The inspection starts with the planning of inspections in the master
inspection plan, as described in Section 07.03. Implementation of the
MIP also includes the coordination of site visits and inspections to
promote regulatory efficiency and effectiveness and to reduce regulatory
burden on the licensee. Then, inspections are conducted, inspection
reports are written, license performance is assessed, feedback on the
decommissioning inspection program should occur, and this process should
repeat until the site is decommissioned. A basic inspection process
should entail:

-   Preparation for the inspection by reviewing appropriate background
    material (e.g., license, license file, decommissioning plan, past
    inspection reports, allegations, and other pertinent information).

-   Preparation of an inspection plan describing the scope and major
    areas of emphasis that will be reviewed, evaluated, or assessed.
    This plan should be reviewed by a supervisor.

-   Inspectors shall utilize appropriate and calibrated radiation
    detection instrumentation or any other equipment to verify licensee
    activities, if applicable for the inspection. *In-situ* measurements
    with licensee personnel can be beneficial in future determinations
    as to the scope of confirmatory surveys required for the facility.

-   Inspectors shall conduct an entrance meeting with the licensee.
    Inspectors should discuss the inspection scope with licensee
    management and articulate whether open items will be reviewed. The
    inspector should state that the inspection may involve the
    observation of facility operations, interviews with staff, document
    reviews, and/or radiation surveys to obtain independent and
    confirmatory data. Any change or potential change to the onsite
    inspection plan should be communicated with appropriate NRC
    management.

-   Although unique plant conditions may exist following the permanent
    cessation of operations, NRC inspectors should not face situations
    in which license conditions, regulatory requirements, or licensee
    commitments do not apply. In cases where unique situations or
    unclear configurations may be identified and considered potentially
    adverse to the conduct of safe decommissioning or public health and
    safety, the inspector(s) should discern whether the licensee is
    aware of the situation and taking appropriate action, if necessary,
    to correct and preclude recurrence. Such cases or problems involving
    NRC requirements and licensee commitments should be raised to the
    responsible NRC manager. Equally important, the inspector should
    determine if the situation is beyond the scope of the inspector\'s
    expertise. If it is beyond the inspector\'s expertise, the inspector
    should promptly inform his or her supervision and make
    recommendations, so that management can determine the urgency of the
    request for assistance, what type of expertise is required, and what
    extent of effort is required.

-   An exit meeting shall be conducted with licensee management at the
    conclusion of the inspection. The inspection scope and applicable
    findings shall be presented emphasizing their impact on safety.

-   Upon return to the regional office, the appropriate supervisory
    personnel should be briefed on the inspection findings and
    conclusions.

-   Inspection findings, open items, follow-up items, and conclusions
    shall be documented in accordance with Manual Chapter 0610 and other
    relevant regional instructions. Inspections resulting from
    allegations will be documented and dispositioned in accordance with
    Management Directive 8.8.

Because decommissioning involves the reduction of residual radioactivity
to a level that permits release of the property and license termination,
inspections at decommissioning facilities should act as a historical
record of the licensee\'s ability to effectively and accurately conduct
radiological surveys and characterizations, manage occupational dose,
maintain the facility licensing and design basis, and control
radiological effluents. This record should help focus inspections in
areas of licensee performance directly related to site release and
license termination activities.

07.13 [Documentation of Inspections]{.underline} The inspection staff
shall fully document, in the form of either a written report or NRC Form
591M, all visits to and inspections of each site undergoing
decommissioning. Inspectors should be certain to document the results of
the inspection activities related to the security and control of
radioactive materials and reviews of environmental data (airborne and
liquid effluent releases and groundwater sampling data).

07.14 [IMCs and IPs for the Decommissioning Program]{.underline} The NRC
Inspection Manual Chapters (IMCs) and procedures (IPs) listed below are
applicable and are recommended for inspections at sites undergoing
decommissioning. These documents should be used as guidelines for
inspectors in determining the inspection requirements for
decommissioning and radiological safety aspects of various types of
licensee activities. The core decommissioning IPs are annotated with an
(\*). The other listed procedures are used on an "as needed" basis.

[Document Number]{.underline} [Title]{.underline}

IMC 0610 \"Nuclear Material Safety and Safeguards Inspection Reports\".

IMC 2800 \"Materials Inspection Program\".

IP 83822 \"Radiation Protection\".

IP 83890\* \"Closeout Inspection and Survey\".

IP 84850 \"Radioactive Waste Management - Inspection of Waste Generator
Requirements of 10 CFR Part 20 and 10 CFR Part 61\".

IP 84900 \"Low-Level Radioactive Waste Storage\".

IP 86740 \"Inspection of Transportation Activities\".

IP 87103 \"Inspection of Materials Licensees Involved in an Accident
Incident or Bankruptcy Filing\".

IP 87104\* "Decommissioning Inspection Procedure for Materials
Licensees".

IP 88005 \"Management Organization and Controls\".

IP 88015 \"Headquarters Nuclear Criticality Safety Program\".

IP 88025 \"Maintenance and Surveillance Testing\".

IP 88045 \"Environmental Protection\".

IP 88050 \"Emergency Preparedness\".

IP 88055 \"Fire Protection\".

IP 93001 \"OSHA Interface Activities\".

In addition to the procedures described above, inspection staffs should
also use other existing parts of the NRC Inspection Manual that are
routinely used on typical inspections and which are included in IMC 2600
and IMC 2800. For example, these may include: IP 90712, on in-office
reviews of events; and IPs 92701, 92702, and 92703, on followup on
inspection problems and licensee violations.

END

[^1]: Throughout this manual chapter, unless stated otherwise, any
    reference to a licensee or licensed facility also applies to all
    non-licensed (and/or formerly licensed) materials facilities at
    which the decommissioning is being conducted under NRC oversight.